Brent Randall Phillips v. Hon. o'neil/state Bar

Summary

The Court accepted special-action jurisdiction and held that Arizona Rule of Evidence 408 bars use of a consent judgment’s stipulated facts to establish liability in a later disciplinary proceeding, including use for impeachment. Rule 613(b) could not independently authorize admission because the judgment was inadmissible under Rule 408. The Court vacated the disciplinary judge’s order and directed that the judgment not be used in the disciplinary proceedings.