Background
Judge Pro Tempore David Ruzumna sought a $10 employee parking discount at the Goat Hill Garage in King County on multiple occasions. When parking attendants refused to grant the discount without proper employee identification, Ruzumna created a letter stating he was employed as a Judge Pro Tempore and affixed it with the signature stamp of Judge Rebecca Robertson—without her permission—along with the King County District Court seal. He presented this document to the parking attendant. Ruzumna was entitled neither to the discount (pro tempore judges do not receive employee benefits) nor to use Judge Robertson’s official stamps.
After the parking garage manager discovered the unauthorized use of judicial insignia, the King County District Court’s executive committee unanimously removed Ruzumna from the pro tempore list. The Commission on Judicial Conduct charged him with violating the Code of Judicial Conduct. During disciplinary proceedings, Ruzumna claimed he had created the document as a “joke” with “multiple random stamps” to demonstrate he should receive the discount. Other witnesses, including the garage manager and the HR director who measured the paper, testified no additional stamps appeared on the document, contradicting his account.
The Court’s Holding
The Washington Supreme Court upheld the Commission’s findings that Ruzumna violated Code of Judicial Conduct Rules 1.1 (Compliance with the Law), 1.2 (Promoting Confidence in the Judiciary), and 1.3 (Avoiding Abuse of the Prestige of Judicial Office). The court affirmed removal from judicial office, rejecting Ruzumna’s argument that only an admonishment was appropriate.
The court held that creating a false or misleading document using another judge’s signature stamp and official court seal without authorization constitutes impropriety violating judicial integrity. Critically, the court ruled that even if Ruzumna had been entitled to the discount, the means employed—misappropriating official judicial insignia—abuses the prestige of judicial office. The court characterized his conduct as a “flagrant and intentional” misuse of judicial power. The court also found that Ruzumna’s fabricated account during disciplinary proceedings (the “multiple stamps” story) compounded the misconduct and demonstrated lack of genuine remorse. Rather than acknowledge the gravity of misusing judicial symbols, Ruzumna minimized his conduct as “farcical,” which the court found aggravating.
Key Takeaways
- Judges cannot misuse official judicial insignia—signature stamps and court seals—for personal gain, regardless of the benefit’s magnitude
- Whether a judge was entitled to the underlying benefit (here, the parking discount) does not justify unethical means of obtaining it
- Dishonesty and lack of remorse during disciplinary proceedings compound underlying misconduct and are critical factors in sanction determination
- A judge’s experience on the bench aggravates misconduct; experienced judges should know that misuse of judicial symbols is improper
Why It Matters
This decision establishes that unauthorized misuse of official judicial insignia constitutes grounds for removal—the most severe sanction available. The court emphasized that judicial signature stamps and court seals carry significant legal weight because judges’ orders must be followed. Misuse of these symbols threatens public confidence in the legitimacy of judicial institutions. The court noted that Judge Robertson’s own reaction—confusion and shock—reflects how serious this violation is within the judicial community. The decision sends a clear message: judges cannot exploit their official position or its symbols for personal advantage, however minor.
For judges facing disciplinary action, the opinion underscores that genuine acknowledgment of misconduct and remorse are critical mitigating factors. Ruzumna’s strategy of fabricating explanations and minimizing his conduct as a joke ultimately compounded his situation by evidencing a “pattern of dishonest behavior.” The decision also highlights that judges have alternative, legitimate means available—such as contacting HR or the court administrator for clarification—rather than misappropriating official stamps.