Graeme Hancock v. Hon. o'neil/state Bar of Arizona

Summary

The Arizona Supreme Court accepted special-action jurisdiction and held that offensive issue preclusion does not apply in attorney disciplinary proceedings unless authorized by the Arizona Supreme Court's disciplinary rules. The court concluded that a civil sanctions order therefore could not prevent Hancock from contesting the underlying facts in his disciplinary case, although the order and related proceedings could be admitted as evidence. The court vacated the disciplinary judge's order and remanded for further proceedings.