In re Himmel
Illinois Supreme Court
533 N.E.2d 790 (1988)
After attorney John Casey stole $23,233 from a settlement he obtained for client Tammy Forsberg, Forsberg hired attorney James Himmel (defendant) to recover the money; rather than report Casey's theft to the state bar, Himmel negotiated a $75,000 settlement in which Forsberg agreed not to pursue criminal charges or bar discipline against Casey. The Illinois Attorney Registration and Disciplinary Commission's Administrator (plaintiff) brought a complaint against Himmel for failing to report Casey's misconduct; a hearing board recommended a private reprimand, but the Review Panel recommended dismissal, and the Administrator appealed.
In Illinois, may an attorney be disciplined for failing to report another attorney's illegal or immoral conduct to the state bar?