IN RE: DISCIPLINE OF BRYAN J. BLEHM (2025)

ORDER IMPOSING RECIPROCAL DISCIPLINE

This is a petition under SCR 114 for reciprocal discipline of attorney Bryan J. Blehm based on his discipline in Arizona. Blehm self-reported the Arizona discipline as required by SCR 114(1) but has not responded to the petition. See SCR 114(3).

Blehm was suspended in Arizona for 60 days beginning on July 7, 2024, followed by a one-year probation. Blehm represented defeated Arizona gubernatorial candidate, Kari Lake, in a petition for review of adverse election rulings. Blehm made false assertions to Arizona's appellate courts concerning alleged voting fraud activities at the Runbeck vote processing facility. Blehm frivolously argued that it was an “undisputed fact” that 35,563 unaccounted for ballots were added to the total number of ballots at a third-party processing facility. Blehm again misrepresented that “the record indisputably reflects” at least 35,563 election day early ballots were added at Runbeck. Based on these facts, the Arizona hearing panel found Blehm violated Arizona rules of professional conduct equivalent to Nevada's RPC 3.1 (meritorious claims); RPC 3.5(d) (tribunal decorum); RPC 8.2(a) (judicial and legal officials); and RPC 8.4(d) (misconduct). The Arizona panel found five aggravating factors (dishonest or selfish motive, multiple offenses, bad faith obstruction of the disciplinary proceeding by intentionally failing to comply with rules or orders of the disciplinary agency, refusal to acknowledge wrongful nature of conduct, and substantial experience in the practice of law) and two mitigating factors (absence of a prior disciplinary record and imposition of other penalties or sanctions). The Arizona panel further found that Blehm acted knowingly and caused injury to his client, the public, and the legal system,

SCR 114(4) provides that this court shall impose identical reciprocal discipline unless the attorney demonstrates or this court finds that at least one of four exceptions is present: (1) the procedure in the other jurisdiction denied the attorney due process; (2) there is such an infirmity of proof of the misconduct in the other jurisdiction that this court cannot accept the other court's decision; (3) substantially different discipline is warranted in this state; or (4) the established misconduct does not constitute misconduct under the rules of this state. None of the exceptions apply, so we grant the petition for reciprocal discipline. Accordingly, we hereby suspend Blehm for 60 days commencing from the date of this order. Upon completion of the suspension, Blehm shall be placed on probation for one year subject to the terms set forth in the Arizona discipline order. The State Bar shall comply with SCR 121.1.

It is so ORDERED.

Herndon, C.J.

Bell, J.

Stiglich, J.