Can lawyers face discipline for good faith legal errors while acting in quasi-judicial roles? In re Discipline of La Jeunesse Explained

The Utah Supreme Court in In re Discipline of La Jeunesse addressed whether a lawyer can face professional discipline for making good faith legal errors while exercising quasi-judicial authority. The case arose from disciplinary proceedings against Richard LaJeunesse, who served as Presiding Administrative Law Judge at the Utah Labor Commission.

Background and Facts

LaJeunesse implemented a policy allowing ALJs to reject medical panel reports and request revisions without first distributing the original reports to parties and their attorneys. Under Utah Code section 34A-2-601(2), medical panels must submit written reports to ALJs, who must “promptly distribute full copies” to all parties. LaJeunesse interpreted this statute as permitting ALJs to reject noncompliant reports before distribution. When this practice was discovered, LaJeunesse was terminated and faced a bar complaint alleging conduct prejudicial to the administration of justice under Rule 8.4(d).

Key Legal Issues

The central issue was whether Rule 8.4(d)’s prohibition on conduct prejudicial to the administration of justice applies to lawyers who make good faith but erroneous interpretations of law while exercising quasi-judicial authority. The district court had to determine whether legal error alone, without more, constitutes sanctionable conduct.

Court’s Analysis and Holding

The Supreme Court affirmed dismissal of the charges, relying heavily on In re Worthen, which established that judges cannot be disciplined for mere legal errors subject to appellate review. The court held that “conduct prejudicial to the administration of justice” requires proof of a breach of ethical norms, not simply incorrect legal judgment. The court found LaJeunesse’s policy was adopted in good faith based on a reasonable interpretation of an ambiguous statute, even if ultimately incorrect.

Practice Implications

This decision provides important protection for attorneys exercising judicial or quasi-judicial functions. It establishes that good faith legal errors, even those affecting case outcomes, cannot alone support professional discipline charges. However, the court emphasized this protection applies only to objectively reasonable positions taken in good faith—conduct involving dishonesty, evidence tampering, or violations of established ethical norms remains sanctionable regardless of the attorney’s subjective intent.