Matter of Holtzman

While serving as a county district attorney, Holtzman (defendant) publicly released a letter accusing a criminal court judge of misconduct for requiring an alleged sexual assault victim to physically demonstrate the assault position in camera, despite her own staffers warning her against doing so; her accusations rested solely on a newly hired trial assistant's memorandum, without Holtzman ever directly speaking to the assistant or anyone who witnessed the alleged impropriety, and she knew when releasing the letter that the judge had already been transferred out of criminal court and that appropriate authorities would investigate. Disciplinary proceedings found Holtzman violated professional conduct rules by making false accusations, the state court of appeals upheld that finding, and Holtzman sought further review.