Supreme Court of Colorado

In the Matter of Attorney G.

April 22, 20132013 Colo. LEXIS 290

Summary

The court held that its plenary authority permitted review of the dismissal of an attorney-discipline complaint even though the disciplinary rules did not provide an ordinary appeal from such a dismissal. It further held that the retaining-lien statute does not authorize an attorney to retain a United States passport to secure payment of legal fees, and that no other law permitted withholding the passport under the applicable professional-conduct rule. The court left the dismissal in place but disapproved the Hearing Board's rationale.