IN RE: DISCIPLINE OF LEANNE M. RODGERS (2026)

ORDER APPROVING CONDITIONAL ADMISSION AGREEMENT

This is an automatic review of a Southern Nevada Disciplinar 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 Leanne Rodgers. Under the agreement, Rodgers admitted to violating RPC 1.15 (safekeeping property) and RPC 8.4(d) (misconduct). Rodgers agreed to a one-year suspension, stayed for two years subject to certain conditions.

Rodgers admitted to commingling client and third-party funds in Rodgers’ client trust account. Rodgers also admitted to maintaining proceeds from personally owned entities in her client trust account. This conduct exposed Rodgers’ clients to potential injury because the funds in the client trust account were potentially subject to seizure, as the Federal Trade Commission had previously secured a judgment against Rodgers as a relief defendant.

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).

The most serious instance of misconduct is the violation of RPC 1.15 (safekeeping property). See Standards for Imposing Lawyer Sanctions, Compendium of Professional Responsibility Rules and Standards, 454 (Am. Bar Ass'n 2023) (explaining that when there are multiple charges of misconduct, “[t]he ultimate sanction imposed should at least be consistent with the sanction for the most serious instance of misconduct”). Rodgers admitted she should have known she was violating a duty owed to clients to safekeep their property. The baseline sanction for that misconduct, 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”). The record supports one aggravating circumstance (substantial experience in the practice of law) and two mitigating circumstances (full and free disclosure to the disciplinary authority and cooperative attitude toward the disciplinary process; lack of prior discipline). Considering all four factors, we conclude that the agreed-upon discipline is appropriate.

Accordingly, we hereby suspend attorney Leanne Rodgers from the practice of law in Nevada for one year, with the suspension stayed for two years from the date of this order, subject to the conditions outlined in the panel's findings of fact, conclusions of law, and recommendation. Those conditions include requirements that Rodgers complete six additional continuing education credits in the areas of ethics and/or law office management; refrain from holding any client funds in her client trust account other than for retained clients that are not an entity in which Rodgers or an immediate family member is an owner or decision-maker; provide monthly reconciliation reports to the Office of Bar Counsel; and engage in no conduct involving client funds for which a letter of reprimand is issued or a complaint is filed. Rodgers 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.

Bell, J.

Stiglich, J.

Cadish, J.