Background
Nathalie Perez has been enrolled as a registered Spanish-language courtroom interpreter in Oklahoma since November 23, 2015. Under the Rules of the State Board of Examiners of Certified Courtroom Interpreters, interpreters must complete eight hours of continuing education per calendar year and submit an annual renewal form. A medical exemption is available only when a licensed physician verifies that a medical condition prevented the interpreter from working and completing continuing education for the entire calendar year.
In January 2025, Perez submitted her renewal form checking the box declaring she was “medically unable to work or attend continuing education during the entire year” of 2024, signing under oath that all information provided was true and correct. She attached a doctor’s note and, after being told it was insufficient, a follow-up physician letter stating her fibromyalgia and generalized anxiety disorder “prevented her from working as an Interpreter and completing her continued education.” In fact, Perez had worked every single month of 2024, completing 132 court cases and earning $8,347.50 as a registered interpreter. After the Administrative Office of the Courts discovered the discrepancy, the Board filed a formal disciplinary complaint.
Following a hearing in August 2025, the Board unanimously found that Perez had committed misrepresentation in obtaining certification (Rule 2(b)) and fraud (Rule 2(d)), and recommended that the Oklahoma Supreme Court revoke her enrollment. The Court had already administratively suspended Perez on June 23, 2025, pending the disciplinary proceedings.
The Court’s Holding
The Oklahoma Supreme Court, reviewing the record de novo, upheld a finding of misrepresentation under Rule 2(b) based on Perez’s sworn statement that she was medically unable to work for the entire year of 2024, when the record conclusively showed she worked every month that year. The Court found this misrepresentation in obtaining her credential renewal demonstrated a lack of integrity warranting discipline, as courts, parties, and counsel depend on the integrity of courtroom interpreters to administer justice.
The Court declined, however, to find fraud under Rule 2(d). Applying the common-law fraud elements from Bowman v. Presley, 2009 OK 48, 212 P.3d 1210, the Court found that while Perez satisfied the first three elements—a false material misrepresentation, made as a positive assertion recklessly or knowingly, with intent it be acted upon—the record contained no evidence that the Board actually relied upon or was deceived by the false statement. The fourth element of fraud was therefore unproven.
The Court also declined to find misrepresentation or fraud with respect to the physician’s note and letter. Neither document stated that Perez was unable to work for the entire year; they said her conditions prevented her from working and completing continuing education. Because the record included no evidence that her health did not also limit her work capacity, the Court refused to treat those documents as independently false. Finally, the Court rejected the Board’s recommendation of revocation and instead imposed a one-year suspension beginning June 23, 2025—the date of the prior administrative suspension—with eligibility for reinstatement under RGDP-CI Rule 9(a).
Key Takeaways
- An interpreter who swears under oath to a medical work-incapacity exemption while actively working throughout the year commits disciplinable misrepresentation under Rule 2(b), even without a finding of fraud.
- Fraud under Rule 2(d) requires proof that the Board actually relied on or was deceived by the false statement; the absence of that reliance element defeated the fraud charge here despite the other elements being met.
- Physician letters that do not specifically claim total inability to work for the entire year are not independently false simply because the interpreter continued working—the Board must affirmatively prove the letters were untrue.
- The Oklahoma Supreme Court has full discretion to impose a lesser sanction than the Board recommends; here it substituted a one-year suspension for the recommended revocation, giving weight to Perez’s clean prior record.
- Interpreters facing continuing education difficulties should pursue the available hardship exception under Rule 18(h) or complete the hours with payment of the late fee—options that were expressly communicated to Perez before she submitted the false exemption claim.
Why It Matters
This decision reinforces that courtroom interpreters occupy a position of trust in the justice system, and that sworn misrepresentations to the credentialing authority—even absent technical fraud—carry serious disciplinary consequences. The opinion provides useful guidance on the precise boundary between misrepresentation and fraud in the interpreter-discipline context: a false sworn statement satisfies Rule 2(b) on its own, but Rule 2(d) fraud additionally requires proof of detrimental reliance by the Board.
The ruling also signals that the Oklahoma Supreme Court will exercise independent judgment on sanction severity, and that a first-time offender with a long clean record may avoid outright revocation where a suspension adequately addresses the integrity concern. Practitioners representing credentialed interpreters in disciplinary proceedings should note both the Court’s willingness to depart downward from Board recommendations and its careful, element-by-element fraud analysis.