Background
In February 2023, the Kansas Supreme Court ordered attorney Mark Allen Galloway to serve three years of supervised probation as a disciplinary sanction. In re Galloway, 317 Kan. 87, 524 P.3d 416 (2023). The probation was imposed subject to terms and conditions overseen by a supervising attorney and monitored by the Office of the Disciplinary Administrator.
On June 3, 2026, Galloway moved for early discharge from probation, submitting his own affidavit and one from his supervising attorney attesting to his compliance with all probation terms and conditions. The Office of the Disciplinary Administrator reviewed the submission and confirmed Galloway had satisfied his obligations and was eligible for discharge under Supreme Court Rule 227(g).
The Court’s Holding
The Kansas Supreme Court granted Galloway’s motion and fully discharged him from probation effective July 8, 2026. The court assessed any remaining costs of the proceeding to Galloway and ordered the disciplinary proceeding closed.
The court also directed the Reporter of Decisions to publish the discharge order in the Kansas Reports, making the resolution part of the official record of the disciplinary matter.
Key Takeaways
- Galloway successfully completed his supervised probation and was discharged prior to the original three-year term’s expiration in February 2026, with the motion filed June 3, 2026 — reflecting the court’s acceptance of his compliance record.
- Both Galloway’s supervising attorney and the Office of the Disciplinary Administrator confirmed full compliance with probation terms, which was dispositive in the court’s decision to grant discharge.
- The discharge was governed by Kansas Supreme Court Rule 227(g), which sets out the procedural requirements for motions to terminate attorney disciplinary probation.
Why It Matters
This order illustrates the rehabilitative pathway available to Kansas attorneys subject to disciplinary probation. When an attorney demonstrates sustained compliance with court-imposed conditions — verified by both a supervising attorney and the Disciplinary Administrator — the court will grant discharge and close the proceeding, allowing the attorney to move forward without the continued burden of formal supervision.
For practitioners, the case underscores the importance of meticulous compliance with probation conditions and the procedural mechanism under Rule 227(g) for seeking early or timely discharge once those conditions are met.