IN RE: Krista Ann WILLIKE (2026)

OPINION AND ORDER

Krista Ann Willike (“Willike”) seeks restoration of her license to practice law in Kentucky after her license was suspended for non-payment of Kentucky Bar Association (“KBA”) dues for the July 1, 2018, to June 30, 2019, fiscal year and for non-compliance with the minimum continuing legal education (CLE) requirements for the 2017-2018 educational year. The Office of Bar Counsel (OBC) forwarded the matter to the Character and Fitness Committee (“Committee”) of the Office of Bar Admissions (“OBA”). The Committee recommended restoration. The Committee then referred Willike to the Board of Bar Examiners to take the restoration examination.¹ On May 20, 2026, Willike received a passing score on the examination and received the Board of Bar Examiners’ recommendation to be readmitted to the KBA. For the reasons set forth below, we restore Willike to the practice of law.

BACKGROUND

Willike, who currently resides in Bowling Green, Kentucky, was admitted to the KBA in 2013. Her KBA member number is 95732. On January 18, 2019, Willike was suspended from the practice of law in Kentucky under SCR ² 3.050 and SCR 3.675 for non-payment of KBA dues for the July 1, 2018, to June 30, 2019, fiscal year and for non-compliance with the minimum continuing legal education (CLE) requirements for the 2017-2018 educational year.

On November 3, 2025, Willike filed an Application for Restoration with the KBA. The Office of Bar Counsel issued a memorandum on July 3, 2025, stating that Willike did not have pending discipline and had not been the subject of any claims against the Clients’ Security Fund. The KBA Accounting Department certified on July 21, 2025, that Willike's dues were paid through the 2025-2026 fiscal year.³ The CLE Commission of the KBA issued a memorandum dated August 22, 2025, stating that Willike was compliant with the CLE requirements set forth in SCR 3.685 for purposes of restoration during the 2025-2026 educational year.⁴

In her application, Willike affirms that she has never: (1) been charged with unprofessional or unethical conduct; (2) been charged with violating any law (other than traffic violations); (3) had an emergency protective order or domestic violence order issued against her; (4) been charged with fraud in any legal proceeding; (5) been adjudged bankrupt; (6) been discharged for unsatisfactory work; (7) been requested to resign from employment; or (8) been adjudicated incompetent or otherwise legally incapacitated. She further affirms that there are no unsatisfied judgments against her. The record contains no evidence contradicting these statements. An Application for Restoration under SCR 3.504 requires providing the names and addresses of three former clients. The Executive Director of the KBA waived this requirement for Willike after communicating with the Applicant about the nature of her previous legal work. As required by the application, Willike provided the names and addresses of three Kentucky attorneys in good standing, each of whom attested to the character and fitness of Willike to practice law in Kentucky.

The Inquiry Commission issued a notice and order on February 4, 2026, determining that Willike's application was complete and that no further investigation beyond review of the application was necessary. On February 6, 2026, the Commission transferred the application to the Office of Bar Admissions. Willike and the Office of Bar Counsel agreed that a formal hearing on Willike's restoration should not be required. On March 16, 2026, after reviewing the full application and the agreement of Willike and the Office of Bar Counsel, the Committee also agreed that a formal hearing was not required.

The Committee found that Willike “met the standards set forth in SCR 3.502 and SCR 3.504 and has proven by clear and convincing evidence that she possessed the requisite character, fitness, and moral qualification for restoration to the practice of law in the Commonwealth of Kentucky.” Accordingly, on March 16, 2026, the Committee submitted its report recommending that Willike's Application for Restoration be approved. The Committee's report and recommendation specified that, if after thirty days there is no appeal taken, under the provisions of SCR 3.504(3)(e), Willike shall be referred to the Disciplinary Clerk, who shall issue a notice of recommended approval to the Board of Bar Examiners to take the restoration exam. The notice was issued on April 27, 2026.

On June 24, 2026, this Court received the OBA's certification that Willike took the restoration examination on May 20, 2026, and received a passing score. Accordingly, the OBA recommended that Willike be readmitted as a member of the KBA.

ANALYSIS

Under SCR 3.504(1), “[a] former member ․ who was suspended for failure to pay dues as provided by SCR 3.050 ․ may be restored to membership upon compliance with the conditions set forth in this rule.” The rule requires that the former member whose suspension from membership has prevailed for five years or longer submit an application and filing fee, as well as all unpaid dues, a certification from the Office of Bar Counsel that the former member has no pending disciplinary matters, and a certificate from the Director of Continuing Legal Education. SCR 3.504(3). After the Director files the foregoing items, the Director shall refer the application to the Inquiry Commission, which imposes an additional fee to be paid to the KBA. Id. The Committee then reviews the application. Id. If the Committee recommends approval of the application and no appeal is taken to the Board of Governors within thirty days, the Applicant becomes eligible to sit for the written examination.⁵ Id. If the Applicant passes the examination, such fact, along with a recommendation for the Applicant's restoration to membership, is certified to the Court and to the Director. Id. “The burden of proof for establishing that the Applicant's present qualifications to practice law in Kentucky is on the Applicant.” SCR 3.504(5).

Having reviewed the application, record, and recommendations from the Committee and the Board of Bar Examiners and noting that neither the Committee nor OBC requested conditions to be imposed, we agree with the recommendations and hereby adopt them pursuant to SCR 3.370(10).

ACCORDINGLY, IT IS HEREBY ORDERED that Krista Ann Willike's Application for Restoration is granted. Pursuant to SCR 3.503(5), Willike is directed to pay all costs associated with this reinstatement proceeding in the amount of $42.17, which should be paid from the deposit against costs. If these costs exceed the deposit paid by Willike, she shall pay any additional costs. If any amount remains after the KBA has recovered its costs, it will be refunded to Willike.

FOOTNOTES

1.   The restoration examination is colloquially known as the “mini bar”.

2.   Rules of the Supreme Court.

3.   Although we are currently in the 2026-2027 fiscal year, KBA dues are due on or before September 1, 2026. A notice of delinquency is mailed after October 15, 2026.

4.   Although the original certification from the Director for CLE only covered the 2025-2026 educational year, a subsequent memo issued on July 15, 2026, by the Director of Continuing Legal Education states that the “applicant is compliant with the CLE requirement set forth in SCR 3.685 for purposes of restoration/reinstatement and will not need to recertify CLE compliance for future educational years.”

5.   Effective August 18, 2026, the Kentucky Supreme Court issued Administrative Order 2026-29, which suspended this reinstatement requirement.

All sitting. All concur.