State Bar & Bar Associations,
Law Practice,
Ethics/Professional Responsibility
Feb. 17, 2022
Calling female commissioner ‘succubistic’ is free speech, State Bar judge rules
"Distasteful as it is, this comment was made figuratively, representing rhetorical hyperbole, and consequently is protected by the First Amendment," Judge Cynthia Valenzuela wrote.




An attorney who called an Orange County commissioner's fee denial "succubistic" in a 2020 sexual harassment case was protected by the First Amendment, a State Bar judge determined, but recommended probation, fines and a 30-day suspension of his bar license for other insults and a perceived lack of remorse.
"I do not have any comment on the bar court's instant decision about my case, as litigation is still pending, other than to say that the...
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