Background
Connie Reguli, a Tennessee lawyer licensed since 1994, faced nine disciplinary complaints arising from conduct between 2014 and 2018 in matters in which she was participating as counsel. The complaints described an escalating pattern that included filing contempt petitions to coerce a CASA volunteer, communicating with represented parties, filing papers for a person represented by another lawyer, making false or misleading accusations against judges and justice-system officials, and disregarding court directives.
The most serious misconduct involved Reguli’s use of social media to publish officials’ personal information, direct followers to contact them, encourage harassment, spread false accusations and conspiracy theories, and endorse posts that officials reasonably perceived as threatening. In another matter, Reguli helped client Wendy Hancock evade law enforcement during an Amber Alert by providing a burner phone and concealing Hancock and her child in Reguli’s home despite a protective-custody order. A Board of Professional Responsibility hearing panel found multiple violations of the Tennessee Rules of Professional Conduct and recommended disbarment. The circuit court held that a 2017 flyer criticizing the child-welfare system was protected speech but otherwise affirmed the findings and sanction.
The Court’s Holding
The Tennessee Supreme Court affirmed the disciplinary rule violations and ordered Reguli permanently disbarred, effective upon entry of its opinion and judgment. It rejected her procedural and constitutional challenges, including her contention that the disciplinary process entitled her to a jury trial. The court also concluded that the panel’s and circuit court’s decisions were supported by substantial and material evidence and were neither arbitrary nor capricious.
The court rejected Reguli’s argument that the First Amendment categorically protected her out-of-court statements. Although it excluded certain protected remarks from consideration and left undisturbed the circuit court’s protection of the 2017 flyer, it held that the First Amendment did not prevent professional discipline for the remaining false, recklessly made, intimidating, harassing, and prejudicial statements connected to judicial proceedings. Given the seriousness and breadth of the misconduct, Reguli’s prior discipline, multiple offenses, substantial experience, dishonest or selfish motive, refusal to acknowledge wrongdoing, deceptive conduct during the proceedings, and absence of mitigating circumstances, no sanction short of disbarment was adequate.
Key Takeaways
- A lawyer’s First Amendment rights do not categorically shield extrajudicial speech that falsely attacks judicial integrity, interferes with proceedings, or encourages harassment and intimidation of justice-system participants.
- Social-media conduct—including doxing officials, mobilizing followers to contact them, and endorsing threatening posts—can support professional discipline when connected to the lawyer’s representation in judicial proceedings.
- A sustained pattern of dishonesty, intimidation, defiance of court orders, and interference with the administration of justice can warrant permanent disbarment even when some challenged speech is constitutionally protected.
Why It Matters
The decision draws a line between protected criticism of courts and child-welfare institutions and attorney speech or conduct that undermines adjudication through falsehoods, threats, harassment, or intimidation. It confirms that lawyers retain free-speech rights but remain subject to professional obligations arising from their role in the justice system.
The ruling also demonstrates that disciplinary sanctions may rest on the cumulative effect of misconduct across multiple representations. When that pattern threatens participants, disobeys judicial authority, and erodes public trust in the legal system, Tennessee’s highest court may impose its most severe professional sanction.