In the Matter of a Member of the Bar of the Supreme Court of Delaware: Christopher S. Koyste, Esquire, Respondent

Summary

The Court upheld the Board’s finding that Christopher Koyste knowingly violated a protective order by directing his investigator to show discovery photographs to the defendant and the defendant’s wife. The Court concluded that Koyste’s participation in drafting the clear order, repeated reminders of its terms, and failure to review it supported knowing misconduct despite his claimed failure to remember the order’s exact language. The Court approved and adopted the Board majority’s recommendation of a public reprimand because the violation created potential harm to a vulnerable victim and actual injury to the legal system.