IN THE

SUPREME COURT OF THE STATE OF ARIZONA

IN THE MATTER OF A MEMBER 

OF THE STATE BAR OF ARIZONA,

TORI S. BRYANT

ATTORNEY NO. 20391

Respondent.

No. SB-22-0062-AP

Filed April 6, 2023

Appeal of Order of Disbarment 

Based on Reciprocal Discipline

from the Office of the Presiding Disciplinary Judge

The Honorable Margaret H. Downie, Presiding Judge

No. PDJ20229058

AFFIRMED

COUNSEL:

Tori S. Bryant, Chula Vista, CA

Maret Vessella, Chief Bar Counsel, State Bar of Arizona, Phoenix, Attorney 

for State Bar of Arizona 

PER CURIAM:

¶1 Before the Court is an appeal of the Presiding Disciplinary 

Judge’s Order of Disbarment Based on Reciprocal Discipline. Respondent 

Tori S. Bryant contends that the Presiding Disciplinary Judge (“PDJ”) erred 

by suspending her pursuant to Arizona Supreme Court Rule 57(b) and 

argues that, although she was disbarred in another jurisdiction, disbarment 

in Arizona was unwarranted. Based on the record, the PDJ did not err.
IN RE: TORI S. BRYANT

Opinion of the Court

2

¶2 Respondent was previously suspended from the practice of 

law in Arizona for multiple Ethical Rule violations. Based on her prior 

Arizona suspension, the U.S. Court of Appeals for the Ninth Circuit (“Ninth 

Circuit”) issued a reciprocal order of suspension. After Respondent was 

reinstated in the Ninth Circuit (and Arizona), she continued to miss 

deadlines and failed to respond to court orders.

¶3 The Ninth Circuit disbarred Respondent for repeated failures

to comply with the court’s rules and orders, and for conduct unbecoming a 

member of the court’s bar.

¶4 Pursuant to Rule 57(b), once the PDJ receives notice that an 

attorney has been disciplined in another jurisdiction, the PDJ shall impose 

the identical or substantially similar discipline, unless bar counsel or 

respondent establishes by the preponderance of the evidence that one of the 

grounds set forth in Rule 57(b)(3)(A)–(D) applies. Unless one of the 

grounds is established, “a final adjudication in another jurisdiction that a 

lawyer has been found guilty of misconduct shall establish conclusively the 

misconduct for purposes of a discipline proceeding in this state.” Ariz. R. 

Sup. Ct. 57(b)(5). “In reciprocal proceedings, we generally accord 

significant weight to the sanction imposed by the jurisdiction where the 

misconduct occurred because the foreign jurisdiction has the greatest 

interest in fashioning sanctions for misconduct perpetrated therein. 

Therefore, when the sanction prescribed by the foreign jurisdiction is not 

inconsistent with the sanction for similar misconduct in this jurisdiction, 

this Court will impose the very same sanction.” In re Sirkin, 928 N.Y.S.2d 

680, 683–84 (N.Y. App. Div. 2011) (internal citations omitted).

¶5 Respondent may not re-litigate the merits of the federal 

disbarment orders in this forum. See In re Zdravkovich, 831 A.2d 964, 969 

(D.C. 2003) (“Put simply, reciprocal discipline proceedings are not a forum 

to reargue the foreign discipline.”). The PDJ’s role in reciprocal discipline 

proceedings is not “to sit in appellate review of the foreign disciplinary 

proceedings, in order to determine whether they conformed in every 

respect to local procedural and substantive law.” In re Chaganti, 144 A.3d 

20, 24 (D.C. 2016) (quoting In re Morrissey, 648 A.2d 185, 190 (D.C.1994)).

Rather, the PDJ’s “function is to determine whether any serious defects 

were present in the foreign proceedings . . . such that it would be wrong to 

impose reciprocal discipline here.” Id. (quoting In re Morrissey, 648 A.2d

at 190) (alteration in original).
IN RE: TORI S. BRYANT

Opinion of the Court

3

¶6 Respondent was given a full and fair opportunity to respond 

to the allegations of misconduct before she was disbarred by the Ninth 

Circuit. And under the ABA Standards for Imposing Lawyer Sanctions 

(“ABA Standards”), the misconduct found by the Ninth Circuit would 

warrant disbarment in Arizona. See ABA Standard 4.41(b) (“Disbarment 

is generally appropriate when[] a lawyer knowingly fails to perform 

services for a client and causes serious or potentially serious injury to a 

client[.]”); ABA Standard 4.51 (“Disbarment is generally appropriate when 

a lawyer’s course of conduct demonstrates that the lawyer does not 

understand the most fundamental legal doctrines or procedures and causes 

injury or potential injury to a client[.]”); ABA Standard 8.1(b) (“Disbarment 

is generally appropriate when a lawyer[] has been suspended for the same 

or similar misconduct, and intentionally or knowingly engages in further 

similar acts of misconduct that cause injury or potential injury to a client, 

the public, the legal system, or the profession.”).

¶7 Respondent offered to the PDJ and this Court reasons she 

believes disbarment is an overly harsh sanction. However, the time and 

place to offer such evidence was in the Ninth Circuit, which directed her to 

“file a statement in writing explaining why she should not be suspended or 

disbarred.” She failed to do so.

¶8 We find that Respondent did not establish by the 

preponderance of the evidence any exceptions set forth in Rule 57(b)(3).

We therefore affirm the decision and sanction of the Presiding Disciplinary 

Judge.