In re Raykin.

2025 CO 12. No. 24SA216. Colorado Rules of Professional Conduct—ABA Standards for Imposing Lawyer Sanctions—Court Rules Interpretation—Colo. RPC 4.4(a).

March 24, 2025

In this case, the supreme court reviewed the Office of the Presiding Disciplinary Judge’s (PDJ) finding that attorney Raykin violated Colo. RPC 4.4(a) and its imposition of sanctions for that violation. The court considered whether the PDJ’s hearing board properly relied on the American Bar Association’s Standards for Imposing Lawyer Sanctions (ABA Standards) when determining the appropriate sanction for Raykin. The court held that the ABA Standards are a guide for determining sanctions in attorney discipline cases, but that the Colorado Rules of Professional Conduct are ultimately determinative and that the hearing board’s finding of a violation and imposition of sanctions are proper. The court affirmed the sanctions imposed by the hearing board.