Minnesota Supreme Court decision here.
The Director argues that Michael’s e-mail questioning the tribal court’s impartiality violated Rule 8.4(d). Michael counters that her accusation regarding the tribal court’s impartiality was well founded and, therefore, was not a violation of Rule 8.4(d). Similar to the misconduct in Getty, the conclusion that Michael’s conduct constitutes a violation of Rule 8.4(d) rests on the manner in which she raised her concerns about the tribal court’s alleged unfairness. Even if Michael could establish that her concerns were well founded, Michael’s flippant rhetorical question at the end of the e-mail that she addressed to the presiding tribal court judge and sent to opposing counsel was unprofessional and disrespectful. Michael’s conduct demonstrates a failure to “show . . . restraint and . . . respect for the judicial system even while disagreeing strongly with it or its decisions.” In re Getty, 401 N.W.2d at 671; cf. In re Snyder, 472 U.S. 634, 645-47 (1985)
Turtle Talk 