In re Conduct of Conry

491 P.3d 42 (2021)

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In re Conduct of Conry

Oregon Supreme Court
491 P.3d 42 (2021)

KD

Facts

A man (client) who had been convicted of theft and burglary hired attorney Brian Conry (defendant) after the government instituted deportation proceedings against the client. The government contended that the client’s crimes were crimes of moral turpitude such that the client was subject to deportation. After the client was ordered deported, he retained a new attorney. The government ultimately dropped the matter. The client posted negative reviews about Conry on Yelp, Google, and Avvo in which the client identified himself by a shortened version of his first name and his last initial. The client complained that Conry lost his case even though the client was not deportable. The client’s reviews referenced charges but did not disclose that the client had been convicted or identify the specific crimes involved. Conry responded online, explaining that the client was convicted of burglary and theft. In the Avvo review, Conry identified the client by the client’s full name. The Oregon Bar (bar) (plaintiff) filed a formal complaint charging Conry with violating Oregon Rule of Professional Conduct 1.6(a). Conry argued that the self-defense exception to the rule’s prohibition applied. A trial panel rejected Conry’s arguments and recommended a 30-day suspension. Conry sought review from the Oregon Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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