Disbarment for Retaliating Against Clients for Bad On-Line Reviews

AVVOOn December 1, 2015, the Indiana Supreme Court disbarred a lawyer for, among other egregious conduct, retaliating against clients for unfavorable Avvo reviews. See In the Matter of David J. Steele, No. 49S00-1509-DI-527 (Ind. Dec. 1, 2015). Avvo.com is one of the leading on-line professional directories and social-media sites for lawyers. The respondent “manipulated” Avvo reviews relating to his legal services and his law firm by “monetarily incentivizing positive reviews.” Even worse, he made false statements and revealed confidential information about clients who published bad reviews. He did so not only to “punish” them for unfavorable reviews, but also to “inflate” his own Avvo rankings. This conduct, held the court, violated Rule 1.6 (duty of confidentiality to existing clients), Rule 1.9(c) (duty of confidentiality to former clients), and Rule 7.1 (duty to refrain from making false or misleading communications about the lawyer or the lawyer’s services).


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