Background
Charles Frederick Rogers, Jr. was admitted to the Kentucky Bar in October 2015 and maintained a Bar Roster address in Cincinnati, Ohio. During the 2024-2025 educational year, Rogers failed to complete the minimum continuing legal education (CLE) credit hours required under Kentucky Supreme Court Rule 3.645(1). The Kentucky Bar Association (KBA) and its CLE Commission made repeated attempts to notify Rogers of his delinquency—sending multiple written notices by mail and email to his official Bar Roster address and, after Rogers updated his contact information in November 2025, calling his updated phone number on two occasions.
On November 21, 2025, the CLE Commission certified Rogers’ name to the KBA Board of Governors as having failed to satisfy the CLE requirements. The Board issued a Show Cause Notice of Delinquency requiring Rogers to respond or certify compliance within thirty days to avoid suspension. That same afternoon, Rogers updated his Bar Roster contact information, but the KBA mailed the notice to his prior address the following business day; it was returned as undeliverable. The KBA subsequently resent the notice to Rogers’ updated address, and Rogers accepted and signed for it on January 16, 2026—the same day the KBA suspended his license.
Rogers appealed his suspension to the Kentucky Supreme Court on February 6, 2026, attesting that he had believed himself to be in compliance, that he was unable to access the KBA website to verify his status, and that upon learning of his suspension on January 16, 2026, he promptly completed and reported six CLE credit hours. He also acknowledged that he had failed to update his Bar Roster contact information after leaving his prior employer at the end of 2024, doing so only in November 2025.
The Court’s Holding
The Kentucky Supreme Court denied Rogers’ appeal, holding that he failed to demonstrate good cause sufficient to warrant revocation of his suspension. The Court found no procedural errors in the KBA’s suspension process: the CLE Commission properly certified Rogers’ delinquency, the Board issued the Notice of Delinquency to his official Bar Roster address at the time, and the KBA made numerous additional attempts to reach him. Citing Hofmann v. Kentucky Bar Association, 647 S.W.3d 268, 271 (Ky. 2022), the Court reiterated that an attorney’s failure to keep his Bar Roster address current is not a viable excuse for ignoring notices.
The Court also emphasized that Rogers failed to cure his delinquency before or during the suspension appeal. The six CLE credit hours he reported after his suspension were not earned during the 2024-2025 educational year and, even if they had been, would still have left him short of the twelve credit hours required for that year under SCR 3.645(1). Accordingly, Rogers was ordered to remain suspended and to pursue reinstatement through the formal restoration process under SCR 3.504, which requires completion of at least twenty-four CLE credit hours covering both the 2024-2025 and 2025-2026 educational years, payment of all unpaid KBA dues, and the absence of pending disciplinary matters.
Key Takeaways
- Attorneys bear personal responsibility for keeping their official Bar Roster contact information current; an outdated address is not a defense against CLE-delinquency notices sent to that address.
- An appeal of a CLE-based suspension requires a showing of good cause; post-suspension completion of credit hours, especially when still insufficient to satisfy the deficient year’s requirement, does not meet that standard.
- An attorney who cannot demonstrate good cause on appeal must pursue formal restoration under SCR 3.504, which carries its own requirements independent of the appeal process.
Why It Matters
This decision reinforces the Kentucky Supreme Court’s strict approach to CLE compliance and attorney contact-information obligations. The ruling makes clear that the combination of multiple missed notices and failure to remedy a delinquency before suspension leaves little room for appellate relief—even where an attorney claims inadvertent noncompliance.
For Kentucky practitioners, the case serves as a practical reminder that SCR 3.035 imposes an affirmative duty to maintain accurate Bar Roster information, and that the KBA’s administrative process provides multiple off-ramps—extensions under SCR 3.670 and exemptions under SCR 3.665—that must be invoked proactively. Attorneys who miss those opportunities face the more burdensome restoration pathway rather than a simple reinstatement on appeal.