In the Matter of Igor Raykin Attorney-Respondent:

2025 CO 12, 565 P.3d 728
CourtSupreme Court of Colorado
DecidedMarch 24, 2025
Docket24SA216
StatusPublished

This text of 2025 CO 12 (In the Matter of Igor Raykin Attorney-Respondent:) is published on Counsel Stack Legal Research, covering Supreme Court of Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of Igor Raykin Attorney-Respondent:, 2025 CO 12, 565 P.3d 728 (Colo. 2025).

Opinion

2025 CO 12

In the Matter of Igor Raykin Attorney-Respondent:

No. 24SA216

Supreme Court of Colorado, En Banc

March 24, 2025


          Original Proceeding in Discipline Appeal from the Presiding Disciplinary Judge, 23PDJ046

2

          Attorney-Respondent Igor Raykin, pro se Aurora, Colorado

          Attorneys for the People of the State of Colorado: Jessica E. Yates, Attorney Regulation Counsel Jonathan P. White, Assistant Regulation Counsel Denver, Colorado

          JUSTICE HART delivered the Opinion of the Court, in which CHIEF JUSTICE MARQUEZ, JUSTICE BOATRIGHT, JUSTICE HOOD, JUSTICE GABRIEL, JUSTICE SAMOUR, and JUSTICE BERKENKOTTER joined.

3

          OPINION

          HART, JUSTICE

         ¶1 This matter asks us to consider the relationship between the Colorado Rules of Professional Conduct and the American Bar Association's ("ABA") Standards for Imposing Lawyer Sanctions (Am. Bar Ass'n, 2d ed. 2019) ("ABA Standards"), when the Office of the Presiding Disciplinary Judge ("PDJ") imposes sanctions on an attorney for violating our rules of professional conduct.

         ¶2 In May 2022, during a meeting with the staff of the Mesa County Valley School District 51 (the "school district"), attorney Igor Raykin directed several inappropriate expletive-laden outbursts at the staff in the presence of his minor client and his client's parents. Raykin's conduct at the meeting was reported to the Office of Attorney Regulation Counsel ("OARC"). OARC investigated and filed a complaint with the PDJ, (1) alleging that Raykin had violated Colo. RPC 4.4(a), which addresses an attorney's respect for the rights of third persons, and (2) seeking sanctions for the violation.

         ¶3 A Hearing Board concluded that Raykin's conduct at the meeting violated Colo. RPC 4.4(a) because the conduct had no substantial purpose other than to delay, embarrass, or burden the school district's staff. After weighing the aggravating and mitigating circumstances, the Hearing Board determined that the appropriate sanctions were a public censure and an independent medical examination ("IME").

4

         ¶4 Raykin appealed the Hearing Board's determination, as well as two other PDJ orders, to this court. Raykin's primary objection to the Hearing Board's sanctions relies on the language and structure of the ABA's Standards for Imposing Lawyer Sanctions, which we use as "our guiding authority" in determining appropriate sanctions. In re Rosen, 198 P.3d 116, 119 (Colo. 2008). We take this opportunity to make clear that the ABA's standards are a starting point-an important guiding authority-but not a text that supersedes the Colorado Rules of Professional Conduct. In this case, the PDJ correctly determined that Raykin's conduct violated his duties as a professional. The sanctions imposed are appropriate, and we affirm the Hearing Board's final decision and the PDJ's denial of both prehearing motions.[1]

5

         I. Facts and Procedural History

         ¶5 This matter involves events that occurred during a May 18, 2022 meeting with the school district's staff to review the Individual Education Plan ("IEP") of one of Raykin's clients. The meeting was hybrid, with Raykin, his client, and the client's parents attending remotely.

         ¶6 The school district's representatives in attendance included Tammy Eret Lynch, the school district's outside counsel; Walter Fox, a special education instructor; and Jan Blair, a special education consultant who led the meeting.

         ¶7 Over the course of the approximately eighty-minute call, Raykin made several profane and disparaging comments directed toward the school district's staff that started about twenty-three minutes into the meeting. During an argument with Blair, Raykin said, "Shut up, Jan." A few seconds later, he pointed his finger at the screen and again said, "Shut up, Jan." A minute later, Raykin told Blair again to shut up.

         ¶8 Soon after, apparently having received an incorrect document by email, Raykin said the following to Blair and Lynch: "You people can't even send the right f**king document." Lynch told Raykin that he should not be cursing in the meeting, to which he replied, "I sure as f*** am." Blair muted Raykin the next time he began cursing. Raykin unmuted himself and said, "Every time I unmute myself, I'm going to say f*** again. That's how I am going to start every sentence."

6

         ¶9 A few minutes later, Raykin called Blair a "miserable person." He then said, "One of us is a lawyer, and the other one is you." Approximately two minutes later, Blair told Raykin, "We wish you would be quiet," to allow the meeting to continue. Raykin replied to Blair, saying, "I wish you would actually stop working here and go work where you really belong, which is in the gutter, ok? So please go ahead and get yourself employed where you need to be."

         ¶10 About sixty-two minutes into the meeting, Blair interrupted Raykin. Raykin responded by saying, "My God, Jan, you really don't know how to shut up, do you? I mean, it is unbelievable how little you actually listen to people. You are an incredible person." A few seconds later, Raykin said, "Jan, really, I feel so bad for your ex-husbands," after which someone snickered. Toward the end of the meeting, Raykin shook his finger at Blair and Fox and said, "I don't like you." Raykin went on to say he was frustrated and his frustration was why he continued using the word "f***." A few minutes later, Raykin commented, "You guys are full of s***," followed by him telling Lynch and Blair to "shut the f*** up" shortly before the meeting ended.

         ¶11 The next day, Raykin sent an email to Lynch referring to Blair as a "despicable creature and a cancer to kids."

         ¶12 After a request for investigation was filed with OARC, Raykin submitted his initial response on August 24, 2022. In this response letter he wrote, "I did call

7

Blair a 'despicable creature and a cancer to kids.' Ok, I like to call things what they are." Raykin further wrote, "If I have to scream at someone or intimidate them or release my anger in order to get what's best for a [child with special needs], then so be it." In the same response letter, Raykin stated, "I have attention deficit disorder, intermittent explosive disorder, and oppositional defiant disorder. Frankly, I don't think any of these things are 'disorders.' I have dealt with these things since adolescence." Raykin also wrote, "But sometimes these conditions are useful. And if these conditions are necessary to represent kids more effectively, then I suppose that having them is better than not having them." He further commented, regarding the school district, "If they want to bully my clients by smiling in their faces while preparing to screw them over, then I'm going to bully them back."

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Armintrout v. People
864 P.2d 576 (Supreme Court of Colorado, 1993)
People v. Easley
956 P.2d 1257 (Supreme Court of Colorado, 1998)
In Re Leblanc
972 So. 2d 315 (Supreme Court of Louisiana, 2007)
In Re Rosen
198 P.3d 116 (Supreme Court of Colorado, 2008)
People v. Beecher
224 P.3d 442 (Supreme Court of Colorado, 2009)
People v. Cali
2020 CO 20 (Supreme Court of Colorado, 2020)
In Re People v. Maes, Carlos
2024 CO 15 (Supreme Court of Colorado, 2024)
The PEOPLE of the State of Colorado v. R. Alex RAINES, 36610
510 P.3d 1089 (Supreme Court of Colorado, 2022)
In the MATTER OF Robert E. ABRAMS
488 P.3d 1043 (Supreme Court of Colorado, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
2025 CO 12, 565 P.3d 728, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-igor-raykin-attorney-respondent-colo-2025.