Monthly Archives: February 2014

Top Colorado CLE FAQ

When are my Colorado CLE credits due?

When do I report CLE compliance?

How do I report compliance?

These are some of the questions that we hear everyday when we speak to our attorneys.  We know that many of you have questions about your CLE compliance.  The information is not always easy to find and the state bars don’t always make things easy.

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For that reason, we have created a CLE FAQ for many of the states around the country, including a CLE FAQ for Colorado attorneys.  Attorneys in the Centennial State are required by the Colorado CLE Board to complete their CLE obligation every three years.  Luckily for attorneys in Colorado, they may complete their entire CO CLE requirement through online and downloadable CO CLE courses.

Top Colorado CLE Questions

What are the mandatory CLE requirements in Colorado?

Colorado attorneys must complete at least forty-five (45) CO CLE credit hours every three years.

How many online Colorado CLE courses can I take through Attorney Credits?

All forty-five (45) CLE credit hours.

How do Attorney Credits’ CLE courses qualify for CLE credit in Colorado?

Online CLE courses are considered to be Home Study Credits in Colorado. Colorado attorneys may satisfy all CLE requirements through Attorney Credits’ online courses. To receive CLE credit for any home study course, a Homestudy Affidavit must be submitted to the Supreme Court Board of Continuing Legal and Judicial Education (Colorado CLE Board). Every Colorado attorney was given a Homestudy Affidavit from the Colorado Supreme Court upon admission to the bar, or subsequently with an address change.

How is CLE compliance reported to the Colorado CLE Board?

If you have already completed your CO CLE requirement, the Colorado CLE Board will send you a confirmation e-mail during the last year of your current compliance period. If you have not completed the CO CLE requirement, the CLE Board will send you an email with information and guidelines explaining how to remedy your CLE deficiency. This email will be sent in May of the last year of your current compliance period. In November, a final notice will be sent to you if you have not complied at that point.

Does Attorney Credits report my CO CLE hours completed to the CO CLE Board?

Attorney Credits does not report your compliance to the Colorado CLE Board. While CLE sponsors are required to retain CLE attendance records, CLE sponsors may not file CLE compliance information on behalf of an individual Colorado attorney.

What if I don’t report my Colorado CLE compliance by January 31?

If you fail to complete the required CO CLE units at the end of your compliance period, your final Affidavit may be accompanied by a specific plan for curing the CLE deficiency within 119 days (17 weeks) after the date that the final affidavit is issued. When filed, the CLE deficiency plan must be accompanied by a make-up plan filing fee. The CO CLE Board will determine the amount of the fee annually. The CLE deficiency plan will be deemed accepted by the CO CLE Board, unless within 14 days after the CLE Board’s receipt of the final affidavit the Board notifies the attorney that the plan has been rejected. Full completion of the CLE make-up plan will be reported by the attorney to the CLE Board no later than 14 days following the 119-day period.

Who can I contact for more information about CO CLE?

For more information about CO CLE, please call the State Bar of Arizona at (303) 928-7771. You may also contact Attorney Credits support via email or telephone. For further assistance and information about Colorado CLE, please call our Support Center at (877) 910-6253 or visit our support page on the website.

Attorney Credits offers CLE for Colorado attorneys.  Attorneys may complete CO CLE courses in the following media formats: streaming video & audio, MP3 and video download (MP4).  Completing courses online saves you time and money, and many attorneys are impressed with the ability to complete CLEs from the home, office or on-the-go.  We also offer MP3 Player and USB Stick compliance packages that come pre-loaded with all 45 required CO CLE credit hours.

For more information about CLE in Colorado, please click the following link: Colorado CLE.

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Arizona CLE Deadline is June 30th

screen-capture-1Attorneys in Arizona have continuing legal education obligations like most attorneys around the country.  Attorneys in Arizona must complete 15 credit hours by June 30 as part of the Arizona MCLE (Mandatory Continuing Legal Education) requirement.[1]  As part of this 15 credit hour AZ CLE requirement, attorneys must complete a minimum of 3 credit hours of Professional Responsibility credit.

How many AZ CLE hours are required?

A total of 15 credit hours, including 3 credit hours if Professional Responsibility.  The educational year is July 1 to the following June 30.

In order to properly report AZ MCLE compliance, Arizona lawyers must submit proof of compliance with the AZ MCLE requirements each year on a form provided by the State Bar of Arizona.  Unless exempted, this affidavit must be filed by September 15 of each year.[2]   A blank affidavit is also provided in the September edition of the Arizona Attorney magazine that is issued in mid-August.

AZ CLE Provider Approval

Arizona does not certify courses or providers. Arizona lawyers are required to independently review the AZ MCLE Regulations regulations and make their own determination that it qualifies for credit towards their MCLE requirements. MCLE Regulation 104(A) identifies the standards to apply.[3]

Arizona does not certify CLE courses or CLE Providers.  However, Attorney Credits offers CLE courses in over 30 states across the country and we are Approved Providers of CLE in a number of jurisdictions.  We have also had hundreds of Arizona attorneys complete thousands of CLE courses by completing our online and offline CLE courses. For more information about CLE in Arizona please click here: AZ CLE.


[1] New members/registrants admitted or registered with the Bar during the first half of an educational year (July to December) have a reduced requirement of 10 total hours, of which two are professional responsibility.  Members/registrants admitted or registered with the Bar during the second half of an educational year (January to June) have no CLE requirement for that year.

http://www.azbar.org/cleandmcle/mcle/frequentlyaskedquestionsaboutmcleinarizona

[2] Online CLE filing is available beginning in mid-July.

[3] Mandatory Continuing Legal Education

http://www.azbar.org/MCLE

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Top CLE FAQ in New Jersey

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New Jersey recently made CLE mandatory for its attorneys.  When the mandatory CLE program first began in New Jersey, attorneys were required to complete 12 credits hours.  The requirement has since been bumped up to 24 mandatory CLE credit hours every two years.

An attorney holding a license to practice in this State shall be required to participate in a program of continuing legal education in accordance with regulations adopted under these rules. In satisfaction of the continuing legal education requirement, attorneys shall participate in twenty-four hours of qualifying continuing legal education over a two-year period. Four of the twenty-four hours of credit shall be concentrated in the areas of ethics and/or professionalism.[1]

However, since the mandatory CLE program is still so new in New Jersey, many New Jersey attorneys still have numerous questions about their NJ CLE requirement.  Attorneys have questions on everything from how many units must be completed to the NJ CLE requirements if you don’t live inside the borders of New Jersey.  And we know that it’s not always easy to find the answers to the NJ CLE questions that you may have.

Top New Jersey CLE Questions

What are the mandatory CLE requirements in New Jersey?

  • New Jersey lawyers must complete at least twenty-four (24) NJ CLE credit hours every two years, including four (4) mandatory credit hours of legal ethics.

When must I complete my NJ CLE requirement and report my NJ CLE compliance?

  • The New Jersey CLE compliance and CLE reporting deadline is December 31.

What are the CLE compliance groups in New Jersey?

  • Each New Jersey attorney is permanently assigned to one of two compliance groups for CLE purposes, with one compliance group reporting each year. Compliance Group 1: Attorneys whose birthday fall between January 1 to June 30 must certify their NJ CLE compliance in each EVEN numbered year next following the completion of a compliance period. Compliance Group 2: Attorneys whose birthdays fall between July 1 to December 31 must certify their NJ CLE compliance in each ODD numbered year next following the completion of a compliance period.

How many online New Jersey CLE courses can I take through Attorney Credits?

  • Without a medical or non-resident exception, New Jersey attorneys may only complete twelve (12) of the required twenty-four (24) NJ CLE units through Attorney Credits’ online NJ CLE courses.

What is the medical exception in New Jersey?

  • Attorneys that have a serious medical condition may apply to the New Jersey CLE Board to obtain all of their required CLE credits through alternative verifiable learning formats such as online CLE courses. A licensed physician must certify to the New Jersey CLE Board that the attorney is unable to attend live CLE courses. Attorneys who qualify for this exception and obtain approval from the New Jersey CLE Board can complete all of their required NJ CLE credits through alternative verifiable learning formats.

What is the non-resident exception in New Jersey?

  • Under BCLE 201:8 lawyers admitted to the New Jersey Bar Association who reside in, work in, and are licensed in another mandatory CLE state that allows for 100% of CLE courses to be taken through alternative verifiable learning formats may satisfy their entire NJ CLE requirement through 100% alternative verifiable learning formats.

What is an alternate verifiable learning format?

  • Alternate verifiable learning format CLE courses are those NJ CLE courses that are presented on videotape, audiotape, remote place viewing, online Internet computer courses, webinars, webcasts, podcasts, satellite simulcasts, teleconferences, videoconferences, and Internet computer self-study.

Does the NJ MCLE Board keep a record of my CLE activities?

  • The New Jersey CLE Board does not keep track of individual New Jersey attorney’s credit-by-credit course work. New Jersey attorneys must maintain possession of their Certificates of Completion for at least 3 years. In the event of an audit, attorneys will be asked to produce CLE records to verify their NJ CLE compliance. Each New Jersey attorney is responsible for keeping track of the NJ CLE courses that he or she takes toward compliance with the mandatory NJ CLE requirement. The Certificate of Completion issued by Attorney Credits should be maintained and used to verify attendance.

How do I report my NJ CLE compliance?

  • New Jersey attorneys will certify NJ CLE compliance on the Annual Attorney Registration and Billing Statement. Every New Jersey attorney is assigned to one of two compliance groups that is determined by birth date. Compliance Group 1 (born January 1 – June 30) will certify NJ CLE compliance in even-numbered years and Compliance Group 2 (born July 1 – December 31) will certify NJ CLE compliance in odd-numbered years.

Who can I contact for more information about NJ CLE?

  • For more information about CLE in New Jersey, please call the New Jersey CLE Board at (609) 633-9733. You may also contact Attorney Credits support via email or telephone. For further assistance and information, please call our Support Center at 877-910-MCLE (6253) or visit the support page on the website.

For that reason we have compiled the answers to the top CLE questions in New Jersey for you on our NJ CLE webpage.  I have included the questions and answers above.  To see a list of the full questions and answers, please click here: NJ CLE FAQ.

[1] RULE 1:42. Continuing Legal Education

http://www.judiciary.state.nj.us/rules/r1-42.html

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Protecting Your Client’s Brand: Tips For Talent Lawyers From a Litigation Perspective

From copyright infringement to right of publicity violations, protecting your client’s brand can be an extremely daunting task if you are a talent attorney.  Join attorney Chris Arledge of One LLP as he provides an excellent overview of how entertainment attorneys can best use intellectual property law to protect their client’s brand.

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The main topics addressed in this CLE course include intellectual property protection, copyright issues for talent attorneys and specific litigation tips based on previously litigated cases.  You can access the course by clicking on the following link: Protecting Your Client’s Brand: Tips For Talent Lawyers From a Litigation Perspective.

Further issues addressed in this CLE course include:

  • Sources of legal protection
  • Patents
  • Trademarks
  • Copyrights
  • False Endorsement
  • The Right of Publicity
  • The Lanham Act
  • Design patents
  • Original works of authorship
  • “Fixed in a tangible medium of expression”
  • The Fair Use doctrine
  • Copyright authorship
  • Copyright reversion
  • The Superman heir’s copyright conversion case

The specific litigation discussed includes Don Henley, et al. v. Charles S. Devore, et al., CMG Brands v. Stop Staring! Designs, Patricia Day vs. Wonderama Toys and L.A. Triumph vs. Madonna Luis Ciccone.  Christopher W. Arledge is a co-founder and managing partner of One LLP.  His main focus at One LLP is intellectual property litigation and he focuses on disputes over copyrights, trademarks, and trade secrets.  In recent years, he has handled disputes involving the intellectual property of celebrities such as Don Henley, Kobe Bryant, Madonna, Bette Davis, and Perez Hilton.

This Entertainment Law CLE course is currently accredited in the following states:

  • Alaska (AK)
  • Arizona (AZ)
  • California (CA)
  • Connecticut (CT)
  • District of Columbia (DC)
  • Georgia (GA)
  • Illinois (IL)
  • Maryland (MD)
  • Massachusetts (MA)
  • Michigan (MI)
  • New Jersey (NJ)
  • New York (NY)
  • Pennsylvania (PA)
  • South Dakota (SD)

Attorney Credits offers continuing legal education (CLE) for attorneys in California and around the country.  For more information about CLE in California please click the following link: California CLE.

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Winning on Appeal

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If you are a trial attorney with an eye towards appeal or you are an appellate attorney looking to hone your craft, we have just added an excellent new course presented by Peter R. Afrasiabi of One LLP.

“Legal contentions, like the currency, depreciate through over-issue. The mind of an appellate judge is habitually receptive to the suggestion that a lower court committed an error. But receptiveness declines as the number of assigned errors increases. Multiplicity hints at a lack of confidence…. multiplying assignments of error will dilute and weaken a good case and will not save a bad one.”                                                                      – U.S. Supreme Court Justice Robert Jackson

In the course, Peter addresses the keys to effective appellate representation. The main topics covered include the appeals process, standards of review, the appellate brief, oral arguments and a number of other pertinent topics.  To access the course, please click here: Winning on Appeal.

Further issues addressed include:

  • Reasons to secure appellate counsel
  • When to file the notice of appeal
  • Rule 4(a)(2) & the ripening lesson
  • Tolling
  • Clear error
  • Questions of law
  • Abuse of discretion
  • Arbitrary & capricious
  • Standards of review & prejudicial error in the briefing
  • Using an “introduction” section in the brief
  • Choosing issues wisely
  • Stating exactly what you want the court to hold
  • Your audience
  • The merits panel
  • The response prism
  • Avoiding overselling your case
  • Q & A during oral arguments
  • Effective arguments
  • Amicus briefs
  • The Federal Appellate Mediation Program
  • The Pro Bono Appellate Program.

From battles with Madonna over the “Material Girl” brand to fair use disputes with the Eagles’ Don Henley to protecting such iconic brands as Bettie Page in trademark and trade dress disputes, Peter R. Afrasiabi primarily handles copyright, trademark, and entertainment disputes. Recognized for his expertise, Mr. Afrasiabi has been a legal commentator on NBC and CBS, in addition to being recognized as a Super Lawyer. In addition to being an adjunct professor of law, he was selected by the University of California’s prestigious CEB publications division to author an annual intellectual property chapter entitled Copyrights, Patents and Trademarks. Mr. Afrasiabi’s book Show Trials was a 2012 Indie Book National Finalist.

This CLE course on effective appellate representation is currently accredited in the following states:

  • Alaska (AK)
  • Arizona (AZ)
  • California (CA)
  • Connecticut (CT)
  • District of Columbia (DC)
  • Georgia (GA)
  • Illinois (IL)
  • Maryland (MD)
  • Massachusetts (MA)
  • Michigan (MI)
  • New Jersey (NJ)
  • New York (NY)
  • Pennsylvania (PA)
  • South Dakota (SD)

Attorney Credits offers continuing legal education (CLE) for attorneys in Illinois and around the country.  For more information about CLE in Illinois please click the following link: Illinois CLE.

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Texas CLE: 3 Hours of Legal Ethics Annually

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Attorneys licensed by the State Bar of Texas must complete a minimum of 15 TX CLE credit hours each annual TX MCLE compliance period as part of the mandatory CLE (Continuing Legal Education) requirement in Texas.  Attorneys in Texas have a variety of methods to complete their CLE – from online streaming CLE courses to downloadable MP3 CLE courses.

Legal Ethics shall include programs that deal with usages and customs among members of the legal profession, involving their legal and professional duties toward one another, toward clients, and toward the courts.[1]

Like every other state in the country that has mandatory CLE requirements, Texas attorneys must also complete legal ethics courses.  As part of the mandatory 15 credit TX CLE requirement, Texas attorneys must complete 3 credit hours of Legal Ethics or Professional Responsibility.

Legal Professional Responsibility shall include programs that deal with maintaining the integrity and competence of the Bar so that legal services are delivered with the highest degree of professional conduct.[2]

Attorney Credits offers a number of pre-approved TX CLE courses that qualify for legal ethics and professional responsibility credit on a variety of subjects.  From the top 10 ways to stay out of ethical trouble to alcoholism in the legal profession, we have some extremely interesting and informative ethics courses.  Here is a list below of some of the titles:

  • Avoiding Ethical Violations and Legal Malpractice Claims: An Expert’s Perspective
  • Elimination of Bias in the Legal Profession
  • Ethics for Lawyers in the Cloud
  • Ethics in a Web 2.0 World
  • Fee Agreements: Ethics & Reasonableness
  • Honesty is Best Policy: How Far Can You Go in Negotiations
  • Personal Injury: An Ethically Hazardous Practice Area
  • Practical Ethics: Avoiding Trouble with Clients, Courts and the State Bar
  • Take Five: Edifying and Educational Ethical Examples
  • Top 10 Ways to Stay Out of Ethical Trouble
  • Working with Experts

For further information about CLE in Texas, please click the following link: TX CLE.


[1] Accreditation Standards for CLE Activities – Definitions

https://www.texasbar.com/Content/NavigationMenu/ForLawyers/MCLE/MCLERules/AccrStandards-2010.pdf

[2] Accreditation Standards for CLE Activities – Definitions

https://www.texasbar.com/Content/NavigationMenu/ForLawyers/MCLE/MCLERules/AccrStandards-2010.pdf

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NY CLE Requirements

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Experienced attorneys admitted to the New York State Bar Association must complete at least twenty-four (24) accredited CLE credit hours every two-year compliance period in order to full the NY CLE requirement.  An “experienced” New York attorney is an attorney that has been admitted to the New York State Bar Association for more than two (2) years.[1]  At least 4 of the required 24 credit hours must be in the Ethics and Professionalism category of credit and the remaining credit hours may be in any category of NY CLE credit.

NY CLE Requirements for Experienced NY Attorneys

  • NY CLE Credits Required: 24
  • NY CLE Reporting Cycle: 2 years
  • NY CLE Compliance Deadline: Your Birthdate 
  • NY CLE Reporting Deadline: 30 days after your birthday

Experienced attorneys may earn NY CLE credit in a number of ways – from live CLE courses to audiotapes, videoconferences and online CLE courses.  The key is that the New York State CLE Board has either accredited the CLE Provider to offer the course in the particular format or the course is eligible for credit under New York’s Approved Jurisdiction policy.  Attorney Credits is an Accredited Provider of Continuing Legal Education (NY CLE) in New York and we are approved to offer streaming audio & video, CD, DVD, MP3 and video download CLE courses.

What kinds of courses count toward my CLE requirement?

Experienced attorneys may earn CLE credit by attending CLE courses offered in the traditional live classroom format, or in nontraditional formats such as audiotapes, videoconferences, online, etc., so long as the CLE Board has accredited the provider to offer the course in the particular format, or the course is eligible for credit under New York’s Approved Jurisdiction policy.[2]

In order to report your NY CLE compliance you must file your attorney registration form and complete your CLE requirement within 30 days after your birthday on alternate years.[3]  At the time of the biennial registration all New York attorneys must certify that they have completed their CLE requirement for that NY CLE reporting cycle and that they have retained the proper CLE records.  Failing to report your NY CLE compliance can lead to fines, suspension and possible disbarment.

For more information about New York CLE requirements please click here: NY CLE.


[1] Its important to note that newly admitted attorneys to the New York State Bar Association have their own set of special NY CLE requirements.

[2] FAQs for Experienced Attorneys

http://www.nycourts.gov/attorneys/cle/attorney_faqs.shtml#s1_q3

[3]  If you were admitted to the New York State Bar Association before January 1, 1982, or in an even-numbered year then you will register in even-numbered years. If you were admitted in an odd-numbered year after 1982, then you register in odd-numbered years.

[3] FAQs for Experienced Attorneys

http://www.nycourts.gov/attorneys/cle/attorney_faqs.shtml#s4_q1

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June 30 IL MCLE Deadline

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For certain attorneys in Illinois it’s almost that time again.  Time to complete your Illinois MCLE requirement!  The deadline this year to complete your IL MCLE requirement is June 30, 2014.  Illinois is split into two different reporting groups for Illinois MCLE compliance.  This year attorneys with the last name A-M must complete their 30 credit hour IL MCLE requirement.[1]

Illinois MCLE Compliance Requirements:

  • Reporting Cycle: 2 years
  • Compliance Deadline: June 30
  • Reporting Deadline: Jul 31

Illinois is a self-reporting CLE state.  All Illinois attorneys are required to report compliance, non-compliance or exemptions by July 31, 2014.  The Illinois MCLE Board will mail an MCLE Certification Form to each Illinois attorney at the mailing address on file with the ARDC (Attorney Registration and Disciplinary Commission). The Certification Form must be properly completed and returned to the IL MCLE Board by the due date printed on the form.  Illinois attorneys that fail to complete their IL MCLE requirement face fines, suspension and even being removed from the Master Roll of Attorneys.

There is no limit to the amount of Illinois CLE hours an attorney can earn by viewing or listening to courses that are recorded as long as there is an interactive component to the delivery methods. These delivery methods may include on-demand programming, videotape, DVD, CD and podcasts.

Luckily, Illinois attorneys have a variety of options to fulfill their IL MCLE requirement, including computer based education.  Attorney Credits is an Approved CLE Provider in Illinois and we have a number of options for you to complete your Illinois MCLE requirement.  As part of CLE Your Way, Attorney Credits offers a number of different ways for Illinois attorneys to study and complete their IL CLE, including streaming audio, streaming video, MP3, video download, CD & DVD.

For more information about the Illinois MCLE requirement, please click here: IL CLE.


[1] As part of this 30 credit IL MCLE requirement, attorneys must also complete at least 6 credit hours of Professional Responsibility.

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Florida CLE: 30 Online CLE Units

screen-capture-1Every state regulates the conduct of its own attorneys – everything from bar admission to the grounds for disbarment … and everything in between.  And continuing legal education is no exception.  Each state across the country determines the continuing legal education (CLE) requirement for attorneys admitted to practice within its borders.  CLER, or Continuing Legal Education Requirement, was adopted by the Supreme Court of Florida in 1988 and requires all members of The Florida Bar to continue their legal education.[1]

Florida calls it mandatory continuing legal education program the CLER – Continuing Legal Education Requirement.[2]

The Florida CLER requires all members of The Florida Bar (without a valid exception) to continue their legal education by completing Florida CLE courses.  Every three-year compliance period each member of the Florida Bar must complete a minimum of 30 FL CLE credit hours – including 5 credit hours in the area of ethics, professionalism, substance abuse, or mental illness awareness.

Does The Florida Bar allow credit for audio/video or computer CLE?

Florida lawyers may satisfy all Florida CLE requirements through online CLE courses.[3]

Florida attorneys do have the luxury of fulfilling all 30 required CLER hours through online and offline CLE courses.  The Florida Bar allows the entire CLER to be fulfilled via streaming audio & video, MP3, MP4, CD and DVD CLE courses.  For more information about Attorney Credits’ Florida CLE courses and the CLER in Florida please click this link: Florida CLE.


[1] Frequently Asked About CLER

http://www.floridabar.org/tfb/TFBMember.nsf/ed6e4bcb92a8fe1b852567090069f3c2/dde037de5dcfe59885256b2f006c6a4d?OpenDocument

[2] The Florida CLER was adopted by the Supreme Court of Florida back in 1988.

[3] Florida CLE FAQ

http://www.attorneycredits.com/florida-cle-faq

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Group 3 Late California MCLE Compliance

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The State Bar of California requires active California attorneys  (with some exceptions) to complete 25 hours of continuing education every three years.  As part of the 25 credit hour requirement attorneys must complete at least four hours of legal ethics, one hour of elimination of bias in the legal profession and one hour of substance abuse.  For Group 3 attorneys (N-Z) the compliance deadline was January 31, 2014.  The deadline to report MCLE compliance for Group 3 attorneys is today, February 3, 2014.

“You cannot be disbarred for failure to take MCLE … But you can be disbarred for lying about it.”[1]

                            – Jerome Fishkin, Walnut Creek legal ethics attorney

Failing to complete your California MCLE requirements can result in negative consequences, including fines and placement on administrative inactive status.  Further, California attorneys that are audited by the State Bar and found to have falsely reported their California MCLE compliance may also face discipline and possible disbarment.  There have been a number of moral turpitude cases brought against California attorneys who lied about completing the CA MCLE requirement.

Extensions of Time

If you can comply by June 30, there is no need to request an extension of time, although a late fee of $75 will be assessed if you have not reported your compliance by February 1.[2]

Luckily for California attorneys in Group 3, you can still complete your MCLE requirement.  You will have to pay a $75 fine and you will have until June 30, 2014, to complete your CA MCLE requirement.  Don’t get disbarred!  Get your MCLE done and remain in compliance with the State Bar of California.  To see Attorney Credits 25 credit hour CA MCLE compliance packages please click here: CA CLE.


[1] MCLE Audits Catch Lawyers Off Guard

https://www.callawyer.com/clstory.cfm?eid=928451&wteid=928451_MCLE_Audits_Catch_Lawyers_Off_Guard

[2] http://mcle.calbar.ca.gov/Attorneys/Requirements/GoodCauseModification.aspx

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