No Bar Discipline for Yoo:

An interesting report from Jan Crawford Greenburg:

News reports yesterday made much out of the fact that a draft report about the so-called “torture memos” doesn’t recommend criminal prosecution for DOJ officials John Yoo and Jay Bybee, but instead would only refer them to their state bars for disciplinary proceedings.

Setting aside that my friend Mike Isikoff reported this back in February, the flurry of reporting is baffling for another reason: It appears John Yoo cannot be disciplined or disbarred for writing those memos, even if the Office of Professional Responsibility says it has evidence he should be.

That’s because OPR’s five-year investigation—carefully timed for release only as Bush was leaving the White House and Obama was coming in—dragged on too long. As a result of that timing, OPR blew the deadline for referring possible misconduct allegations against Yoo.

As for Bybee, Greenburg reports that neither DC nor Nevada has a comparable limitation period, "But how strange would it be to only refer Bybee, when his involvement largely amounted making a few edits and signing Yoo’s legal work?"

John Yoo is admitted to the bar in Pennsylvania. But the Pennsylvania Disciplinary Board, which would investigate any complaints against him, imposes a four-year limitation for complaints.

Yoo wrote the memos in 2002 and 2003. This is 2009. You do the math.

Roy C (mail):
If advising a pardon is grounds for disbarment, I don't see how the current presidential pardon system, or heck any modern pardon system, can continue to function.
5.7.2009 8:50am
MR:
Couldn't Yoo also be subject to discipline in DC? I thought when you practice law in a state, you're subject to that state's disciplinary laws (even when you're not admitted there). See Rule 8.5(a):

Disciplinary Authority. A lawyer admitted to practice in this jurisdiction is subject to the disciplinary authority of this jurisdiction, regardless of where the lawyer's conduct occurs. A lawyer not admitted in this jurisdiction is also subject to the disciplinary authority of this jurisdiction if the lawyer provides or offers to provide any legal services in this jurisdiction. A lawyer may be subject to the disciplinary authority of both this jurisdiction and another jurisdiction for the same conduct.
5.7.2009 8:52am
Anderson (mail):
The first question, is, Does the PA Bar have any equivalent to the discovery rule?

That still doesn't help on the first August 2002 memo, which I believe was leaked in May 2004 (and is the more egregious of the two); but I don't see how a memo kept secret until April 2009 can be said to have had its deadline run in 2007.
5.7.2009 8:53am
RPT (mail):
Does Pennsylvania have a tolling provision for concealment of the alleged misconduct? There are reports that Yoo (not a member of the CA or DC Bar) and Bybee (and Bradbury) have sought to block, delay and/or water down the content of the OPR Report, perhaps with this result in mind. What is the limitations period in Nevada? Was Yoo required to join the DC Bar to practice with the OLC?
5.7.2009 8:53am
Anderson (mail):
MR, I'm not clear that Yoo was ever admitted to practice in D.C. -- is that even a requirement to work at OLC?

Note: It should be.
5.7.2009 8:54am
Mountaineer (mail):
I don't think whether or not it is "strange" to pursue Bybee but not Yoo is relevant. The question should be whether or not it is appropriate to pursue such action against Bybee. I won't pretend to know whether it is. But suggesting that he shouldn't be punished because someone else isn't sounds like the reasoning of a 9 year old complaining to his mother. And beyond that Jan Crawford Greenburg certainly makes light of the importance of signatures.
5.7.2009 8:54am
Just an Observer:
Anderson,

MR seems to make a good point about Yoo's exposure to discipline in D.C. whether he ever was admitted there or not. He certainly did "provide[] ... legal services in [that] jurisdiction."

BTW, if you follow the link to Greenburg's blog post, you will find a link to the Pennsyvania rules. It would be helpful to this discussion if someone could post the equivalent for D.C. and Nevada.
5.7.2009 9:09am
ruuffles (mail) (www):

signing Yoo’s legal work

Oh cmon! That's just ridiculous on its face. Is he going to assert he never bother to read the documents he was signing?
5.7.2009 9:17am
Philistine (mail):

MR, I'm not clear that Yoo was ever admitted to practice in D.C. — is that even a requirement to work at OLC?


I think the reference was to:


A lawyer not admitted in this jurisdiction is also subject to the disciplinary authority of this jurisdiction if the lawyer provides or offers to provide any legal services in this jurisdiction.


Presumably, the memos and other legal services were provided in DC.

Also-the McDade Amendment states: "An attorney for the Government shall be subject to State laws and rules, and local Federal court rules, governing attorneys in each State where such attorney engages in that attorney’s duties, to the same extent and in the same manner as other attorneys in that State."

The definition of "attorney for the Government" is given in 28 CFR § 72.2, and appears on a quick glance to be broad enough to cover Yoo.
5.7.2009 9:18am
Just an Observer:
And beyond that Jan Crawford Greenburg certainly makes light of the importance of signatures.

I agree. She is stretching that point rather shamefully. Bybee's signature as head of the office was quite significant.

The reporter is definitely wearing her sympathies on her sleeve in this blog post. Perhaps that kind of advocacy is acceptable in a journalist's blog, which is more like an opinion column than a news report.
5.7.2009 9:19am
Anderson (mail):
Ah, JaO &Philistine are right -- I was reading MR too hastily.

I'm not clear at all about what that discipline could be. Presumably PA isn't going to let D.C. make the call as to disbarring Yoo, for ex? Or is that how it works?

I agree. She is stretching that point rather shamefully. Bybee's signature as head of the office was quite significant.

Damn straight. She should read Rule 11 sometime.
5.7.2009 9:27am
Houston Lawyer:
What is the DC bar going to do to Yoo, disbar him? He was never a member. Go after him for the unauthorized practice of law? I imagine that a large number of attorneys that work for the federal government in DC never get admitted to the DC bar. Does anyone think that the trainload of attorneys that Obama has hired since January are all admitted to the DC bar or plan to refrain from giving legal advice until after they are so admitted?
5.7.2009 9:34am
Just an Observer:
Given the immediate doubts that have been raised here about the sufficiency of Jan Crawford Greenburg's conclusion, I respectfully suggest that the headline of this blog post above

No Bar Discipline for Yoo:

should be changed to

No Bar Discipline for Yoo?
5.7.2009 9:47am
One Man's View:
The DC Bar choice of law rule seems clear: "If the lawyer is licensed to practice in this and another jurisdiction, the rules to be applied shall be the rules of the admitting jurisdiction in which the lawyer principally practices; provided, however, that if particular conduct clearly has its predominant effect in another jurisdiction in which the lawyer is licensed to practice, the rules of that jurisdiction shall be applied to that conduct." The Legal Ethics Committee opinion on choice of law for non-judicial matters is Opinion 311.

Assuming (and it is by no means clear) that the McDade amendment has the effect of directing the DC Bar to treat Yoo like a DC-barred lawyer, the opinion, as I read it would apply the law of his admitting jurisdicition in which he principally practices. That would be Pennsylvania, save that he probablyd oesn't practice there — so we would then apply a predominant effects test and who knows where the predominant effects would lie.

More importantly, since Yoo is not a member of the DC Bar, the only action the DC Bar could take would be to refer him to Pennsylvania ....
5.7.2009 9:47am
Upend, Coming:
Two points:

1. Is it possible that the SoL cannot be used as a shield if the report was deliberately delayed? or
2. Is it possible that the SoL runs when the document becomes declassified?

I mean, its the same sort of catch-22 argument that the Gov't used, successfully for a time, in the state secret charity case.

If you make it illegal to reveal the objectionable material until it is declassified, then SoLs could be abused to avoid prosecution by a gov't figure misusing the classification powers.
5.7.2009 9:56am
innocent bystander (mail):
Berkeley: No soup for Yoo, either.
5.7.2009 10:03am
Smooth, Like a Rhapsody (mail):
Maybe I am missing something, but this talk of concealment misses the point that the "person" whom these rules are designed to protect are, first, clients--Yoo's client got the memos right away, so no concealment there; or possibly a finder of fact--and there being no pending, or even contemplated, litigation, that does not seem useful, either.
5.7.2009 10:09am
Just an Observer:
One Mamn's View: ... so we would then apply a predominant effects test and who knows where the predominant effects would lie.

Are you seriously arguing that the "predominant effects" of Yoo's opinions at OLC were in Pennsylvania?
5.7.2009 10:10am
stoshy (mail):
Can someone cite precisely the disciplinary rule Yoo &Bybee are supposed to have violated?

I have not conducted any systematic research on the topic, but in my experience, it is exceptionally rare for an attorney to be disciplined for poor substantive advice or substandard lawyering. Almost all disciplinary actions in New York, for example, involve either embezzlement of client funds from escrow accounts, convictions of crime, or neglect of client matters, or some variant of the above. They are invariably clear-cut open-and-shut matters, quickly concluded, and designed to speedily suspend or disbar lawyers who are clearly incompetent, wholly indifferent to their clients' needs, or whose conduct otherwise presents a continuing palpable threat to the client community.

On the other hand, prosecutors who unlawfully withhold exculpatory evidence, defense lawyers who render “ineffective assistance” to their clients, lawyers who botch estate plans by ignoring germane estate tax regulations, attorneys who miss statutes of limitations or other filing deadlines to their clients’ permanent detriment - none of these is professionally disciplined.

In the criminal arena, unacceptable lawyering by prosecutors or defenders can result in the vacatur of the underlying conviction, and though they may suffer reputational damage, the attorneys are free to continue practicing law without fear of answering to disciplinary authorities. On the civil side, substandard practices can be remedied by legal malpractice actions, which abound these days. And lawyers who lose malpractice actions against them are not suspended or disbarred as a result.

I can offer a guess as to why disciplinary authorities normally don’t involve themselves in sanctioning attorneys for poor lawyering. First, there are other remedies available (noted above), and the authorities do not want to be used as indirect collection agencies for aggrieved clients. Second, most disciplinary authorities are understaffed, not well-paid, and do not attract top-drawer legal talent — they do not feel competent to second-guess practitioners, particularly when so many lawyering choices are matters of judgment about which reasonably competent &experienced lawyers can disagree. Third, sanctioning lawyers for judgment calls would result in unduly protracted litigation, invariably devolving into inconclusive battles of legal experts. Fourth, sanctioning attorneys for erroneous substantive judgment calls can too easily drift into sanctioning attorneys who either bring controversial lawsuits or who defend unpopular causes.

So, again, precisely which disciplinary rule in which jurisdiction have Yoo and Bybee violated?
5.7.2009 10:29am
Prosecutorial Indiscretion:
What is the DC bar going to do to Yoo, disbar him? He was never a member. Go after him for the unauthorized practice of law? I imagine that a large number of attorneys that work for the federal government in DC never get admitted to the DC bar. Does anyone think that the trainload of attorneys that Obama has hired since January are all admitted to the DC bar or plan to refrain from giving legal advice until after they are so admitted?

A great many, maybe most, federal attorneys in DC are not members of the DC bar. There's no requirement that they join so long as their only client is the federal government (incidentally, that seems to be the case in a great many jurisdictions, though generally local federal offices have internal rules that their attorneys be members of the local bar).
5.7.2009 10:30am
Joe T Guest:

MR, I'm not clear that Yoo was ever admitted to practice in D.C. -- is that even a requirement to work at OLC?

Note: It should be.


How do you figure? Lawyers in an exclusively federal practice are not required to gain admission in the state where they are physically practicing. This lets the government handle federal matters in a uniform manner, at least in theory. To change it, you'd need to be able to articulate a rule that is uniformly applicable, not just targeting John Yoo or a particular office. The alternatives I came up with are requiring licensure, 1) any place a lawyer sits; 2) any place a lawyer does work; 3) any place a lawyer's work has substantial effects. #1 would have the effect of making it extremely difficult for government lawyers to have a national practice. Engaging in multi-district enforcement litigation, for instance, might require a large team of attorneys to take several bar exams each, and / or pay waive-in fees, where reciprocity is available. # 2 is a failure for similar reasons, again especially in practices involving multiple districts or travel. #3 would be remarkably unworkable, requiring many lawyers on the policy side (like Yoo) to be licensed in 50 states and a number of territories.

The final issue is DC Bar membership isn't exactly like getting into the Skull and Bones or for that matter most other state bars. They have 50 state reciprocity. You fill out some paperwork, pay some money, demonstrate you're licensed to practice somewhere else, and they let you in. There are some sharp cookies running the D.C. Bar and they offer some of the best CLE around thanks to the wealth of talent they draw from for instructors, but it isn't quite the selective and prestigious body that a lot of state bars (supervised by eminent appellate courts and with high barriers to entry) are. They do debar a lot of attorneys for embezzlement of client funds though, I'll give 'em that.
5.7.2009 10:32am
U.Va. Grad:
Are you seriously arguing that the "predominant effects" of Yoo's opinions at OLC were in Pennsylvania?

Whatever the predominant effects may be, the important part of One Man's View's comment is probably the end--what can DC do to him, other than refer him for sanctions to a jurisdiction that can't sanction him any more?
5.7.2009 10:32am
cmugirl (mail):
Yoo did not have to be licensed in DC.

DC Bar Rule 49(c) lists exceptions to those who need to be licensed to practice law in DC.

(c) Exceptions. The following activity in the District of Columbia is excepted from the
prohibitions of section (a) of this Rule, provided the person is not otherwise engaged in the practice of law or holding out as authorized or competent to practice law in the District of Columbia:

(1) United States Government Employee: Providing authorized legal services to the United States as an employee thereof;

(2) United States Government Practitioner: Providing legal services to members of the public solely before a special court, department or agency of the United States, where:

(A) Such legal services are confined to representation before such fora and other conduct reasonably ancillary to such representation;

(B) Such conduct is authorized by statute, or the special court, department or agency has adopted a rule expressly permitting and regulating such practice; and

(C) If the practitioner has an office in the District of Columbia, the practitioner expressly gives prominent notice in all business documents of the practitioner’s bar
status and that his or her practice is limited consistent with this section (c).

(3) Practice Before a Court of the United States: Providing legal services in or reasonably related to a pending or potential proceeding in any court of the United States if the person has been or reasonably expects to be admitted to practice in that court, provided that if the practitioner has an office in the District of Columbia, the practitioner expressly gives prominent notice in all business documents of the practitioner’s bar status and that his or her practice is limited consistent with this section (c).
5.7.2009 10:42am
NTB24601:
Based solely on the plain language of the four-year statute of limitations in Pa.R.D.E. 85.10, I don't think that it applies to John Yoo's case.
§85.10. Stale matters.

(a) General rule. The Office of Disciplinary Counsel or the Board shall not entertain any complaint arising out of
acts or omissions occurring more than four years prior to the date of the complaint, except as provided in subsection (b).

(b) Exceptions. The four year limitation in subsection (a) shall:

(1) Not apply in cases involving theft or misappropriation, conviction of a crime or a knowing act of concealment.

(2) Be tolled during any period when there has been litigation pending that has resulted in a finding that the
subject acts or omissions involved civil fraud, ineffective assistance of counsel or prosecutorial misconduct by the respondent-attorney.


The torture memos were knowingly concealed; they were classified. Jan Crawford Greenburg's characterization of the concealment exception as requiring "that the lawyer concealed a crime" is not supported by the plain language of Pa.R.D.E. 85.10: the exception plainly requires only an act of concealment. The reference to conviction of a crime is connect with a disjunctive, showing that crimes are a different exception rather than a component of the concealment exception.

I'm not familiar with how the disciplinary board has interpreted this rule, however. Perhaps the board has limited it in the way that Ms. Greenburg suggests; although, that would strike me as a poor interpretation of the rule. A better counter argument in favor of Yoo, I think, would be to contend that the rule requires that the knowing concealment be a component of the attorney's unethical conduct. If the board interprets the rule that way then I think Yoo is protected: the concealment was done by Yoo's client (the United States), not by Yoo himself.

While I'm uncertain how this rule has been interpreted, I don't think the plain language alone protects Yoo.
5.7.2009 10:50am
Uh_Clem (mail):
Oh cmon! That's just ridiculous on its face. Is he going to assert he never bother to read the documents he was signing?

Why not? That defense strategy seemed to work for
Alberto Gonzales.
5.7.2009 11:03am
MarkField (mail):

I have not conducted any systematic research on the topic, but in my experience, it is exceptionally rare for an attorney to be disciplined for poor substantive advice or substandard lawyering.


It's not all that common, but it does happen. Many states now have self-reporting requirements which, for example, require lawyers to report sanctions awards above a certain level. The Bar can (and sometimes does) investigate these.

PA Bar Rule 1.1 requires competence in representation. I have no idea how that Bar enforces that rule (I'm in CA). Other relevant provisions include 2.1 and 8.4.
5.7.2009 11:04am
Ken Arromdee:
If this is true, then I say "tough".

While timing a prosecution for political expedience is common, we sometimes forget that it's not actually supposed to work that way. Doing it is a form of gaming the system. If you game the system and it turns out you messed up, you have only yourself to blame.
5.7.2009 11:09am
Waste93 (mail):
I'm not sure the McDade amendment applies. DC isn't a state.

Secondly if it does apply to any lawyer that is in DC could that not also seem to apply to all those politicians that are legislators in DC? That could have some interesting results.
5.7.2009 11:15am
NTB24601:
Waste93: "I'm not sure the McDade amendment applies. DC isn't a state."

That argument is addressed in the regulations interpreting the McDade amendment.
The phrase state laws and rules and local federal court rules governing attorneys means rules enacted or adopted by any State or Territory of the United States or the District of Columbia or by any federal court, that prescribe ethical conduct for attorneys and that would subject an attorney, whether or not a Department attorney, to professional discipline, such as a code of professional
responsibility. ....
28 CFR 77.2(h).
5.7.2009 11:25am
Connecticut Lawyer (mail):
Fortunately, the statute of limitations has not run on everything. I trust that Attorney General Holder, in his relenetless pursuit of wrongdoing without regard for politics, will hold accountable those individuals in DOJ who violated their professional and ethical obligations by leaking the confidential results of OPR investigations.
5.7.2009 11:34am
Splunge:
the flurry of reporting is baffling

Goodness, no it's not. If the Stalinists can't get you in court, they always go for the Two Minute Hate smear campaign option. In fact, in many cases, they go for the smear right away, as they're good at whipping that up, not being constrained by considerations of factualness, honesty, nor empathy.

A compelling good vs. evil narrative in the media beats a complicated legal case with a lot of yes but arguments in it, every time.
5.7.2009 11:40am
micdeniro (mail):
Let's see.

2009-2002=7

Given the limitations period in PA is 4,

7-4=3

Since 2x3<7, the limitations period has run.

Too bad Yoo isn't licensed in MA.
5.7.2009 11:42am
Just an Observer:
Philistine: The definition of "attorney for the Government" is given in 28 CFR § 72.2, and appears on a quick glance to be broad enough to cover Yoo.

Perhaps not. In my own reading of that CFR section, I could not find the Justice Department's Office of Legal Counsel (or, FWIW, the Office of Legal Policy) within that definition.
5.7.2009 11:48am
Anon21:
Ken Arromdee:
If this is true, then I say "tough".

While timing a prosecution for political expedience is common, we sometimes forget that it's not actually supposed to work that way. Doing it is a form of gaming the system. If you game the system and it turns out you messed up, you have only yourself to blame.

I'm not clear who is meant to have "tim[ed]" this "prosecution" (well, misconduct report, but whatever) "for political expedience." The Bush Administration? If you view foot-dragging with the intent of never having to deal with the issue as "timing," I suppose you could make that claim, but if so, it was an attempt to "time" it to Yoo and Bybee's benefit, so I'm not sure why it's so self-evident that the "mistake" should benefit them. If you mean the Obama Administration, the DoJ has been under their control for about four months. I don't know how long an OPR report generally takes to turn around, but four months hardly seems unreasonable, provided it is thorough. And more importantly, how can the timing of this report (and the leaks of its contents) be construed as "politically expedien[t]"? Is there some scandal the Obama DoJ is trying to push off the front page? Are Yoo and Bybee suddenly becoming particular thorns in the Administration's side?

All this to say that I can't see why a group of bad actors' decision to conceal other bad actors' misconduct until such time as it would be impossible to punish that misconduct should be construed as a case in which the latter bad actors "deserve" to get off because someone was "gaming the system." If anyone was indeed doing that, it was in order to help Yoo and Bybee.
5.7.2009 11:52am
NTB24601:
micdeniro: "Since 2x3<7, the limitations period has run."

Do you know of any Pennsylvania Disciplinary Board decisions, or other case law, that gets John Yoo around the exception for cases involving an act of knowing concealment?
5.7.2009 11:56am
Ken Arromdee:
I'm not clear who is meant to have "tim[ed]" this "prosecution" (well, misconduct report, but whatever) "for political expedience." The Bush Administration?

The original post says that


OPR’s five-year investigation—carefully timed for release only as Bush was leaving the White House and Obama was coming


That sounds like the release of the investigation was timed for the benefit of the prosecution (i.e. so it would be released under a more sympathetic Obama administration), not that it was being timed for the benefit of the defendants.
5.7.2009 12:02pm
Anderson (mail):
That sounds like the release of the investigation was timed for the benefit of the prosecution

Really? When it's timed so that the SOL may've run vs. Yoo?

When the Bush administration sat on it and wouldn't release it?

There is no way it really took FIVE YEARS to do that report. Or four. Or three. Or two.

Marginally more plausible trolling, please.
5.7.2009 12:04pm
micdeniro (mail):
NTB24601:

"micdeniro: "Since 2x3<7, the limitations period has run."

Do you know of any Pennsylvania Disciplinary Board decisions, or other case law, that gets John Yoo around the exception for cases involving an act of knowing concealment?"


Don't ask me. I'm just trying to win the thread.
5.7.2009 12:21pm
Sigivald (mail):
NTB: Isn't that concealment from the client?

As Smooth said earlier, while the memos were classified, they were not concealed from the party that commissioned them, which seems plainly to be the "concealment" that the Pa. regulation refers to.

If a lawyer conceals incompetence or illicit behaviour from a client (or opposing counsel or the court, in cases where there's a duty to reveal it), that sure sounds like something that should have no limitations.

But the fact that legal advice not concealed from its commissioner was kept secret by the party that commissioned it doesn't seem like it should open the lawyer up to sanctions later "because the public at large didn't find out about it, because the guy who PAID for it didn't tell anyone".

(Does that mean that if I got a Pa. lawyer to draft a will for me, and I never told anyone about it for a decade, then revealed it... that he could be notionally sanctioned for something in it because I concealed the will from the general public?

Of course, this doesn't really matter, because nobody has so far been able to explain what the notionally sanctionable content in Yoo's memos was...)
5.7.2009 12:32pm
Philistine (mail):

Philistine: The definition of "attorney for the Government" is given in 28 CFR § 72.2, and appears on a quick glance to be broad enough to cover Yoo.

Perhaps not. In my own reading of that CFR section, I could not find the Justice Department's Office of Legal Counsel (or, FWIW, the Office of Legal Policy) within that definition.



I assumed he would fall under "any attorney employed in, or head of, any other legal office in a Department of Justice agency."

Maybe not, though. The definition does seem to focus on enforcement, and § 77.3 seems to limit application to "In all criminal investigations and prosecutions, in all civil investigations and litigation (affirmative and defensive), and in all civil law enforcement investigations and proceedings" which doesn't seem to fit the memos.

Normally it comes up in the investigation/litigation context, which appears to be what the regs deal with.
5.7.2009 12:45pm
Just an Observer:
Anon21: I'm not clear who is meant to have "tim[ed]" this "prosecution" (well, misconduct report, but whatever) "for political expedience." The Bush Administration?

Greenburg apparently is hinting at (facilitating?) Andy McCarthy's line of attack, that OPR "is largely a bastion of the Left at DOJ," and therefore orchestrated the timing.

It looks like an Alley Oop PR play. If there is "old-fashioned politics" going on here, as Greenberg suggests, I am not sure she is not part of it -- knowingly or not. Quite clearly, she has taken sides in the matter.

The funny thing about that whole partisan conspiracy theory is this: If the SOL-like deadline definitely ran out on Yoo in 2007, why did Mukasey not raise that objection when the draft OPR report was presented to him in late 2008? Instead, he wrote a letter to accompany the report, and insisted that all the principals have a chance to reply. That kicked the hot potato into Holder's hands.
5.7.2009 12:46pm
cal ethics lawyer (mail) (www):
1. I don't see anything remotely close to "concealment" unless there's some yet undisclosed bombshell evidence showing a guilty conscience that hidden from the client during the representation. If the "concealment" was that the OLC memos were not made public, pursuant to lawful and appropriate DOJ decisions, then it can't be "concealment," can it?

2. Supposing that the PA statute ran and that only DC (which has no discipline SoL as I understand it) could have power to discipline. What SoL would DC apply? What's the choice of law on that? Would DC apply substantive ethics law of PA (yes, I think, but am no 100% certain), and would DC apply PA's SoL?

John Steele
5.7.2009 12:55pm
MarkField (mail):
If Yoo wrote the memo as part of a conspiracy to torture, then I can't see how the delay of the "client" who is co-conspirator can run the SOL.

Also, I believe there were earlier complaints about Yoo to the PA Bar (I don't have dates). I wonder if the Bar would apply a relation back rule.
5.7.2009 12:58pm
Philistine (mail):

If a lawyer conceals incompetence or illicit behaviour from a client (or opposing counsel or the court, in cases where there's a duty to reveal it), that sure sounds like something that should have no limitations.

But the fact that legal advice not concealed from its commissioner was kept secret by the party that commissioned it doesn't seem like it should open the lawyer up to sanctions later "because the public at large didn't find out about it, because the guy who PAID for it didn't tell anyone".



I can think of some rules where knowledge of the client wouldn't necessarily effect concealability--Candor Towards the Tribunal, for instance. The various rules dealing with communications with third parties, etc.

In Pennsylvania, Rule 1.13 (Organization as a Client) applies to the Government.

The portion that is arguably applicable seems to be (b):


If a lawyer for an organization knows that an officer, employee or other person associated with the organization is engaged in action, intends to act or refuses to act in a matter related to the representation that is a violation of a legal obligation to the organization, or a violation of law which reasonably might be imputed to the organization, and is likely to result in substantial injury to the organization, the lawyer shall proceed as is reasonably necessary in the best interest of the organization. In determining how to proceed, the lawyer shall give due consideration to the seriousness of the violation and its consequences, the scope and nature of the lawyer's representation, the responsibility in the organization and the apparent motivation of the person involved, the policies of the organization concerning such matters and any other relevant considerations. Any measures taken shall be designed to minimize disruption of the organization and the risk of revealing information relating to the representation to persons outside the
organization.


Here as well, it seems that concealment from third parties, rather than the client might be enough.

(Though this would presuppose Yoo knew the conduct was illegal, and presumably tailored his advice to suggest legality, or a similar finding--which seems pretty unlikely to be able to be proven).

Pa. Rules of Professional Conduct
5.7.2009 1:03pm
NTB24601:
Sigivald: "Isn't that concealment from the client?"

I agree that's a plausible interpretation of the rule -- its similar to the counterargument that I mentioned above -- but I don't see that limitation in the plain language and I wouldn't agree that its the only plausible interpretation.

I think a better interpretation would at least include knowing concealment from any injured parties. That way the concealment exclusion serves a similar function as the discovery rule. Any other interpretation strikes me as too susceptible to allowing attorneys to prevent disciplinary action by engaging in chicanery with their clients.

This is all supposition on my part though. I would hope that the Disciplinary Board has already addressed this question in some opinion that I haven't located.
5.7.2009 1:05pm
Pete Freans (mail):
But the Pennsylvania Disciplinary Board, which would investigate any complaints against him, imposes a four-year limitation for complaints.

Given I'm licensed in PA, that's sure good to know...
5.7.2009 1:16pm
NTB24601:
cal ethics lawyer: "If the 'concealment' was that the OLC memos were not made public, pursuant to lawful and appropriate DOJ decisions, then it can't be 'concealment,' can it?"

I would think that depends on the purpose behind the exception. If the purpose is to punish attorneys who conceal misconduct more strictly because such attorneys are seen as more culpable, then I would agree with you. I suppose the fact that concealment is grouped with "theft," "misappropriation" and "conviction of a crime" -- all things that suggest a higher level of culpability -- supports that interpretation. I'd also agree with you if the exception is seen as akin to the dirty hands exception to laches.

I am more inclined, however, to read the exception as serving a purpose similar to the discovery rule. If that's correct, then the touchstone ought to be whether the Office of Disciplinary Counsel was prevented from timely pursuing a complaint. In which case, I would think that it would be irrelevant whether or not the misconduct was properly concealed.
5.7.2009 1:26pm
Just an Observer:
On the question of D.C. diciplinary action, Greenburg now has added this update to her own blog post:

UPDATE: My friends at Volokh are commenting that Yoo could be disciplined in Washington D.C., where he practiced. But Yoo wasn't admitted in DC. And while ABA Model Rule 8.5a indeed says non-admitted lawyers may be disciplined if they provide legal services in the jurisdiction, DC took that very sentence out when it adopted the model rules. DC bar rules, in other words, don't have the comparable provision for non-admitted attorneys that's found in the ABA Model Rules. So the way I read these various rules--whether you look at the McDade Amendment (which says DOJ attorneys are subject to state rules "to the extent as" private attorneys) or through DC rules, Yoo is not subject to discipline in DC.
5.7.2009 1:43pm
Benjamin Davis (mail):
More acquiescence to torture stuff - boy it sure is running around today.

A complaint was filed already against him in Pennsylvania and it was dismissed by the State Bar in deference to the OPR report. With the OPR report out, that complainant could amend his complaint to add that information - so no time bar that way.

Second, the tolling of the statute of limitations is more complicated than McCarthy tries to make it look.

Third, even if McCarthy is right on the state bar statute of limitations, well we just prosecute Yoo. Then after he was convicted, he could be disciplined/disbarred (see Clinton).

Yoo is still very much in the woods. And that is only speaking domestically. As you may not know, the Spanish judge who has Yoo in his case has asked the United States to advise whether the United States intends to prosecute Yoo and the other five lawyers to help the Spaniards determine whether they need to go forward now. It is a classic rule of international law of seeking to exhaust all remedies in one state, before another state takes action. One exception is that it would be meaningless to do the process in the first state for whatever reasons.

So we are at another key point and Yoo is far closer to be indicted then he has been in the past five years.

If we insist, they will be prosecuted.

Best,
Ben
5.7.2009 1:47pm
CDU (mail) (www):

If Yoo wrote the memo as part of a conspiracy to torture, then I can't see how the delay of the "client" who is co-conspirator can run the SOL.

Is it even legally possible for the government to be a conspirator?
5.7.2009 2:05pm
Just an Observer:
FYI, the Washington Post today has this story, Experts Say Authors Of Memos May Avoid Professional Sanctions, speculating about bar discipline. (It does not mention the Pennsylvania deadline issue.)
5.7.2009 2:10pm
Just an Observer:
Sorry, I seem to have fouled up the link to the Post story. Try this link instead.
5.7.2009 2:12pm
geokstr (mail):

stoshy:
Can someone cite precisely the disciplinary rule Yoo &Bybee are supposed to have violated?

Rules? RULES? We don' need no steenking rules.

We are Darleks. The Doctor must be ter-min-at-ed...
5.7.2009 2:18pm
Just an Observer:
Meanswhile, the Las Vegas Sun (h/t How Appealing) leads with Bybee lobbying his member of Congress. The Sun story includes this detail about the D.C. bar disciplinary process:

Wallace E. Shipp, counsel for the Washington bar, would not comment on the Bybee matter Wednesday but did explain the process for reviewing claims of misconduct.

If the bar receives a complaint, Shipp and his staff review the matter and determine whether it deserves “docketing,” or a formal investigation. Of 1,200 complaints the bar receives each year, 450 to 550 a year qualify for docketing, Shipp said.

After the investigation, the bar can recommend sending the issue to a disciplinary hearing before a committee made up of two lawyers and a nonlawyer member of the public. The panel makes a recommendation, which goes to a Board of Professional Responsibility. After that, the matter goes to the D.C. Court of Appeals. The process can take one to three years.

5.7.2009 2:29pm
Connecticut Lawyer (mail):
If there were any doubt that the attacks on Yoo, et al. were something other than cheap score settling, ill-disguised retribution for the Iraq War, this story settles it.
5.7.2009 3:41pm
NTB24601:
As far as I've been able to tell, those of us who want investigations into the conduct of "Yoo, et al." ask only that the law be applied as written. We certainly have strong opinions about how the law ought to be interpreted, but we ground our arguments in the law. Those most staunchly opposed to investigation, on the other hand, strike me as tending to ground their arguments in poltical concerns (i.e., an investigation would be a "witch hunt," "score settling," "criminalization of policy differences").
5.7.2009 3:57pm
PaulYale (mail):
Isn't the Holder Jsutice Department using Yoo's memo to support the government case in the deportation case of Demanovick (sp?). The memo was deemed valid in a US Court of Appeals case
5.7.2009 4:08pm
Just an Observer:
I have been reading lately about how this was a "five year" OPR investigation. What does that mean?

I certainly was not aware of it five years ago, but maybe I just had my head in the sand. Was the OPR probe's existence reported contemporaneously? Was it formally started during Jack Goldsmith's tenure at OLC, when he withdrew all those Yoo/Bybee opinions?
5.7.2009 4:09pm
NTB24601:
@JaO: Here's what Newsweek has to say about when OPR began its investigation:
But the OPR probe began after Jack Goldsmith, a Bush appointee who took over OLC in 2003, protested the legal arguments made in the memos. Goldsmith resigned the following year after withdrawing the memos, and later wrote that he was "astonished" by the "deeply flawed" and "sloppily reasoned" legal analysis in the memos by Yoo and Bybee, including their assertion (challenged by many scholars) that the president could unilaterally disregard a law passed by Congress banning torture.
That suggests that OPR began its investigation sometime in 2003 or 2004, i.e., about 5 years ago.

I don't think that OPR publicly confirmed the investigation until last year though, which would explain why you and I weren't aware of it. From the same Newsweek article (which was published on February 14, 2009):
H. Marshall Jarrett, chief of the department's ethics watchdog unit, the Office of Professional Responsibility (OPR), confirmed last year he was investigating whether the legal advice in crucial interrogation memos "was consistent with the professional standards that apply to Department of Justice attorneys."
5.7.2009 4:28pm
Just an Observer:
A related question still nags me. There reportedly was an OPR investigation into the warrantless wiretapping, too. Bush originally blocked it, but it was revived in late 2007.

What ever happened to it, one way or another? I don't recall reading about any closure.
5.7.2009 4:49pm
jukeboxgrad (mail):
paul:

Isn't the Holder Jsutice Department using Yoo's memo to support the government case in the deportation case of Demanovick (sp?).


No.

The memo was deemed valid in a US Court of Appeals case


Wrong. All that court did was notice that the statute embodies the concept of "specific intent." There's nothing remarkable or controversial about that. McCarthy wants you to think that the court specifically endorsed Yoo's peculiar interpretation of "specific intent," even the court did not do so.
5.7.2009 5:03pm
PlugInMonster:
The left is extremely mistaken if it thinks the American people are as obsessed about this fake-torture issue as they are. Most people are worried about their jobs, 401Ks, children, health care, not this nonsense.
5.7.2009 5:10pm
NTB24601:
@PlugInMonster: You're falling into the trap of believing your side's spin. That argument won't be persuasive to those who want investigations because -- contrary to the fervent spin of those opposed to the investigations, including most of the beltway media -- we aren't arguing for investigations for political gain.
5.7.2009 6:01pm
Leo Marvin (mail):
So the OPR timed the release of this report to the more prosecution-friendly Obama administration it knew in 2003 would be in the White House now? Did I mention that jet fuel doesn't burn hot enough to melt steel?
5.7.2009 6:05pm
NTB24601:
@Leo Marvin: Exactly. OPR knew for 5 years that Obama would be elected in 2008. Delaying a report that would embarrass the Bush Administration was just an added bonus in their cunning plan.
5.7.2009 6:25pm
Jim Rhoads (mail):
I guess since it is almost unanimous on this thread. Yoo and Bybee are toast.

But is the commentariat here representative of the country as a whole? So far, the Obama Justice Department's actions seem to indicate they are not.
5.7.2009 6:42pm
geokstr (mail):

NTB24601:
@PlugInMonster: You're falling into the trap of believing your side's spin. That argument won't be persuasive to those who want investigations because -- contrary to the fervent spin of those opposed to the investigations, including most of the beltway media -- we aren't arguing for investigations for political gain.

And of course your side has no spin on this or any other issue...riiiggggghhhhtttt. I have a bridge up in Alaska that doesn't go anywhere in particular I'm looking to sell if you're interested.

I call BS. You give yourself away by your own words. How do you know whose side an opponent is on; perhaps like you claim about yourself, they just think your argument is wrong. But by the accusatory words "your side" you're admitting your own partisanship. Tell me I'm wrong and how you're really a conservative Republican who just believes in the rule of law.

The pathological hatred of everything to do with Bush runs through so many of these comments on the "torture" threads, but I suppose it's tough to smell it after wallowing in it for 8 years.

I'll believe you when you start pushing for the "investigation" and "truth commission" looking into the fund-raising improprieties of the Obama campaign, and other legal pecadillos of the left. Funny I see a whole different "lack of spin" coming from your side on posts about those.

BTW, I'm taking notes so that when the inevitable accusations of "illegalities" of the Obama folks start hitting, I can ask you all about where the outrage has gone. I don't even like Bush, and didn't vote for him either time. But I do like fair play, and all this screaming about "torture" is so obviously partisan it makes me want to hurl.
5.7.2009 6:56pm
Stash:
While they usually follow the state disciplinary bodies, the U.S. District Courts can also disbar attorneys. This is, of course, effective only in that U.S. District. To my knowledge, the U.S. District Courts do not have a time bar on conduct for disbarment. So, thoeretically, any District Court to which he is admitted, could disbar Yoo.

Also do not forget that the Pa. disciplinary code allows discipline, if you are disbarred by another jurisdiction. Unless it there was no due process or it offends Pa public policy, Rule 216 states:

(d) In all other respects, a final adjudication in another jurisdiction that an attorney, whether or not admitted in
that jurisdiction, has been guilty of misconduct shall establish conclusively the misconduct for purposes of a disciplinary proceeding in this Commonwealth.


So a DC or federal ruling could conceivably result in Pa discipline. Unless the limitations sections is a strong public policy, which it arguably is not, Yoo can get nailed in Pa if the DC bar or a federal court acts.

Second, why is everyone talking only about disbarment? There are a whole range of sanctions that could be imposed. There could be public censure, temporary suspension, or even mere private reprimand.

As for the statute of limitations, I do not believe the "client" was Bush, Cheney or other individuals to whom the advice was communicated. The "client" was the United States. If the time runs against the client, as the arguments against the "concealment" tolling the limitations suggests, then query whether the doctrine of "nullum tempus occurit regi" applies. Literally this means that "time does not run against the King" and is usually short-handed as "nullum tempus."

Also, a "complaint" seems to be only one method that would initiate an investigation under Pa law. The rules state that no complaint is necessary to initiate an investigation. If the investigation is sua sponte, would the limitations apply?

Finally, there seem to be quite a few plausible bases for discipline. There is the catch-all of an act involving dishonesty or an act prejudicial to the administration of justice. See Pa. Rule 8.4 c and d. This could come into play if, as is being reported, matters were removed from the opinions that made them less one-sided. I.e., if legal considerations were consciously concealed in the opinion. Of if it could really be shown that they did not believe the opinion to be valid, this would seem to apply.

More specifically, there is arguably a case to made that PA rule 1.2 was violated:

"A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law."

If the writing of the memos was not in "good faith" from a legal standpoint (just because they had a good faith belief that the policy was correct does not mean they had a "good faith" belief in the legal position) they were arguably "assisting" in conduct "the lawyer knows is criminal." I.e., they were providing legal cover for an illegal practice. If I was researching this issue, I think I would look for cases of tax fraud where some sort of bogus legal opinion was used. Were the attorneys criminally or civilly liable, and were they subject to discipline? Are there any standards for this? Obviously just because I strongly believe an expense should be tax deductible from a policy standpoint does not mean my incorrect advice that it is cannot be disciplined or subject me to criminal sanctions.

Also an arguable "lesser" violation might be of 2.1: Advisor

In representing a client, a lawyer should shall exercise independent professional judgment and render candid advice.

[strikethrough original]. The issue here is whether the advice was tailored rather than candid. True, it was what the bosses wanted, but again the client was the government, not the individuals.

This one is a little tenuous, but perhaps marginally plausible:

Rule 4.4 Respect for Rights of Third Persons
(a) In representing a client, a lawyer shall not ... use methods of obtaining evidence that violate the
legal rights of such [third] a person.


For my part, I would see nothing wrong with these memos if they had been written as briefs instead of opinions making a positive statement of the law. There is not much defensible in them to the extent they purport to be objective analyses. Without either a survey of prior prosecutions and suitable distinctions, and without placing the word "arguably" before most of the propositions, the memos flunk any test for objective advice. Still, I would hesitate to state positively that there is either a clear basis or no basis for discipline. It is all about the facts, which supposedly the OPR is going to provide.

And now after looking at Pa Rules, I find the "choice of law" rule which suggests that says Pa will look at the law of the place the alleged misconduct occurred. Pa Rule 8.5. So is the statute of limitations substantive or procedural in disciplinary cases? The general rule is that it is procedural, but it does not necessarily need to be interpreted that way by Pa. I have not looked at any law on this.

I do not purport to know all the answers to these questions, but there seems to be a lot more involved here than folks are talking about. Analyzing the whole issue would take a lot of work--it seems to have taken OPR five years--so all this is speculation. I wish I had a client who would pay me to look into this and write an objective opinion.
5.7.2009 7:47pm
jukeboxgrad (mail):
NTB24601:

Delaying a report that would embarrass the Bush Administration was just an added bonus in their cunning plan.


Good point. And pay attention to just how cunning they were. Could they have released information embarrassing to the GOP prior to the 2004 election? Probably so. Likewise for 2006 and 2008. Instead, they cleverly dragged their feet for years. Because when people have information that can embarrass their political enemies, that's what they typically do: sit on it as long as possible. And definitely not release it prior to important elections.

This strategy is so cunning I don't think I can make sense of it. But hopefully Greenburg and McCarthy will put their heads together again and explain the mysterious logic behind it all.
5.7.2009 8:12pm
Jim Rhoads (mail):
Several questions Juke:

(1) If the US paid you to <i>defend</i> Yoo/Bybee, would you do it?

(2) How about if the ACLU paid you to defend?

(3) Do you believe any bona-fide liberal (under any definition you select) would or could defend Yoo/Bybee?

(4) If you were given a bar exam question requiring you to state the best defense you can think of for Yoo/Bybee, how would you answer?

FYI, I am now pretty sure after reading arguments pro an con that I could either prosecute or defend, but I didn't think I could prosecute last night.
5.7.2009 9:53pm
jukeboxgrad (mail):
If the US paid you to defend Yoo/Bybee, would you do it?


Only if no one else was willing to take the job. Like every defendant, they deserve a proper defense, but it's a job I would try to avoid.

How about if the ACLU paid you to defend?


I see no reason to answer this question differently than the first question.

Do you believe any bona-fide liberal (under any definition you select) would or could defend Yoo/Bybee?


Like I said, every defendant deserves a proper defense. The fact that I would avoid the job is strictly a personal preference. But I can easily imagine some other "liberal" having a different view, and I see no dishonor in that.

If you were given a bar exam question requiring you to state the best defense you can think of for Yoo/Bybee, how would you answer?


'It seemed like a good idea at the time. I thought it was my patriotic duty to give my president exactly what I knew he wanted. It was a mistake. I'm sorry. I won't do it again. I'm ready to pay for the crime I committed, and I hope others will learn from the error of my ways.'

I realize that approach doesn't get him out from under the statute. But it's an honorable approach, and it's likely to win the sympathy of the court. Which means penalties will be minimal.
5.7.2009 10:25pm
Jim Rhoads (mail):
My compliments, Juke. I think that is a pretty good answer, except for the last part. I suspect if you worked at it long enough, though, you would come up with some better defense arguments.

You sure have exhibited persistence on this subject on this site. I have generally found that applying such persistence to recognizing and articulating the other side's best case (even when it/they might not) pays big dividends in motions practice and at trial.
5.7.2009 10:55pm
Leo Marvin (mail):
Jim Rhoades,

We can only speculate what the defense would be, because we don't have access to key evidence needed to prosecute. That's why the need for a proper investigation to ferret out what messages were exchanged, between whom, what pressure was applied, who winked and who nodded, etc. Without a smoking gun to refute, the defense would be easy: "My client believed and still believes every word in the memos." If Yoo, Bybee, et al, covered their tracks, or if, implausible though it seems, they actually did believe everything in the memos, i.e., their arguments weren't the product of working backward from a desired result, it would be easier to defend than to prosecute. But just because a defense is easy doesn't mean it's right.
5.8.2009 6:56am
Andrew J. Lazarus (mail):
The NY Times blundered today in one of its obituaries, of a US Air Force pilot who was captured by the Chinese near the end of the Korean War. The obit says the pilot was tortured into a false confession of germ warfare, but the techniques enumerated in the obit all fall under the new American category of non-torture enhanced interrogation techniques. Or, as I have alleged repeatedly, is this all a charade to avoid coming to terms with war crimes authorized at the highest (more likely, second-highest) levels of government?

Suppose memos turn up where the Office of Maoist Legal Counsel approve the treatment of the American pilot, since none of the techniques caused severe pain approaching that of organ failure or death. The same casual so-what as we have hear? I doubt it.

I will be writing to the Times insisting that they apologize to the People's Republic of China. Who will be joining me? (Yes, geo, I am particularly thinking of you.)
5.8.2009 11:43am
jukeboxgrad (mail):
Andrew, it's simple. The key to separating torture from non-torture lies in applying the following principle: IOKIYAR.

Those Chinese torturers just made the mistake of being non-Republicans. Future torturers around the world simply need to contract their torture needs to Republican contract torturers (I'm sure Blackwater is available, even though they've changed their name). Because when Republican torturers torture, the Yoo principle applies, which means that the torture is non-torture (I can picture the slogan: 'Millions tortured, and not a single organ failure yet'). Note that this is also an example of the free enterprise system spreading around the world. And also note the positive effect on our trade deficit. So I hope you will not stand in the way of progress.
5.8.2009 12:20pm

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