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IN RE: the Petition for Leave to Appeal of Lindsay E. DANSDILL Lindsay E. Dansdill, Petitioner v. Disciplinary Board of the Supreme Court of North Dakota, Respondent
[¶1] Lindsay E. Dansdill appeals a private admonition issued by the Inquiry Committee West, and approved by the Disciplinary Board, for violating N.D.R. Prof. Conduct 5.5. We affirm.
I
[¶2] Dansdill is licensed in Illinois, Nevada, and California, but not North Dakota. On March 28, 2022, Dansdill initiated a lawsuit in Cass County District Court on behalf of her client. The complaint lists as counsel both local counsel and Dansdill. Dansdill's signature block did not include her signature.
[¶3] On October 11, 2022, local counsel filed a motion for pro hac vice admission on Dansdill's behalf. In her supporting affidavit, Dansdill stated under oath a “copy of the motion has this date been filed with the State Board of Law Examiners” and “the applicable admission fee has been paid.” The district court granted the motion the same day, ordering “Dansdill is allowed to appear pro hac vice as an attorney for Plaintiff in the above-captioned matter[.]” Contrary to her affidavit, Dansdill had not filed a copy of the motion with the State Board or paid the applicable fee.
[¶4] From October 2022 through June 2024, Dansdill practiced law in North Dakota, attending hearings, conducting discovery, and drafting motions, without filing the pro hac vice paperwork with the State Board of Law Examiners or paying the required fees for 2022, 2023, or 2024. On June 18, 2024, the State Board notified the Cass County district court, Dansdill, and the Office of Disciplinary Counsel of Dansdill's noncompliance with North Dakota Admission to Practice Rule 3. The court issued an Order to Show Cause. Dansdill promptly paid the outstanding fees, submitted the paperwork, and apologized to the court and to the State Board for the error. At an August 6, 2024 hearing, the court admonished Dansdill but did not revoke her pro hac vice admission. In September 2024, the parties to the Cass County lawsuit resolved the case during mediation. Counsel for one of the defendants filed a stipulation of dismissal in November 2024. The court subsequently entered an order for dismissal with prejudice and judgment of dismissal with prejudice.
[¶5] On November 18, 2024, the Office of Disciplinary Counsel notified Dansdill a complaint had been filed against her and requested she respond within twenty days. See N.D.R. Lawyer Discipl. 3.1(D)(2), (3). The attached complaint, the June 18, 2024 email from the State Board of Law Examiners, alleged Dansdill “is not in compliance with Admission to Practice Rule 3.” Dansdill, through counsel, responded to the complaint.
[¶6] On January 17, 2025, Disciplinary Counsel issued an Investigative Report of Informal Complaint, which was sent to Dansdill's counsel and the members of the Inquiry Committee. See N.D.R. Lawyer Discipl. 3.1(D)(5). Summarizing the allegations, Disciplinary Counsel wrote, Dansdill “appeared on behalf of her client in a case venued in Cass County, North Dakota, from 2022 through 2024.” She further wrote, “although Dansdill moved for and was granted admission pro hac vice by the District Court, she failed to file the paperwork with the State Board's office. In addition, Dansdill never paid the required annual fee of $380 for each of those years.” Disciplinary Counsel wrote the allegations suggest potential violations of N.D.R. Prof. Conduct 3.3 (candor toward the tribunal) and 5.5 (unauthorized practice of law).
[¶7] In her investigative report, Disciplinary Counsel opined:
Dansdill failed to properly follow the Rules for pro hac vice admission into North Dakota. See N.D. Admission to Practice R. 3. Dansdill did not file the paperwork with the State Board of Law Examiners, nor did she remit the appropriate fee to obtain pro hac admission. See N.D. Admission to Practice R. 3(A)(1)[(a)](3)-(4). Pro hac vice admission was required for her as a lawyer who was appearing, whether in person or by signing pleadings, in an action filed in state court. See N.D. Admission to Practice R. 3(A). As a result of Dansdill's failure to follow the proper procedure for pro hac vice admission, she is subject to the North Dakota Rules for Professional Conduct. See N.D.R. Prof. Conduct 8.5(b).
Dansdill inaccurately represented to the Court in October 2022 when she filed her motion for pro hac vice admission that she had filed the applicable paperwork with the State Board of Law Examiners and paid the admission fee of $380. Rule 3.3, N.D.R. Prof. Conduct, governs a lawyer's conduct while representing a client in the proceedings of a tribunal. A lawyer shall not knowingly make a false statement of fact or law to the court or fail to correct a false statement previously made to the court by the lawyer. N.D.R. Prof. Conduct 3.3(a). Pursuant to Rule 3[(A)(1)](b)(7), N.D. Admission to Practice R., Dansdill was required to state in her affidavit that the fee had been paid to the State Board of Law Examiners and was required to do so for each calendar year in which she was admitted, see N.D. Admission to Practice R. 3[(A)](1)[(a)](4).
When signing the affidavit accompanying her motion affidavit, Dansdill was unaware that her admission fee was not paid by her office's business manager. As a result, she was not aware she was making an inaccurate statement to the Court. Additionally, Dansdill admitted that she never confirmed that the paperwork had been subsequently sent to the State Board. She further admitted that it was ultimately her responsibility to ensure compliance with the statements within her affidavit. While it may have been due to an oversight and lack of understanding regarding the pro hac vice admissions process within North Dakota, the representations to the Court within the affidavit were not accurate. As a result, probable cause of a violation of Rule 3.3(a), N.D.R. Prof. Conduct, is present.
Dansdill did not complete the pro hac vice admissions process within 45 days after she filed the complaint in March 2022. Rule 3(A)(2), N.D. Admission to Practice R., requires the motion requesting permission to appear to be filed no later than 45 days after the service of the pleading, motion, or other paper. Dansdill did not submit her motion for pro hac vice admission until October 2022, well beyond the permissible 45 days given by the Rule. As a result, by filing the matter and failing to comply with the applicable admissions time frame, Dansdill engaged in the unauthorized practice of law in North Dakota. See N.D. Admission to Practice R. 3; N.D.R. Prof. Conduct 5.5(a).
After Dansdill sought and had her motion for pro hac vice admission granted by the District Court, it was raised in June 2024 that Dansdill had not been properly admitted to practice. Rule 5.5(a), N.D.R. Prof. Conduct, states that a lawyer shall not practice law in a jurisdiction where doing so violates the regulation of the legal profession in that jurisdiction. Dansdill's practice of law did not fall into the safe harbors provided within subsection (b) or (c) of Rule 5.5, N.D.R. Prof. Conduct. Additionally, the lawyer shall not represent or hold out that the lawyer is admitted to practice law in North Dakota. See N.D.R. Prof. Conduct 5.5(d). By continuing to make filings from March 2022 through June 2024, Dansdill was repeatedly practicing law and holding out that she was properly admitted. From the time of the filing of the complaint, Dansdill actively represented her client, despite the lack of a valid pro hac vice admission. While Dansdill asserts this was an innocent oversight, this was not caught with a review of her billings, nor with calendaring for the annual payment of her admission fee in 2023 or 2024. See N.D.C.C. § 27-11-22. As a result, there were multiple times that this error should have been caught, but was not. To Dansdill's credit, she immediately rectified the issue once the State Board of Law Examiner's brought it to her attention. Despite the correction and the assertions that this was an oversight, Dansdill still practiced law for a period of approximately three years without a valid license. See N.D.R. Prof. Conduct 5.5. Accordingly, probable cause is present that Dansdill violated Rule 5.5, N.D.R. Prof. Conduct.
[¶8] After an investigation, further correspondence, and a Committee meeting at which Dansdill appeared with counsel, the Inquiry Committee issued a notice of disposition on May 8, 2025. See N.D.R. Lawyer Discipl. 3.1(D)(7), (8). The notice informed Dansdill the Committee found, by clear and convincing evidence, “Dansdill violated Rule 5.5 of the North Dakota Rules of Professional Conduct by appearing in North Dakota Courts without being properly licensed.” The Committee “determined that Dansdill was remorseful, believed she was practicing properly without any notice to the contrary, that no client was harmed, and that she had no prior disciplinary history.” The Committee issued an admonishment. See N.D.R. Lawyer Discipl. 2.4(F)(2)(c); see also N.D. Stds. Imposing Lawyer Sanctions 1.2 (“Only in cases of minor misconduct, when there is little or no injury to a client, the public, the legal system, or the profession, and when there is little likelihood of repetition by the lawyer, should private discipline be imposed.”). The notice did not reference or find a violation of N.D.R. Prof. Conduct 3.3.
[¶9] Dansdill timely appealed the Inquiry Committee's determination to the Disciplinary Board. See N.D.R. Lawyer Discipl. 3.1(D)(8). On November 4, 2025, the Disciplinary Board approved the decision of the Inquiry Committee to issue an admonition. See N.D.R. Lawyer Discipl. 2.1(H)(1).
[¶10] Dansdill filed her Petition for Leave to Appeal on December 26, 2025. See N.D.R. Lawyer Discipl. 3.1(D)(8). On January 26, 2026, this Court ordered Dansdill made a sufficient showing to allow the appeal to go forward. See N.D.R. Lawyer Discipl. 3.1(F).
II
[¶11] Dansdill argues the Disciplinary Board acted improperly in admonishing her for violating N.D.R. Prof. Conduct 5.5 because the Cass County district court had issued a valid order allowing her to appear pro hac vice in the matter. Dansdill argues the Board is disciplining her for failing to comply with the North Dakota Admission to Practice Rules, not a rule of professional conduct. She asserts there “is simply no authority, anywhere,” to support the position the Inquiry Committee or Board “have authority to discipline an attorney for violating non-disciplinary rules.”
[¶12] The Disciplinary Board responds that a nonresident lawyer's violation of the Admission to Practice Rules is a violation of N.D.R. Prof. Conduct 5.5(a). The Board asserts Dansdill violated the Admission to Practice Rule 3 in three ways: she did not file her motion for pro hac vice admission within 45 days after filing the complaint, as required by Admission to Practice Rule 3(A)(2); she did not file her pro hac vice paperwork with the Board of Law Examiners at the same time she filed them with the district court, as required by Admission to Practice Rule 3(A)(1)(a)(3); and she did not pay the required fee for the 2022, 2023, and 2024 calendar years, as required by Admission to Practice Rule 3(A)(1)(a)(4).
[¶13] This Court has jurisdiction to discipline Dansdill under N.D.R. Prof. Conduct 8.5(b) (“Persons not licensed to practice law in this jurisdiction, but eligible to practice elsewhere who actually engage in this jurisdiction in the practice of law, are subject to the disciplinary authority of this jurisdiction.”) and N.D.R. Lawyer Discipl. 1.1(C) (providing “any lawyer specially admitted by a court of this state for a particular proceeding, and any lawyer not admitted in this state who practices law or renders legal services in this state is subject to the disability and disciplinary jurisdiction of the court under these rules”). See also N.D.R. Prof. Conduct 8.5, Comment [2] (nonresident lawyers authorized to practice under N.D.R. Prof. Conduct 5.5(b) “are not, by virtue of that limited admission, licensed to practice law in this jurisdiction, but are nonetheless subject to discipline here”).
[¶14] “We review the substantive evidence and merits of an informal disciplinary disposition de novo on the record. A violation of the rules of professional conduct must be established by clear and convincing evidence.” Kuntz v. Disciplinary Bd. of Sup. Ct. of N.D., 2015 ND 220, ¶ 10, 869 N.W.2d 117 (cleaned up). “[U]nder the clear and convincing standard, the evidence must be such that the trier of fact is reasonably satisfied with the facts the evidence tends to prove as to be led to a firm belief or conviction.” In re Disciplinary Action Against McGuire, 2004 ND 171, ¶ 8, 685 N.W.2d 748 (quoting Zundel v. Zundel, 278 N.W.2d 123, 130 (N.D. 1979)). “Interpretation of the Rules of Professional Conduct, like the interpretation of statutes, is a question of law for the Court to decide.” In re Disciplinary Action Against Feland, 2012 ND 174, ¶ 20, 820 N.W.2d 672.
III
[¶15] Rule 3.1(D)(8), N.D.R. Lawyer Discipl., provides, “Counsel shall promptly notify the complainant and lawyer in writing of the disposition of the complaint and the reasons for the inquiry committee's decision.” The Inquiry Committee's notice of disposition did not identify the facts it relied on in finding Dansdill violated N.D.R. Prof. Conduct 5.5 or explain the reasons for its decision. Although most of the facts in this case are undisputed, the Committee should have identified the facts it relied on in finding Dansdill violated N.D.R. Prof. Conduct 5.5. It also should have explained the reasons for its decision, including identifying which subsections of Rule 5.5 it found Dansdill violated. The Committee's conclusory statement it found “that clear and convincing evidence was present that Attorney Lindsay Dansdill violated Rule 5.5 of the North Dakota Rules of Professional Conduct by appearing in North Dakota Courts without being properly licensed” does not comply with Rule 3.1(D)(8). Depending on the facts, the lack of notice of a committee's reasons for its decision may impact due process. See In re Gerber, 2015 ND 217, ¶ 18, 868 N.W.2d 861 (“An attorney subject to disciplinary proceedings is entitled to procedural due process, including fair notice of the nature of the charges and an opportunity to be heard.”); see also Matter of Bolinske, 2018 ND 72, ¶¶ 10-11, 908 N.W.2d 462 (attorney's right to due process was not violated, despite not being permitted to attend the disciplinary board meeting, when he appeared at the inquiry committee meeting, provided committee members documents, and the committee “issued a written notice of disposition to Bolinske explaining its decision to issue an admonition”).
[¶16] Dansdill did not argue the Inquiry Committee's notice of disposition violated her due process rights. Moreover, the record demonstrates Dansdill had fair notice of the charges against her and sufficient opportunity to be heard. See Gerber, 2015 ND 217, ¶¶ 19-23, 868 N.W.2d 861 (rejecting the argument the inquiry committee and Disciplinary Board violated attorney's due process rights by failing to explain the reasons for concluding he had violated N.D.R. Prof. Conduct 5.5 when the record showed the attorney had notice of the charge and sufficient opportunity to be heard, including appearing at the inquiry committee's meeting, submitting a letter to the committee addressing the charge, submitting a letter to the Disciplinary Board, and being granted the opportunity to appeal). Disciplinary Counsel's investigative report identified the factual basis for probable cause Dansdill engaged in the unauthorized practice of law in North Dakota. Disciplinary Counsel's investigative report addressed N.D.R. Prof. Conduct 5.5(a), (b), (c), and (d). It also addressed the requirements of N.D. Admission to Practice Rule 3. Dansdill responded to the allegations in writing, submitted exhibits, appeared at the Committee meeting with counsel, and briefed the issues on appeal. For these reasons, this Court reviews the Disciplinary Board's approval of the Committee's decision to issue an admonition to Dansdill despite the Committee's failure to comply with N.D.R. Lawyer Discipl. 3.1(D)(8).
IV
[¶17] Rule 5.5, N.D.R. Prof. Conduct, addresses the unauthorized practice of law. Rule 5.5(a) provides, “A lawyer shall not practice law in a jurisdiction where doing so violates the regulation of the legal profession in that jurisdiction.” Rule 5.5(b) “identifies five situations in which the out-of-state lawyer may perform services in this state without fear of violating this Rule.” N.D.R. Prof. Conduct 5.5, Comment [2]. Thus, Rule 5.5(b) creates “five specific ‘safe harbors’ for multijurisdictional practice[.]” Id.
[¶18] Interpretation of the rules of Professional Conduct and other court rules are questions of law. State v. Kopperud, 2015 ND 124, ¶ 4, 863 N.W.2d 852; Feland, 2012 ND 174, ¶ 20, 820 N.W.2d 672. “The primary objective in interpreting a rule or statute is to determine and give effect to the intent of the drafters by first looking at the language of the rule or statute.” Feland, ¶ 21. When interpreting a rule, we give words their plain, ordinary, and commonly understood meaning. Id. “If the language of a rule or statute is clear and unambiguous, the letter of the rule or statute may not be disregarded under the pretext of pursuing its spirit.” Id.; see also N.D.C.C. § 1-02-05. “Accordingly, the drafters must be presumed to have meant what they have plainly expressed, and it is presumed they intended all that they said, and they said all that they intended to say.” Feland, ¶ 21.
A
[¶19] The Disciplinary Board argues Dansdill engaged in the unauthorized practice of law during the period between the filing of the complaint in Cass County District Court on March 28, 2022, and the district court's October 11, 2022 order authorizing her to appear pro hac vice. The Board argues Dansdill's motion was not filed within the 45-day deadline in Admission to Practice Rule 3(A)(2). “Section A(2) of this rule requires a motion for permission to appear to be filed within 45 days of service of a pleading, motion, or other paper.” Admission to Practice R. 3, Explanatory Note.
[¶20] Dansdill provides four responses to the Disciplinary Board's position. First, she asserts that “the Board and Committee are not empowered to discipline attorneys for violation of an Admission to Practice Rule.” Second, she argues “the ethical rule on pro hac vice admissions, Rule 5.5(b)(3), N.D.R. Prof. Conduct, permits an attorney to appear even before she obtains pro hac admission if she ‘reasonably expects to be so authorized,’ and this ethical rule does not contain the 45-day timing requirement found in the Admission to Practice Rules.” Next, Dansdill contends she “did not ‘appear’ in the matter merely because her North Dakota co-counsel put her name on the pleading, where she did not sign it.” Finally, Dansdill argues “this was not the basis for discipline identified by the Committee and affirmed by the Board; Respondent should not be permitted to invent a post hoc rationale for discipline.”
1
[¶21] Under the plain language of N.D.R. Prof. Conduct 5.5(a), “A lawyer shall not practice law in a jurisdiction where doing so violates the regulation of the legal profession in that jurisdiction.” The term “regulation” means “an authoritative rule dealing with details of procedure,” Merriam-Webster's Dictionary 1049 (11th ed. 2005), or “to control by rule,” Black's Law Dictionary 1540 (12th ed. 2024). See also American Heritage Dictionary 1481 (5th ed. 2018) (defining “regulation” as “A principle, rule, or law designed to control or govern conduct.”); New Oxford American Dictionary 1471 (3d ed. 2010) (defining “regulation” as “a rule or directive made and maintained by an authority”). Thus, the “regulation of the legal profession” includes rules controlling the legal profession. In North Dakota, the rules controlling the legal profession include the North Dakota Admission to Practice Rules.
[¶22] Dansdill's assertion she cannot be disciplined for violating a nondisciplinary rule ignores the plain language of N.D.R. Prof. Conduct 5.5(a). Rule 5.5(a) incorporates rules regulating the legal profession in the jurisdiction, making it an ethical violation to practice in violation of a jurisdiction's rules regulating the practice of law. Admission to Practice Rule 3 regulates the practice of law in North Dakota. Thus, a violation of Rule 3 may be an ethical violation. This conclusion is supported by Comment [1] to Rule 5.5, which reads: “The practice of law in violation of lawyer-licensing standards of another jurisdiction constitutes a violation of these Rules.”
2
[¶23] Relevant to Dansdill's second argument, N.D.R. Prof. Conduct 5.5(b)(3) applies in two alternative circumstances involving matters where pro hac vice admission is available—when “the lawyer is authorized to represent a client or is preparing for a matter in which the lawyer reasonably expects to be so authorized[.]” (Emphasis added.) The word “or” is disjunctive, indicating an alternative between different things and actions. State v. Martin, 2011 ND 6, ¶ 7, 793 N.W.2d 188. “The word ‘or’ expresses an alternative in its ordinary use and generally corresponds to the word ‘either.’ ” Id. Phrases separated by “or” have separate and independent significance. Id.; see also D.A.H. v. D.A.D., 2025 ND 208, ¶ 5, 29 N.W.3d 590 (explaining the word “or” is disjunctive indicating an alternative between different things or actions and phrases separated by “or” have separate and independent significance).
[¶24] The second safe harbor alternative in N.D.R. Prof. Conduct 5.5(b)(3) is limited to when the lawyer “is preparing” for the matter in which the lawyer anticipates pro hac vice admission. As stated in Comment [5]:
This Rule provides a temporary safe harbor to a lawyer acting on a client's behalf in preparatory matters before pro hac vice admission, so long as the lawyer reasonably expects to be so admitted. Such preparatory work might include factual investigations and discovery in connection with litigation or an administrative proceeding where the lawyer reasonably expects to be admitted pro hac vice.
N.D.R. Prof. Conduct 5.5, Comment [5].
[¶25] Dansdill's argument N.D.R. Prof. Conduct 5.5(b)(3) permits an attorney “to appear” even before she obtains pro hac admission is legally incorrect. By its plain language, Rule 5.5(b)(3) only permits an attorney to prepare for the matter before pro hac vice admission.
3
[¶26] Dansdill asserts she did not “appear” in the Cass County case merely because her name was on the complaint. Rule 3(A) of the North Dakota Admission to Practice Rules provides:
Pro hac vice admission is required for all nonresident lawyers admitted and licensed to practice law in another state or the District of Columbia, but not licensed in North Dakota, and who engage in the practice of law in this state by appearing, either in person, by signing pleadings, or by being designated as counsel in actions filed in state courts, administrative agencies, or tribunals.
(Emphasis added.) See also Admission to Practice R. 3, Explanatory Note (“Under this rule, an appearance is not limited to actual physical presence in a court action. A lawyer also makes an appearance by signing or otherwise being designated as counsel on a pleading, motion, or other paper served or filed in an action venued in a North Dakota state court, administrative agency, or other tribunal.”); Carlson v. Workforce Safety & Ins., 2009 ND 87, ¶ 31, 765 N.W.2d 691 (“Admission to Practice R. 3, when read together with N.D.R. Prof. Conduct 5.5, plainly says pro hac vice admission is required for nonresident attorneys who engage in the practice of law by appearing, either in person, by signing pleadings, or by being designated as counsel in actions filed in administrative agencies.”). Thus, being designated as counsel in a matter constitutes appearing in that matter.
[¶27] It is undisputed Dansdill appeared as counsel in the Cass County matter before the district court authorized her to appear pro hac vice. Dansdill's signature block was on the complaint, which was filed more than six months before the court issued its order allowing Dansdill to appear pro hac vice. Dansdill's appearance in the Cass County case before she was authorized to appear pro hac vice does not fall under one of the safe harbors in N.D.R. Prof. Conduct 5.5(b) and is the unauthorized practice of law under Rule 5.5(a). See Blume Const., Inc. v. State ex rel. Job Serv. N.D., 2015 ND 285, ¶¶ 13, 29-30, 872 N.W.2d 312 (stating attorney licensed in Colorado “engaged in the practice of law in this state by signing the appeal request and being designated as counsel in the action before Job Service,” and that the attorney's activities were not preparatory work protected by the safe harbor provisions of N.D.R. Prof. Conduct 5.5(b)); Carlson, 2009 ND 87, ¶¶ 30-31, 765 N.W.2d 691 (rejecting the argument attorneys’ preparation and filing of a request for reconsideration, being designated as counsel for the appellant's claim, and other informal internal procedures were preparatory work).
4
[¶28] Dansdill argues the Inquiry Committee did not discipline her for violating Admission to Practice Rule 3(A)(2). Because of the Inquiry Committee's limited finding, it is unclear whether it found Dansdill violated Rule 3(A)(2). The Committee vaguely found Dansdill violated Rule 5.5 “by appearing in North Dakota Courts without being properly licensed.” The Committee's determination did not mention the complaint, and made no finding Dansdill's signature block was on the complaint. The Committee did not cite Admission to Practice Rule 3(A)(2).
[¶29] The Inquiry Committee's notice of disposition did not adequately explain the reasons for the Committee's decision. See N.D.R. Lawyer Discipl. 3.1(D)(8); see also Gerber, 2015 ND 217, ¶ 18, 868 N.W.2d 861 (“An attorney subject to disciplinary proceedings is entitled to procedural due process, including fair notice of the nature of the charges and an opportunity to be heard.”); Bolinske, 2018 ND 72, ¶¶ 10-11, 908 N.W.2d 462 (attorney's right to due process was not violated when he appeared at the inquiry committee meeting, provided committee members documents, and the committee issued a written notice of disposition explaining its decision). Because we review the substantive evidence de novo, the material facts are undisputed, and Dansdill had notice of this issue, we deem a remand is unnecessary. See In re Disciplinary Action Against McKechnie, 2003 ND 37, ¶ 12, 657 N.W.2d 287 (declining to address the issue “in the first instance” and remanding “to the hearing panel for consideration upon affording [the lawyer] proper notice and a fair opportunity to meet any charge leveled at him”).
[¶30] Based on our de novo review of the record, we conclude there is clear and convincing evidence Dansdill violated N.D.R. Prof. Conduct 5.5(a) by violating Admission to Practice Rule 3(A)(2), which regulates the legal profession in North Dakota. Dansdill violated Admission to Practice Rule 3(A)(2) in that she did not file her motion for pro hac vice admission within 45 days of appearing as counsel in the Cass County case. See Blume Const., 2015 ND 285, ¶ 30, 872 N.W.2d 312 (stating attorney licensed in Colorado, who signed a notice of appeal in the capacity of the company's attorney, “was required to move for pro hac vice admission under Admission to Practice R. 3(A)(2) within 45 days of filing the appeal request”); Carlson, 2009 ND 87, ¶ 34, 765 N.W.2d 691 (stating “nonresident attorneys were required to file a motion for pro hac vice admission under Admission to Practice R. 3(A) within 45 days of their appearance in this agency proceeding.”).
[¶31] Dansdill's noncompliance with Rule 3(A)(2) constitutes the unauthorized practice of law under N.D.R. Prof. Conduct 5.5(a).
B
[¶32] The Disciplinary Board asserts Dansdill also violated N.D.R. Prof. Conduct 5.5 by not filing her pro hac vice paperwork with the Board of Law Examiners at the same time she filed them with the district court, as required by Admission to Practice Rule 3(A)(1)(a)(3); and by not paying the required fee for the 2022, 2023, and 2024 calendar years, as required by Admission to Practice Rule 3(A)(1)(a)(4). We decline to address these arguments because, even if they are violations of Rule 5.5, the sanction would not be affected. In re Disciplinary Action Against Corwin, 2014 ND 50, ¶ 26, 843 N.W.2d 830.
V
[¶33] The Disciplinary Board established by clear and convincing evidence that Dansdill engaged in the unauthorized practice of law in violation of N.D.R. Prof. Conduct 5.5(a) by appearing as counsel in the Cass County matter and not filing her motion for pro hac vice admission within 45 days of appearing as counsel. We affirm the Disciplinary Board's approval of the Inquiry Committee West's admonition of Dansdill for violating N.D.R. Prof. Conduct 5.5(a).
Per Curiam.
[¶34] Lisa Fair McEvers, C.J. Jerod E. Tufte Jon J. Jensen Douglas A. Bahr Mark A. Friese
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Docket No: No. 20250461
Decided: June 04, 2026
Court: Supreme Court of North Dakota.
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