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In re Snyder, 472 U.S. 634, 105 S.Ct. 2874, 86 L.Ed.2d 504, 53 USLW 4833

Facts

Robert Snyder was appointed to represent a defendant under the Criminal Justice Act and submitted a fee request that was deemed insufficiently documented by the Chief Judge of the Court of Appeals. After failing to provide the requested documentation, Snyder wrote a letter expressing his dissatisfaction with the fee structure and administration of the Act. This letter was perceived as disrespectful, leading to a show cause order for his suspension from practice, which the Court of Appeals ultimately imposed.

Issue

Did Snyder's conduct, including his refusal to submit further documentation and his criticism of the Criminal Justice Act, warrant suspension from practice in the federal courts?

Did Snyder's conduct, including his refusal to submit further documentation and his criticism of the Criminal Justice Act, warrant suspension from practice in the federal courts?

Rule

Under Federal Rule of Appellate Procedure 46, an attorney may be suspended for 'conduct unbecoming a member of the bar,' which must be interpreted in light of the attorney's obligations to clients and the justice system.

Under Federal Rule of Appellate Procedure 46, an attorney may be suspended for 'conduct unbecoming a member of the bar,' which must be interpreted in light of the attorney's obligations to clients and the justice system.

Analysis

The Supreme Court analyzed Snyder's actions in the context of the legal standards for attorney conduct. It concluded that while Snyder's refusal to provide further documentation could justify a denial of fees, it did not rise to the level of conduct warranting suspension. The Court noted that criticism of the administration of the Act is permissible and that a single instance of rudeness does not demonstrate unfitness to practice law.

The record indicates the Court of Appeals was concerned about the tone of the letter; petitioner concedes that the tone of his letter was 'harsh,' and, indeed it can be read as ill-mannered. All persons involved in the judicial process—judges, litigants, witnesses, and court officers—owe a duty of courtesy to all other participants. The necessity for civility in the inherently contentious setting of the adversary process suggests that members of the bar cast criticisms of the system in a professional and civil tone. However, even assuming that the letter exhibited an unlawyerlike rudeness, a single incident of rudeness or lack of professional courtesy—in this context—does not support a finding of contemptuous or contumacious conduct, or a finding that a lawyer is 'not presently fit to practice law in the federal courts.' Nor does it rise to the level of 'conduct unbecoming a member of the bar' warranting suspension from practice.

Conclusion

The Supreme Court reversed the Court of Appeals' suspension of Snyder, finding that his conduct did not warrant such a severe penalty.

Accordingly, the judgment of the Court of Appeals is Reversed.

Who won?

Robert Snyder prevailed in the case because the Supreme Court found that his actions did not justify suspension from practice.

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