Background
The Board of Governors of the Oklahoma Bar Association filed an application with the Oklahoma Supreme Court seeking an order striking nine attorneys from the OBA’s membership rolls and the Roll of Attorneys for failure to comply with the Rules for Mandatory Continuing Legal Education (MCLE), 5 O.S. 2011, ch. 1, app. 1-B, for the year 2024.
The affected attorneys had previously been suspended from OBA membership and from the practice of law in Oklahoma by a court order dated June 2, 2025, pursuant to Rule 6(d) of the MCLE Rules, after failing to comply with Rules 3 and 5 governing mandatory continuing legal education for 2024. At its May 15, 2026, meeting, the Board of Governors confirmed that none of the suspended attorneys had applied for reinstatement within the one-year window following the suspension order.
Having failed to seek reinstatement within one year, the Board declared that the nine members had ceased to be members of the OBA as of June 2, 2026, and requested that their names be formally stricken from the membership rolls and the Roll of Attorneys.
The Court’s Holding
The Oklahoma Supreme Court, with all justices concurring, found that the Board of Governors acted in compliance with the MCLE Rules and entered an order formally striking the nine attorneys from the Roll of Attorneys effective June 2, 2026. The Court’s order was entered in conference on June 8, 2026.
The nine attorneys stricken are: Robert Wayne Adcox (OBA #20603), Tyler Robert Christians (OBA #30847), Scott Francis Doering (OBA #13499), Leslie A. Ellis Kissinger (OBA #11295), Robert Murl Messerli (OBA #22465), Ashley Marie Nichols (OBA #35306), Kenneth Daryl Perry (OBA #7055), Sarah Grace Trainer (OBA #32964), and Haley Alexis Vargas (OBA #35388). The order is designated for publication in the Oklahoma Bar Journal only and is not for official publication.
Key Takeaways
- Attorneys suspended for MCLE noncompliance have one year to apply for reinstatement; failure to do so results in permanent removal from the Roll of Attorneys.
- The Oklahoma Supreme Court reviews and approves the Board of Governors’ MCLE enforcement actions as a final step in the striking process.
- Nine Oklahoma-licensed attorneys lost their bar membership effective June 2, 2026, for failing to meet 2024 MCLE requirements and not seeking reinstatement.
- Several stricken attorneys listed out-of-state addresses (Texas, Virginia, Kansas), suggesting they may have relocated but retained Oklahoma bar membership.
Why It Matters
This administrative order illustrates the Oklahoma Supreme Court’s enforcement mechanism for mandatory continuing legal education compliance. The two-step process — initial suspension followed by a one-year reinstatement window — gives attorneys an opportunity to cure their noncompliance before permanent removal, but the finality of a striking order means affected attorneys must go through formal reinstatement proceedings to practice law in Oklahoma again.
For practitioners, the order serves as a reminder that MCLE obligations persist regardless of where an attorney physically resides. Several of the stricken attorneys held Oklahoma bar membership while living in other states, underscoring that out-of-state relocation does not suspend CLE obligations or OBA membership duties.