IN THE SUPREME COURT OF AP PEALS OF WEST VIRGINIA January 2019 Term

_______________ No. 17-0906

_______________ LAWYER DISCIPLINARY BOARD, Petitioner

v. JENNIFER M. WOLFE, A MEMBER OF THE WEST VIRGINIA STATE BAR, Respondent

___________________ _____________________ ____________________ Lawyer Disciplinary Proceeding I. D. No. 16-03-311 LAW LICENSE SUSPENDED AND OTHER SANCTIONS

___________________ _____________________ ____________________ Submitted: April 23, 2019 Filed: May 31, 2019

Jessica H. Donahue Rhodes, Esq. Lawyer Disciplinary Counsel Office of Lawyer Disciplinary Counsel Charleston, West Virginia Counsel for the Petitioner J. Michael Benninger, Esq. Benninger Law, PLLC Morgantown, West Virginia Counsel for the Respondent

JUSTICE ARMSTEAD delivered the Opinion of the Court. 

### FILED June 3, 2019

released at 3:00 p.m. EDYTHE NASH GAISER, CLERK SUPREME COURT OF APPEALS OF WEST VIRGINIAi SYLLABUS BY THE COURT

1. “A de novo standard applies to a review of th e adjudicatory record made before the Committee on Legal Ethics of the West Virg inia State Bar [currently the Hearing Panel Subcommittee of the Lawyer Di sciplinary Board] as to ques tions of law, questions of application of the law to the f acts, and questions of appropri ate sanctions; this Court gives respectful consideration to the Committee’s recommendations while ultimately exercising its own independent judgment. On the other hand, substantial deference is given to the Committee’s findings of fact, unless such findi ngs are not supported by reliable, probative and substantial evidence on the whole record.” Syl. pt. 3, Committee on Legal Ethics v. McCorkle , 192 W.Va. 286, 452 S.E.2d 377 (1994).

2. “In deciding on the appropriate discip linary action for ethical violations, this Court must consider not only what steps would appropriat ely punish the respondent attorney, but also whether the discipline imposed is adequate to serve as an effective deterrent to other members of the Bar and at th e same time restore public confidence in the ethical standards of the legal profession.” Syl. pt. 3, Committee on Legal Ethics v. Walker , 178 W.Va. 150, 358 S.E.2d 234 (1987).1 Armstead, Justice :

This case is before this Court upon the report and recommendations of the Hearing Panel Subcommittee of the Lawy er Disciplinary Board regard ing the license to practice law of Jennifer M. Wolfe (“Wolfe”). Ms. Wo lfe was admitted to the Bar in 2014 and is subject to the disciplinary jurisdiction of this Court.

The Hearing Panel Subcommittee found that Wolfe committed violations of the West Virginia Rules of Professional Condu ct which resulted from her acknowledged drug abuse and dependency. Wolfe formally dise ngaged from the active practice of law on October 22, 2018. 1 The recommendations of the Hear ing Panel Subcomm ittee include the suspension of Wolfe’s license to practice law for one year and six months and her mandatory participation in th e evaluation and treatment protocols established by the West Virginia Judicial and Lawyer Assistance Pr ogram. The Office of Disciplinary Counsel consents to the recommendations. Wolfe asks that her suspensi on be limited to six months.

1 During oral argument, this Court asked Wolf e for verification of her disengagement from the active practice of law. Soon after, Wolfe provided a written suppl ement to the record which states in part: By Order Granting Motion to Withdr aw as Counsel, entered October 22, 2018, by the Family Court of Wood County, West Virginia, [Wolfe] was permitted to withdraw as c ounsel of record for her client, thereby completing the client representation and concluding her active practice of law as of that date.2 Upon review, this Court confirms the findi ngs and conclusion set forth in the report of the Hearing Panel Subcommittee, and we adopt the Subcommittee’s recommendations in their entirety. This Court holds, however, th at the one year and si x month suspension of Wolfe’s license to practice law shall be retr oactive to October 22, 2018, the date Wolfe formally disengaged from the active practice of law.

I. Factual and Procedural Background On October 12, 2017, the Investigative Pane l of the Lawyer Disciplinary Board filed a Statement of Charges forma lly charging Wolfe with violations of the Rules of Professional Conduct. The Statement of Char ges referred to the fo llowing occurrences:

On June 13, 2016, local police officers executed a search warrant of Wolfe’s Jackson County residence in sear ch of Jack Greene, a fugitive from justice. Wolfe, outside the residence when the police arrived, stated th at Greene was not in the residence, that she had not seen him, and that she did not know where he wa s. The police entered the residence, found Greene in the bedroom a nd placed him under arre st. A handgun was observed on the nightstand by the bed. Th e police found drug paraphernalia in the residence, along with a white, crystal substa nce believed to be crystal methamphetamine. According to the Statement of Charges, Wolfe’s two year old child was present at that time.3 As a result of the June 13, 2016, inci dent, Wolfe was charged in the Magistrate Court of Jackson County with the misdemea nor offenses of possession of a controlled substance and obstructing an offi cer and the felony offense of child neglect creating risk of injury. 2 In March 2017, the controlled substance and obstructing an officer charges were resolved through Wolfe’s entry into a pretrial dive rsion program. The child neglect creating risk of injury charge was bound over to the Circu it Court of Jackson County but dismissed nolle prosequi by order entered on June 22, 2017.

The Statement of Charges further alleged that, during a urine drug screen conducted on July 5, 2016, a tube cont aining liquid was obser ved taped to Wolfe’s body. According to the police report, Wolfe stat ed that she had worn the tube to pass the drug screen but decided to be honest and abandoned the plan . During the screen , Wolfe urinated as required. Both liquids, however, field-te sted positive for controlled substances (amphetamines and methamphetamine). The resu lting criminal charge was also resolved through pretrial diversion. Finally, the Statement of Char ges alleged that Wolfe wrote a

2 Separate criminal complaints were filed charging the three offe nses. The criminal complaint for possessi on of a controlled substance wa s designated “misdemeanor” and cited W.Va. Code , 60A-4-401 [2011], which sets fort h prohibited acts under the West Virginia Uniform Controlled Substances Act. The criminal complaint for obstructing an officer was also designate d “misdemeanor” and cited W.Va. Code , 61-5-17 [2014], which addresses obstructing an officer, maki ng false statements to an officer, etc . The criminal complaint for child ne glect creaking risk of injury wa s designated “felony” and cited W.Va. Code , 61-8D-4 [2014], which addresses penaltie s for various forms of child neglect.4 worthless check on May 8, 2016, payable to Foodfair in the amount of $148.48. Denying intentional misconduct, Wolfe maintained that she wrote the check on an account which had been closed by the bank without her knowledge. Wolfe entered a no contest plea to the charge and was assessed a fine, costs and restitution. 3

Wolfe self-reported to the Office of Disc iplinary Counsel that she had been charged with possession of a controlled substance, obstr ucting an officer and child neglect creating risk of injury. Upon inquiry, the Investigative Panel found pr obable cause to charge Wolfe in the October 12, 2017, Statement of Charges with a viola tion of Rule 8.4.(b) of the Rules of Professional Conduct. Rule 8.4.(b) states that it is professional misconduct for a lawyer to “commit a criminal act that reflects adversely on the lawy er’s honesty, trustworthiness or fitness as a lawyer in other respects.” The violation of Rule 8.4.(b) was based on the Investigative Panel’s conclu sion that Wolfe possessed a controlled substance and obstructed an officer, and that she attempted to defeat the drug screen and wrote a worthless check.

In addition, based on Wolfe’s attempt to defeat the drug screen and writing a worthless check, the Investiga tive Panel found probable caus e to charge Wolfe with a

3 The criminal complaint regarding Wolfe’s drug screen was designated “misdemeanor” and cited W.Va. Code , 60A-4-412 [2007], which addresses attempts to defeat a drug or alcohol screening test. The criminal comp laint concerning the worthless check cited W.Va. Code , 61-3-39a [2007], which addresses the mi sdemeanor offense of making or issuing a worthless check with respect to a preexisting debt.5 violation of Rule 8.4.(c) which states that it is professional misconduct for a lawyer to “engage in conduct involving dishonesty, fraud, deceit or misrepresentation.”

An evidentiary hearing was conducted befo re the Hearing Panel Subcommittee in April 2018, and on September 11, 2018, the Subcommittee filed its report and recommendations in this Court. The Hear ing Panel Subcommittee found by clear and convincing eviden ce that Wolfe was guilty of (1) possession of a controlled substance in violation of W.Va. Code , 60A-4-401 [2011], (2) attempting to defeat a drug and alcohol screening test in violation of W.Va. Code , 60A-4-412 [2007], and (3) writing a worthless check in violation of W.Va. Code , 61-3-39a [2007]. 4 Consequently, the Hearing Panel Subcommittee concluded that Wolfe violated Ru le 8.4.(b) of the West Virginia Rules of Professional Conduct. Based on the drug scr een and worthless check violations, the Subcommittee also concluded that Wolfe violated Rule 8.4.(c).

As a result of Wolfe’s violations of th e Rules of Professional Conduct, the Hearing Panel Subcommittee recommends that this Court adopt the following sanctions regarding Ms. Wolfe’s license to practice law:

4 Neither the charge of child neglect creating ri sk of injury, which had been dismissed, nor the charge of obstructing an officer, regarding which no ev idence had been presented before the Hearing Panel Subc ommittee, were part of th e Subcommittee’s report and recommendations to this Court.6 a. That [Wolfe’s] law license be suspen ded for a period of one year and six months; b. That [Wolfe] shall participate in th e evaluation and treatment protocol as established by the JLAP [West Virg inia Judicial and Lawyer Assistance Program]; c. That [Wolfe] must comply with th e mandates of Rule 3.28. of the Rules of Lawyer Disciplinary Procedure; and d. [That Wolfe] be ordered to pay the costs of these proceedings pursuant to Rule 3.15. of the Rules of Lawyer Disciplinary Procedure. 5

II. Standards of Review The standards of review in lawyer discip linary cases are well settled. In syllabus point 3 of Committee on Legal Ethics v. McCorkle , 192 W.Va. 286, 452 S.E.2d 377 (1994), this Court held:

A de novo standard applies to a review of the adjudicatory record made before the Committee on Legal Ethi cs of the West Virginia State Bar [currently the Hearing Panel Subco mmittee of the Lawyer Disciplinary Board] as to questions of law, questions of applicati on of the law to the facts, and questions of appropriate sanc tions; this Court gives respectful consideration to the Committee’s recommendations while ultimately exercising its own independent judgment . On the other hand, substantial deference is given to the Committee’s findings of fact, unless such findings are not supported by reliable, probativ e and substantial evidence on the whole record.

5 Rule 3.28. provides, inter alia , that a suspended lawyer shall notify clients of his or her inability to act as a la wyer. Rule 3.15. authorizes the Hearing Panel Subcommittee, or this Court, to order the lawyer to reimbur se the Lawyer Disciplin ary Board for the costs of the disciplinary hearing.7 Accord , syl. pt. 1, Lawyer Disciplinary Board v. Haught , 233 W.Va. 185, 757 S.E.2d 609 (2014); syl. pt. 1, Lawyer Disciplinary Board v. Santa Barbara , 229 W.Va. 344, 729 S.E.2d 179 (2012).

In addition, syllabus point 3 of Committee on Legal Ethics v. Blair , 174 W.Va. 494, 327 S.E.2d 671 (1984), cert. denied , 470 U.S. 1028 (1985), makes clear: “This Court is the final arbiter of legal ethics pr oblems and must make the ultimate decisions about public reprimands, suspensions or annu lments of attorneys’ licenses to practice law.” Finally, we note that Rule 3.7. of th e West Virginia Rules of Lawyer Disciplinary Procedure provides that, in or der to recommend the impositi on of discipline of a lawyer, “the allegations of the formal charge must be proved by clear and convincing evidence.”

With those standards in mind, we re view the findings, conclusions and recommendations of the Hear ing Panel Subcommittee.

III. Discussion The record before this Court sets forth the testimony of nine witnesses, including Ms. Wolfe, who appeared before the Hear ing Panel Subcommittee during the April 2018 hearing. The record also includes other tr anscripts, four volumes of exhibits and supplementary matters. Applying our de novo review of the record thus submitted, this Court concludes that clear and convincing evid ence demonstrates that Wolfe violated Rule8 8.4.(b) and Rule 8.4.(c) of th e Rules of Professional Conduc t by (1) the illegal possession and use of controlled substances, (2) attempti ng to defeat the drug screen and (3) writing the worthless check. The viol ations were shown largely th rough Wolfe’s admissions and self-reporting to the Lawyer Disciplinary Board. The remaining issue, therefore, concerns the Hearing Panel Subcommitte e’s recommended sanctions.

Rule 3.15. of the Rules of Lawyer Di sciplinary Procedure lists the following sanctions which may be reco mmended to this Court by the Hearing Panel Subcommittee regarding a violation of the Rules of Profe ssional Conduct: (1) probation; (2) restitution; (3) limitation on the nature or extent of future practice; (4) supervised practice; (5) community service; (6) admonishment; (7) repr imand; (8) suspension; or (9) annulment. In deciding which sanctions are appropriate, Ru le 3.16. provides that the following shall be considered:
(1) whether the lawyer has violated a dut y owed to a client, to the public, to the legal system, or to the profe ssion; (2) whether the lawyer acted intentionally, knowingly, or negligen tly; (3) the amount of the actual or potential injury caused by the lawyer’s misconduct; and (4) the existence of any aggravating or mitigating factors.

See , syl. pt. 4, Office of Lawyer Discip linary Counsel v. Jordan , 204 W.Va. 495, 513 S.E.2d 722 (1998) (tracking the language of Rule 3.16.).9 With regard to aggravating or mitigating factors under Ru le 3.16., this Court stated in syllabus point 4 of Lawyer Disciplinary Board v. Scott , 213 W.Va. 209, 579 S.E.2d 550 (2003): “Aggravating factors in a lawyer disciplinary proc eeding are any considerations or factors that may justify an increase in the degree of discipline to be imposed.” In comparison, this Court stated in syllabus point 2 of Scott that mitigating factors in a lawyer disciplinary proceeding “are any considerations or factors that may justify a reduction in the degree of discipline to be imposed.” Accord , syl. pts. 5, 6, Lawyer Disciplinary Board
v. Martin , 225 W.Va. 387, 693 S.E.2d 461 (2010).

The report of the Hearing Panel Subcomm ittee shows that all four components of Rule 3.16. were considered wi th respect to Wolfe’s violati on of Rules 8.4.(b) and 8.4.(c) of the Rules of Professional Conduct. The repor t states that clear a nd convincing evidence established that Wolfe violated her duties to the public, the legal system, and the legal profession “by illegally possessi ng drugs, writing a worthless check and attempting to defeat a drug screen.” The report found th at Wolfe’s conduct in writing the worthless check was negligent, but that her possession and use of illegal dr ugs, as well as her attempt to defeat the drug screen, were intentional. Nevertheless, the report determined that the amount of the actual injury caused by Wolfe’s misconduct was moderate: “While the legal system and the legal profession were injured by [Wolfe’s] misconduct, there is no evidence that any of [Wolfe’s] clients suffered dir ect harm. The people most hurt by [Wolfe’s] conduct are her and her family.”10 The Hearing Panel Subcommitte e also considered the pres ence of aggravating and mitigating factors. The Su bcommittee found one aggravatin g factor: Wolfe’s “illegal conduct which involv ed the use of controlled substances.” 6 Two mitigating factors were found: (1) the absence of a prio r disciplinary record and (2) Wolfe’s inexperience in the practice of law.

Finally, the Hearing Panel Subcommittee not ed in its report that Wolfe has entered into a substance abuse recovery plan throu gh the West Virginia Judicial and Lawyer Assistance Program. The repor t further noted the testimony of the Program’s Executive Director, Robert E. Al bury, Jr., who indicated that Wolfe should not be co nsidered for a return to the practice of law until she has comp leted a full year of treatment, recovery and evaluation. The report also st ated that Wolfe exhibited a le vel of defensiveness regarding her history of drug abuse. Commending Wolfe for her rec overy to date, but concluding that Wolfe should be removed from the practice of law for a period of time, the Hearing Panel Subcommittee conclude d that the recommended sanc tions should include a suspension for a period of one year and six months. The Subcomm ittee determined that the suspension time-frame would fall in line with th e time Wolfe would need for treatment, recovery and evaluation through the Assistance Program.

6 The Hearing Panel Subcommittee stated in its report: “While [Wolfe] used heroin and cocaine in her past, the recent charge fo r possession of a controll ed substance involved methamphetamine, which is also an illegal drug.”11 After the filing of the Subcommittee’s report and recommendations, a supplement to the record was filed which confirms th at on May 15, 2018, Wolfe entered into a Monitoring Agreement with the Judicial and Lawyer Assistan ce Program for a period of five years. Attached to th e supplement was a letter to Wo lfe’s counsel dated April 25, 2019, from Executive Director Albury which states in part:
Ms. Wolfe has remained compliant in all monitoring requirements. All random and alcohol and drug screen s have been negative. Further, Ms. Wolfe’s behavior has been and rema ins indicative of a person who is committed to working a pe rsonal program of recovery, and she has earned WVJLAP advocacy. 7

In Office of Disciplinary Counsel v. Alderman , 229 W.Va. 656, 734 S.E.2d 737 (2012), the Office of Disciplinary Counsel filed a petition against an attorney for violations of the Rules of Professional Conduct, including Rules 8.4.(b) and 8.4.(c). Initially taking prescription pain medication following surgery, the attorney became addicted to controlled substances which resulted in two misdemea nor convictions. In 2009, the attorney

7 Executive Director Albury indicated that Wolfe should not be considered for a return to practice until she has co mpleted a full year of treatmen t, recovery and evaluation. At this point, Wolfe has already been under the May 15, 2018, Monitoring Agreement for over one year and will remain subject to the Agreement until May 2023. Director Albury’s April 2019 letter states that Wolfe has be en compliant with m onitoring requirements, exhibited negative alcohol and drug screens, and has been committed to her recovery. Based on a retroactive suspen sion from practice beginning on October 22, 2018, when Wolfe disengaged from th e practice of law, Wolfe will not be eligible for reinstatement until 2020. As the Hearing Panel Subcommittee recommende d, Wolfe’s suspension timeframe, therefore, falls in line with her recove ry Agreement with the Judicial and Lawyer Assistance Program.12 voluntarily ceased practicing law and engaged in treatment for his addiction. The evidence indicated that the attorney be came drug free, had not caused harm to any clients and had been helpful to other indivi duals suffering from addiction.

In Alderman , the Office of Disciplinary Counsel and the attorney reached a joint recommendation the provisions of which included the attorney’s suspension from practice for two years, with one served retroactively based on the a ttorney’s volunta ry withdrawal from practicing law. The second year of su spension would be held in abeyance pending compliance with supervised pr actice, random drug screening, treatment and counseling services and reimbursement of costs.

The joint recommendation in Alderman was accepted by the Hearing Panel Subcommittee and adopted by this Court. Determining that the findings and recommendation were supported by the evidence, this Court noted, in Alderman , that the attorney had repeatedly sought treatment for his addiction, had provided excellent legal services to his clients, had ma intained sobriety, and had coop erated with the investigation conducted by the Office of Di sciplinary Counsel. Finally , this Court observed, in Alderman , that the recommended sanctions were c onsistent with sanctions imposed upon other attorneys for co mparable drug-related and other vi olations and that retroactive applications of suspensions fro m the practice of law have been utilized in the past. 229 W.Va. at 660, 661, 734 S.E.2d at 741, 742.13 The disciplinary proceeding in Lawyer Disciplinary Board v. Hanna , no. 16-0178 (W.Va. Aug. 30, 2016) (unpublished order), al so concerned an atto rney addicted to controlled substances. In Hanna , the attorney used illegal s ubstances while employed as a public defender and was terminated from her em ployment. The attorney admitted that she had twice overdosed on he roin. On January 20, 2016, this Court, in Hanna , entered an order upon the petition of disc iplinary counsel suspending the attorney pend ing completion of the underlying disciplinary proceedings. 8

As in the current matt er, as well as in Alderman , the transgressions alleged against the attorney in Hanna included a violation of Rule 8.4. (b) concerning criminal acts that reflect adversely on a lawyer’s ho nesty, trustworthiness or fitn ess as a lawyer. The Hearing Panel Subcommittee found , however, that the attorney so ught treatment for her addiction at a respected facility and ha d maintained her sobriety. Moreover, the Hearing Panel Subcommittee in Hanna noted that there was no evidence that the at torney had impacted a specific client by her conduct.

8 See Rule 3.27. of the Rules of Lawyer Disc iplinary Procedure auth orizing an interim suspension from the practice of law pendi ng further disciplinary proceedings. See also Rule 3.23. authorizing an ad ministrative suspension from prac tice until further order, based on “mental infirmity or illness or because of addiction to drugs or alcohol.”14 This Court, in Hanna , entered an order on August 30, 2016, suspending the attorney from the practice of law for one year, retroac tive to January 20, 2016 (the date of her interim suspension). Additional sanctions included comp liance with drug screening, treatment and counseling services and reimbursement of costs.

In the case at bar, Ms. Wolfe admitted to a long history of drug abuse beginning at age sixteen. She testified, however, that an intervening incident of domestic violence, which occurred in 2014 just af ter her admission to practice, propelled her into a deeper level of addiction. Testimony reveals that Wolf e was beaten by an individual by the name of Ty Hill and sustained a broken collarbone and a dislocated shoulder. According to Wolfe, her prescribed pain medication was direc tly contributory to her spiral into a heavier level of drug abuse.

However, Wolfe maintains that, in 2016, shortly after the criminal charges were filed against her, she participated in treatment programs for drug abuse and has remained drug free. The answer filed by Wolfe’s counsel to the Statem ent of Charges averred that Wolfe “has been in active trea tment for her drug use and dependency since July 26, 2016, and she is sober and ha s not used any prescrip tion narcotics or illicit substances, including methamphetamine, with the exception of suboxone prescribed by her medical care15 providers since that date.” 9 Nevertheless, until Wolfe reached out to the Judicial and Lawyer Assistance Program dur ing these disciplinary proceedings, she did not have a consistent, ongoing treatment plan to he lp her deal with her addiction issues.

Currently, Ms. Wolfe is subj ect to the five year Moni toring Agreement with the Judicial and Lawyer Assistan ce Program. She has been comp liant with the Agreement and has earned the advocacy of the JLAP. Neverthe less, the record dem onstrates that Wolfe should remain removed from th e practice of law for a period in time while she continues to make progress on her recovery. Th e Hearing Panel Subc ommittee recommends a suspension of one year and six months.

This Court held in syllabus point 3 of Committee on Legal Ethics v. Walker , 178 W.Va. 150, 358 S.E.2d 234 (1987):
In deciding on the appropriate disciplinary action for ethical violations, this Court must consider not only what steps would appropriately punish the respondent attorney, but al so whether the discipline imposed is adequate to serve as an effective dete rrent to other members of the Bar and at the same time restore public confidence in the ethical standards of the legal profession.

9 Suboxone is an “opiate medication that is used to treat narcotic addiction.” Drug Identification Bible , p. 881 (Amera-Chem, Inc. 2014 / 2015). The eviden ce indicates that Wolfe is no longer taking suboxone.16 Accord , syl. pt. 3, Lawyer Disciplinary Board v. Campbell , 240 W.Va. 146, 807 S.E.2d 817 (2017).

Clearly, a suspension is warrant ed in view of Wolfe’s violations of the Rules of Professional Conduct and to ensure that she is receiving the treatment and monitoring she needs before returning to the practice of law. Wolfe has disengaged from the practice of law, and her Monitoring Agreement with the Judicial and Lawyer Assistance Program extends to May 14, 2023. Under the ci rcumstances of this case, we find the recommendations of the Hearing Panel Subco mmittee reasonable and consistent with the admonition, expressed in Walker , to provide a deterrent to other members of the Bar and to restore public confidence in the ethical st andards of the legal pr ofession. We further find it reasonable to apply retroactivity to the recommended suspension of one year and six months, in accord with Alderman and Hanna

.

IV. Conclusion This Court confirms the findings and conclu sions in the report of the Hearing Panel Subcommittee, and we adopt the Subcommittee’s recommendations. Therefore, as a result of Wolfe’s violations of Rules 8.4.(b) and 8.4.(c) of the Rules of Professional Conduct, this Court orders the following sanctions rega rding Wolfe’s license to practice law:17 a. That Wolfe’s law license be suspende d for a period of one year and six months; b. That Wolfe shall particip ate in the evaluation and treatment protocol as established by the West Virginia Judi cial and Lawyer Assistance Program; c. That Wolfe must comply with the manda tes of Rule 3.28. of the Rules of Lawyer Disciplinary Procedure; and d. That Wolfe shall pay the co sts of these proceedings pursuant to Rule 3.15. of the Rules of Lawyer Disciplinary Procedure.

The one year and six month suspension of Wolfe’s license to practice law shall be retroactive to October 22, 2 018, the date Wolfe formally disengaged from the active practice of law.

Law License Su spended and Other Sanctions.