Background
Dustin Garrison was admitted to the Nebraska bar on April 15, 2008, and practiced law across multiple Nebraska counties, including Gage, Hamilton, Sarpy, Douglas, Lancaster, and York. Beginning in late 2025, the Counsel for Discipline of the Nebraska Supreme Court received a series of grievances against him. In December 2025, judges in York and Hamilton Counties reported that Garrison repeatedly failed to appear in court, leaving clients without counsel. In February 2026, opposing counsel complained that Garrison had contacted a legally represented party despite receiving two cease-and-desist letters.
Further grievances followed in the spring of 2026. A former client alleged negligence, failure to appear, filing plea agreement counteroffers without client consent, and refusal to return client files. A judge filed a separate grievance in May 2026 reporting that Garrison failed to provide court-ordered discovery, failed to appear as ordered, was sanctioned for noncompliance, neglected his client’s interests, and caused all evidence filed on his client’s behalf to be deemed inadmissible due to his repeated failures to comply with court orders.
On May 22, 2026, Garrison filed a voluntary surrender of his law license pursuant to Neb. Ct. R. § 3-315. In doing so, he stated that he knowingly did not challenge or contest the truth of the allegations in the grievances, freely consented to disbarment, and waived his right to notice, appearance, or a hearing before entry of the disbarment order.
The Court’s Holding
The Nebraska Supreme Court accepted Garrison’s voluntary surrender of his license and entered a judgment of disbarment effective immediately. The court found that Garrison had complied with the procedural requirements of Neb. Ct. R. § 3-315 by acknowledging the grievances without contest and waiving all further proceedings. The court further found that disbarment was the appropriate consequence given the scope and nature of the misconduct reflected in the grievances.
The court ordered Garrison to comply with all post-disbarment obligations under Neb. Ct. R. § 3-316, including the winding down of his practice, and directed him to pay costs and expenses pursuant to Neb. Rev. Stat. §§ 7-114 and 7-115 and applicable disciplinary rules within 60 days of any cost order entered by the court. Failure to comply with § 3-316 subjects Garrison to punishment for contempt.
Key Takeaways
- Garrison voluntarily surrendered his license under Neb. Ct. R. § 3-315, which allows a member under grievance to surrender their license by acknowledging or not contesting the allegations and waiving all related proceedings.
- The misconduct reflected in the grievances included repeated failures to appear in court, contact with a represented party in violation of professional rules, filing plea counteroffers without client consent, failure to comply with discovery orders, and abandonment of client files.
- The Nebraska Supreme Court accepted the voluntary surrender and entered immediate disbarment, along with an obligation to comply with post-disbarment wind-down rules and a potential costs award.
Why It Matters
This case illustrates how Nebraska’s voluntary surrender mechanism operates as a streamlined path to disbarment when an attorney facing multiple grievances acknowledges the misconduct and waives the right to contest proceedings. For the bar and the public, the outcome underscores that systematic neglect of client obligations — including repeated failures to appear, noncompliance with court orders, and disregard for clients’ rights — will result in the most severe professional sanction available.
The decision also serves as a reminder that grievances can originate not only from clients but from judges and opposing counsel, and that a pattern of conduct across multiple counties and cases leaves little room for mitigation. Attorneys facing accumulating disciplinary complaints should understand that voluntary surrender, while it avoids a formal hearing, results in full disbarment and all attendant post-disbarment obligations.