In the Matter of Suspension of OBA Members — Oklahoma Supreme Court suspends 23 attorneys for failure to complete 2025 mandatory CLE requirements

Case
In the Matter of the Suspension of Members of the Oklahoma Bar Association for Noncompliance with Mandatory Continuing Legal Education Requirements for the Year 2025
Court
Supreme Court of the State of Oklahoma
Date Decided
June 2, 2026
Docket No.
2026 OK 42 (SCBD)
Topics
Attorney Discipline, Mandatory CLE, Bar Membership Suspension, Oklahoma Bar Association

Background

On May 26, 2026, the Board of Governors of the Oklahoma Bar Association filed an application seeking the suspension of OBA members who failed to satisfy mandatory continuing legal education requirements for the year 2025 under Rules 3 and 5 of the Rules for Mandatory Continuing Legal Education (MCLE Rules), 5 O.S. 2011, ch. 1, app. 1-B. The MCLE Rules require Oklahoma attorneys to complete specified continuing legal education hours each year as a condition of maintaining bar membership and the privilege to practice law in the state.

Prior to the suspension application, on March 16, 2026, the Executive Director of the OBA mailed — by certified mail — an Order to Show Cause to each noncompliant member, affording them sixty days to demonstrate good cause why their membership should not be suspended. The Board of Governors determined that the attorneys identified in Exhibit A to its application failed to show good cause in response to that notice.

Twenty-three attorneys were named in Exhibit A, with addresses spanning Oklahoma, Texas, Colorado, Wisconsin, and Louisiana, reflecting that OBA membership obligations extend to Oklahoma-licensed attorneys regardless of their current state of residence.

The Court’s Holding

The Oklahoma Supreme Court granted the Board of Governors’ application and ordered the suspension of all twenty-three named attorneys from OBA membership effective June 1, 2026. The suspended attorneys are prohibited from practicing law in the State of Oklahoma until they are formally reinstated in accordance with applicable rules.

The Court found that each named attorney had received constitutionally adequate notice through the certified-mail show-cause process, had been given sixty days to respond, and had nonetheless failed to demonstrate good cause for noncompliance with the 2025 MCLE requirements. Having considered the application and underlying record, the Court found suspension warranted under Rule 6 of the MCLE Rules.

Key Takeaways

  • Twenty-three Oklahoma Bar Association members were suspended from practice for failing to comply with 2025 mandatory CLE requirements under MCLE Rules 3 and 5.
  • The OBA provided pre-suspension notice via certified mail and a 60-day show-cause period; attorneys who did not respond adequately were suspended under Rule 6.
  • Suspension prohibits the practice of law in Oklahoma until reinstatement is obtained — the order applies regardless of the attorney’s current state of residence.
  • The opinion is designated for publication in the Oklahoma Bar Journal only and is not for official publication in the Pacific Reporter.

Why It Matters

This administrative order is a routine but consequential exercise of the Oklahoma Supreme Court’s supervisory authority over the state bar. It underscores that MCLE compliance is a non-negotiable condition of bar membership and that the OBA’s enforcement mechanism — certified-mail notice, an opportunity to show cause, and Board of Governors review — satisfies due process before suspension is imposed.

For practitioners, the order serves as a reminder that Oklahoma-licensed attorneys living or working outside the state remain subject to OBA obligations. Failure to track and fulfill annual CLE requirements can result in summary suspension, which interrupts the ability to appear in Oklahoma courts and carry an active Oklahoma bar license until formal reinstatement steps are completed.

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