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

Summary

The court accepted special-action jurisdiction and held that offensive issue preclusion does not apply in Arizona attorney disciplinary proceedings unless the governing disciplinary rules provide for preclusive effect. A civil sanctions order therefore could not conclusively establish facts against Hancock, although the disciplinary judge could consider the order and related evidence if Hancock received an opportunity to contest it. The court vacated the partial-summary-judgment order and remanded for further proceedings.