State ex rel. Oklahoma Bar Ass'n v. Haave, 2012 OK 92

Bar Association filed a complaint against attorney Christian Roll-ow Haave for alleged abandonment of three clients after payment for services.
Panel of Professional Responsibility Tribunal deemed the allegations admitted due to Respondent's failure to respond or appear.
Allegations: failure to inform clients of continuances and reasons for withdrawal; failure to transmit decrees; failure to complete work and return unearned fees.
Investigator testified Respondent did not meaningfully engage, attributing issues to illness but no supporting medical records were provided.
PRT found violations of RPC 1.3, 1.4, 1.5, 3.2, 8.4(d) and RGDP 5.2 and recommended suspension for two years; court conducts de novo review.
Court suspended Respondent from practice for two years and ordered costs of $516.19 to be paid within 90 days; costs to be a reinstatement condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether respondent committed professional misconduct	Haave abandoned three clients and charged unearned fees	Respondent did not meaningfully respond; illness explained her conduct	Yes; clear and convincing evidence of misconduct found
Proper discipline for misconduct	Two years and a day suspension appropriate	Less discipline or Rule 10 consideration possible due to incapacity	Two-year suspension appropriate
Whether due process was satisfied for de novo review	Record was complete and properly noticed; defaults warranted de novo review	Rule 10 considerations not pursued; potential incapacity not adequately addressed	Due process satisfied; court may conduct de novo review
Role of Rule 10 personal incapacity proceeding	Rule 10 options were available to address incapacity	Bar should have pursued Rule 10 to safeguard public; not done here	Rule 10 not pursued; nonetheless suspension upheld under RPC/RGDP framework
Cost recovery associated with discipline	Costs should be assessed against respondent	Not opposed; no explicit argument beyond communication failures	Costs of $516.19 imposed and to be paid; condition for reinstatement

State ex rel. Oklahoma Bar Ass'n v. Whitebook, 242 P.3d 517 (Okla. 2010) (emphasizes prompt and adequate response to misconduct allegations)
State ex rel. Oklahoma Bar Ass'n v. Wilburn, 142 P.3d 420 (Okla. 2006) (discusses least-severe sanction appropriate and safeguards public)
State ex rel. Oklahoma Bar Ass'n v. Phillips, 786 P.2d 1242 (Okla. 1990) (precedent on disciplinary measures in comparable facts)
State ex rel. Oklahoma Bar Ass'n v. McCoy, 912 P.2d 856 (Okla. 1996) (reserved disbarment for irreparable client harm; context for sanctions)