- Court
- New York Supreme Court, Appellate Division, First Department
- Case
- Matter of Murray-Nolan
- Date
- May 28, 2026
- Slip Op. No.
- 2026 NY Slip Op 03365
Background
Respondent Gwyneth Kathleen Murray-Nolan was admitted to practice in New York in 2010. A New Jersey District XII Ethics Committee filed an ethics complaint charging her with violating New Jersey Rules of Professional Conduct rules 1.7(a) and 1.8 by representing clients while having a conflict of interest and entering into improper business transactions with clients. The Attorney Grievance Committee for the First Judicial Department sought reciprocal discipline based on the New Jersey proceedings. Murray-Nolan was heard in response through counsel.
Holding
The Appellate Division imposed reciprocal discipline on Murray-Nolan based on the New Jersey disciplinary proceedings. The Court applied the framework for reciprocal discipline under Rules for Attorney Disciplinary Matters section 1240.13, finding that the misconduct established in New Jersey—representing clients with conflicting interests and entering into prohibited business transactions—constitutes professional misconduct under New York’s Rules of Professional Conduct as well. The corresponding New York provisions (Rules 1.7 and 1.8) impose substantially similar restrictions on conflicts of interest and client business transactions. Murray-Nolan failed to establish any of the three available defenses to reciprocal discipline: lack of due process, infirmity of proof, or the absence of corresponding misconduct in New York.
Takeaways
Conflict of interest violations and prohibited business transactions with clients are recognized as professional misconduct in both New York and New Jersey, making reciprocal discipline virtually automatic when such violations are established in the originating jurisdiction. The conflict of interest rules under both states’ professional conduct frameworks are substantially similar, and an attorney found to have violated these rules in one jurisdiction should expect equivalent discipline in New York. Attorneys engaged in multi-state practice must comply with the conflict of interest rules of every jurisdiction in which they are admitted.
Why It Matters
This case reinforces the principle that conflict of interest violations are treated seriously across jurisdictions and will result in reciprocal discipline in New York. Attorneys who represent clients while laboring under conflicts of interest, or who enter into business transactions with clients without proper safeguards, face disciplinary consequences in every jurisdiction of admission. The decision serves as a reminder that compliance with conflict of interest rules is not jurisdiction-specific; a violation anywhere is a violation everywhere for multi-jurisdictional practitioners.