Author granted license

Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International

Document Type

Article

Publication Date

2025

ISSN

1533-4686

Publisher

Washington University School of Law

Language

en-US

Abstract

California Business & Professions Code § 6086.7(a)(2) provides that a court shall notify the State Bar “[w]henever a modification or reversal of a judgment in a judicial proceeding is based in whole or in part on the misconduct, incompetent representation, or willful misrepresentation of an attorney.” Some California judges now interpret this provision as mandating referral to the State Bar in any case in which a new trial or withdrawal of a plea is granted due to ineffective assistance of counsel. This interpretation directly conflicts with an attorney’s continuing duty to her former client. It is unnecessary and has profoundly deleterious consequences to the integrity of the criminal process.

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