In re: Joel B. Eisenstein

485 S.W.3d 759, 2016 WL 1357206, 2016 Mo. LEXIS 77
CourtSupreme Court of Missouri
DecidedApril 5, 2016
DocketSC95331
StatusPublished
Cited by2 cases

This text of 485 S.W.3d 759 (In re: Joel B. Eisenstein) is published on Counsel Stack Legal Research, covering Supreme Court of Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Joel B. Eisenstein, 485 S.W.3d 759, 2016 WL 1357206, 2016 Mo. LEXIS 77 (Mo. 2016).

Opinions

Richard B. Teitelman, Judge

The Office of Chief Disciplinary Counsel (OCDC), filed an information charging Joel Eisenstein with several violations of the Rules of Professional Responsibility. A disciplinary hearing panel (DHP) found that Mr. Eisenstein violated Rules 4-8.4(c), 4-8.4(d), 4-3.4(a) and 4r-4.4(a) by using illegally-obtained evidence, including the work product of opposing counsel. The DHP recommended an indefinite suspension with no leave to apply for reinstatement for 12 months. Mr. Eisenstein -rejected the recommended discipline. This Court finds that Mr. Eisenstein violated the rules as determined by the DHP and orders that he be suspended indefinitely with no leave to reapply for reinstatement for six months.

Facts

Mr. Eisenstein was licensed as an attorney in Missouri in 1974. Mr. Eisenstein’s license has been disciplined on five prior occasions. In 1991 and again in 1999, Mr. Eisenstein was admonished for violating Rule 4-3.5(b) by engaging in ex parte communications with the judge. In 1997, this [761]*761Court suspended Mr. Eisenstein after he pleaded guilty to a federal misdemeanor for willfully failing to file an income tax return. In 2001, ■ Mr. Eisenstein was- admonished for violating Rule 4-8.1(b)’by failing to respond to the OCDC’s request for information regarding an ethics complaint. Finally, in 2004, • Mr. Eisenstein was admonished for violating Rule 4—3.3(d) for failing to inform the court of material facts relevant to a pending issue.

The present disciplinary matter involves Mr. Eisenstein’s representation of his client (Hüsband) in an action to dissolve Husband’s marriage to Wife. Attorney Stephanie Jones represented Wife. On-multiple occasions,. Husband accessed Wife’s personal e-mail account without, her permission. Mr. Husband obtained Wife’s most current payroll documents and a list of direct examination questions Ms. Jones had e-mailed to Wife in preparation for trial. In November 2013, Husband delivered the payroll, documents, and list of direct examination questions to Mr. Eisenstein.

On February 11,2014, the second- day of trial, Mr. Eisenstein handed Ms. Jones a stack of exhibits that included Ms. Jones’ direct examination questions. Prior to this time, neither Ms. Jones nor Wife was aware that Husband had improperly accessed Wife’s e-mail account and delivered the information to Mr. Eisenstein. Ms. Jones requested a conference with the trial judge and a hearing on the record.

At the hearing, Husband admitted that he improperly accessed Wife’s personal email account and obtained the list of direct examination questions and the payroll information. Husband admitted that he made notes on the list and delivered.the documents to Mr. Eisenstein.

Ms. Jones also questioned Mr. Eisenstein on the record. Mr. Eisenstein admitted that he had viewed the information improperly obtained by Husband and that he did not immediately disclose his receipt of this information to Ms., Jones:

Q. And you said you were going to object to all of my leading questions that are contained in the outline?
A. Well I was teasing you, counsel, I haven’t read—
Q. Did you say that or not?
A. I teasingly said that to you, yes I did.
Q. So you said that? •
A. I told you that I had read the—that at some, point in tíme I had read the first portion of that and realized that it was verboten, it was something that I should not have. - • '
■ Q. But you never came to me and said I have your outline, however, you came to be in possession of it, did you?
A. No, I didn’t counsel. I handed it to you this morning.
Q. Thank you.

On February 14, 2014, Mr. Eisenstein sent the following e-mail to Ms. Jones:

Rumor has it that you are quite the gossip regarding our little spat in court. Be careful what you say. I’m not someone you really want to make a lifelong enemy of, even though you are off to a pretty good start. Joel.

The OCDC filed an Information charging Mr. Eisenstein with violating Rules 4-4.4(a) for using methods of obtaining evidence in violation of the rights of a third person; 4-8.4(c) and (d) for reviewing and using improperly obtained evidence; 4-3.4(a) for unlawfully concealing a document having evidentiary value; and 4-3.3(a) for misrepresenting facts’ to a tribunal. The DHP held a hearing and determined that Mr; Eisenstein violated Rules 4-4.4(a); 4-8.4(c) and (d), and 4-3.4(a). In addition to possessing Ms. Jones’ direct examination [762]*762questions, the DHP also found, based, on Ms. Jones’ testimony, that Mr. Eisenstein had used the improperly obtained payroll information during a pre-trial settlement conference. The DHP recommended an indefinite suspension with no leave to apply for reinstatement for 12 months. Mr. Eisenstein rejected this recommendation. This Court has jurisdiction pursuant to its inherent power to regulate the practice of law.

Standard of Review

The DHP’s findings of fact, conclusions of law, and recommendations are advisory, and this Court may reject any or all of the DHP’s recommendations. In re Coleman, 295 S.W.3d 857, 863 (Mo. banc 2009). “Professional misconduct must be proven by a preponderance of the evidence before discipline will be imposed.” In re Farris, 472 S.W.3d 549, 557 (Mo. banc 2015). “This Court decides the facts de novo, ‘independently determining all issues pertaining to credibility of witnesses and the weight of the evidence, and draws its own conclusions of law.’ ” Id. quoting In re Snyder, 35 S.W.3d 380, 382 (Mo. banc 2000).

Rule 4~4.4(a)

The information alleged that Mr. Eisenstein violated Rule 4~4.4(a) by utilizing the payroll information and list of direct examination questions that were improperly procured by Husband. Rule 4-4.4(a) prohibits a lawyer from using “methods of obtaining evidence that violate the legal rights” of a third party. Comment 1 to Rule 4-4.4(a) specifically notes that the rule is intended to prevent “unwarranted intrusions into privileged relationships, such as the client-lawyer relationship.”

The preponderance of the evidence supports a finding that Mr. Eisenstein violated Rule 4-4.4(a). Ms. Jones testified credibly that Mr. Eisenstein had referenced information from Wife’s payroll documents during pretrial settlement negotiations. Further, Mr. Eisenstein admitted that he reviewed the information provided by Husband, realized it was “verboten,” and did not immediately disclose his receipt of the information to opposing counsel. Mr. Eisenstein’s failure to promptly disclose his receipt of the information and return it to Ms. Jones until after the trial had commenced supports a finding that Mr. Eisenstein utilized Husband’s improper acquisition of Wife’s personal- information, including privileged attorney client communications.

Mr. Eisenstein argues that he did not use improper means to obtain the evidence because it was Husband who obtained the information.

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Cite This Page — Counsel Stack

Bluebook (online)
485 S.W.3d 759, 2016 WL 1357206, 2016 Mo. LEXIS 77, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-joel-b-eisenstein-mo-2016.