Attorney Leila L. Hale was reprimanded by the State of Michigan Attorney Disciplinary Board for mishandling her client’s property and causing them harm. The board issued a notice on Friday, June 30, 2023, stating that Hale was negligent in managing her client’s funds and deprived them of access to their money for a long period of time.
The case is entitled “In the Matter of Leila L. Hale,” with case no. 23-16-RD.
In an order of reprimand dated February 17, 2023, it was stated that the State Bar of Nevada challenged a decision by the Southern Nevada Disciplinary Board to issue the respondent a letter of caution for violating professional conduct rules. The violations included mishandling client funds and terminating representation improperly. The State Bar argued for additional violations, but the hearing panel disagreed. After review, it was agreed that Hale committed the violations, but a public reprimand was deemed appropriate based on the nature of the misconduct and relevant factors.
The State Bar had to provide clear and convincing evidence for the violations, but some of their claims were not supported by substantial evidence. Hale was found to have violated rules regarding safekeeping client property and terminating representation, but not for pressuring clients to settle matters or charging unreasonable fees. The panel’s decision for a letter of caution as a discipline was upheld, considering factors like Hale’s mental state and the harm caused to clients. The most serious violation was Hale’s negligent handling of client property, which caused actual harm to the client by depriving them of funds for an extended period. Consequently, a public reprimand was imposed by the Supreme Court of Nevada as the appropriate discipline for Hale.
The order of reprimand states:
“The State Bar also challenges the hearing panel’s decision that a letter of reprimand is the appropriate discipline based on Hale’s violations of RPC 1.15 (safekeeping property) and RPC 1.16 (declining or terminating representation) and instead seeks a suspension. To determine the appropriate discipline, we weigh four factors: “the duty violated, the lawyer’s mental state, the potential or actual injury caused by the lawyer’s misconduct, and the existence of aggravating or mitigating factors.” In re Discipline of Lerner, 124 Nev. 1232, 1246, 197 P.3d 1067, 1077 (2008). The panel’s recommendation is persuasive, but we review the disciplinary recommendation de novo. SCR 105(3)(b); In re Discipline of Schaefer, 117 Nev. 496, 515, 25 P.3d 191, 204 (2001). When multiple violations are at issue, “[t]he ultimate sanction imposed should at least be consistent with the sanction for the most serious instance of misconduct.” Standards for Imposing Lawyer Sanctions, Compendium of Professional Responsibility Rules and Standards, 452 (Am. Bar Ass’n 2018) (ABA Standards).”
The order of reprimand continues:
“We conclude that the most serious violation is Hale’s failure to safe keep the property, a violation of RPC 1.15(a). We further conclude that she acted negligently, rather than with knowledge, and that her actions violated duties owed to her clients and to the profession. We agree with the State Bar that Hale caused actual injury with the potential for further injury because her misconduct deprived her client of access to and use of funds to which the client was entitled for more than two years. See, e.g., In re Obert, 282 P.3d 825, 842-43 (Or. 2012) (concluding that the failure to disburse funds injured the client by causing “anxiety and aggravation” as well as “actual, financial harm”). For negligent handling of a client’s property causing injury or potential injury, the baseline discipline is a public reprimand. See ABA Standard 4.13 (recommending a reprimand when an attorney acts negligently in safekeeping a client’s property and causes injury or potential injury). The aggravating and mitigating factors do not warrant deviating from that baseline.”
Following this discipline of the respondent in the state of Nevada, the Grievance Administrator filed a notice of reciprocal discipline against the respondent in the state of Michigan. Upon consideration, The Board issued an order on April 3, 2023, regarding the imposition of reciprocal discipline, instructing the parties to provide written notification within 21 days of receiving the order. However, the 21-day period lapsed without any objections or hearing requests from either party. Hence, a reprimand was issued.
The Disposition states:
“On May 25, 2023, the Attorney Discipline Board ordered that respondent be reprimanded. Costs were assessed in the amount of $1,509.00.”
Ms. Hale is listed in the law firm Hale Injury Law as a practicing attorney. She attended the University of Illinois College of Law, graduating in 2000. She practices in Henderson, Nevada. She is licensed in Nevada and Michigan with license no. 79801. Her info can be found on Linkedin.
A copy of the original filing can be found here.