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IN RE: DISCIPLINE OF Matthew E. AARON, Bar No. 4900.
ORDER APPROVING CONDITIONAL ADMISSION AGREEMENT
This is an automatic review of a Southern Nevada Disciplinary Board hearing panel's recommendation that this court approve, pursuant to SCR 113, a conditional admission agreement in exchange for a stated form of discipline for attorney Matthew Aaron. Under the agreement, Aaron admitted to violating RPC 1.15(a), (b), and (d) (safekeeping property) and SCR 78(1)(b) (maintenance of trust funds in approved financial institutions; overdraft notification). Aaron agreed to a two-year suspension, stayed for one year subject to certain conditions.
Aaron admitted to mismanaging an IOLTA trust account by commingling and misappropriating client funds, failing to properly maintain IOLTA trust account records, failing to timely deposit client funds, failing to timely disburse funds to multiple clients, and overdrawing the account. Aaron also admitted to depositing his own funds into the IOLTA trust account to cover potential problems with insufficient funds.
The issue for this court is whether the agreed-upon discipline sufficiently protects the public, the courts, and the legal profession. See In re Discipline of Arabia, 137 Nev. 568, 571, 495 P.3d 1103, 1109 (2021) (stating the purpose of attorney discipline). In determining the appropriate discipline, we weigh four factors: “the duty violated, the lawyer's mental state, the potential or actual injury caused by the lawyer's misconduct, and the existence of aggravating or mitigating factors.” In re Discipline of Lerner, 124 Nev. 1232, 1246, 197 P.3d 1067, 1077 (2008); see also SCR 102.5(1).
Aaron admitted to knowingly violating duties owed to clients (safekeeping property) and to the profession (maintenance of trust funds in approved financial institutions). Aaron further admitted the conduct caused actual or potential injury to clients and third parties, such as lienholders, as well as injury to the integrity of the legal profession. The baseline sanction for such violations, before considering the aggravating or mitigating circumstances, is suspension. See Standards for Imposing Lawyer Sanctions, Compendium of Professional Responsibility Rules and Standards, Standard 4.12 (Am. Bar Ass'n 2023) (providing that suspension is appropriate “when a lawyer knows or should know that he is dealing improperly with client property and causes injury or potential injury to a client”); Standard 7.2 (providing that suspension is appropriate “when a lawyer knowingly engages in conduct that is a violation of a duty owed as a professional and causes injury or potential injury to a client, the public, or the legal system”). The record supports three aggravating circumstances (pattern of misconduct, multiple offenses, and substantial experience in the practice of law) and three mitigating circumstances (absence of prior disciplinary record, personal or emotional problems, and interim rehabilitation). Considering all four factors, we conclude that the agreed-upon discipline is appropriate.
Accordingly, we hereby suspend attorney Matthew Aaron from the practice of law in Nevada for two years, with the suspension stayed for one year from the date of this order, subject to the conditions outlined in the conditional admission agreement. Those conditions include requirements that Aaron shall not engage in solo practice for the term of the one-year stay; not establish, manage, operate, control, or otherwise personally handle a trust account for the term of the one-year stay; complete six additional continuing education credits in the areas of substance abuse and lOLTA/trust accounting; undergo appropriate treatment through the Nevada Lawyer Assistance Program (NLAP) as deemed appropriate and allow NLAP to provide monitoring reports to the State Bar; and engage in no conduct involving client funds for which a reprimand is issued or a complaint is filed. Aaron shall also pay the cost of the disciplinary proceedings, including $2,500 under SCR 120, within 30 days from the date of this order. The State Bar shall comply with SCR 121.1.
It is so ORDERED.
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Docket No: No. 91737
Decided: February 12, 2026
Court: Supreme Court of Nevada.
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FindLaw’s Learn About the Law features thousands of informational articles to help you understand your options. And if you’re ready to hire an attorney, find one in your area who can help.
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