People v. Riley.
No. 25PDJ73. 11/20/2025. Stipulation to Discipline.
December 12, 2025
The Presiding Disciplinary Judge approved the parties’ stipulation to discipline and suspended Kelli R. Riley (attorney registration number 44828) for one year, with six months to be served and six months to be stayed upon Riley’s successful completion of a two-year period of probation, with conditions. The suspension was effective on December 1, 2025.
In January 2022, Riley filed a complaint in Weld County District Court against her client’s former employer. The complaint, which alleged employment discrimination, stated that Riley’s client had “exhausted all administrative prerequisites to filing” the complaint. But Riley had not shown that the Equal Employment Opportunity Commission (EEOC) or the Colorado Civil Rights Division (CCRD) had issued a right to sue letter to her client. Opposing counsel moved to dismiss the complaint on February 4, 2022, alleging that Riley’s client had not exhausted administrative remedies. During a conferral on that motion, Riley falsely told opposing counsel that she had a right to sue letter from the EEOC. But she did not submit requests to the EEOC or the CCRD to issue right to sue letters until February 8, 2022.
On February 22, 2022, Riley responded to the motion to dismiss. In the response, Riley did not correct her assertion in the complaint that her client had exhausted administrative remedies. Rather, she falsely stated that she received the right to sue letter from the EEOC on February 16, 2022; in fact, on that date Riley had received only a notice confirming the EEOC’s receipt of her request for the right to sue letter. Riley did not correct her response, however, and on April 13, 2022, the district court denied the motion to dismiss.
Through the conduct described above, Riley violated Colo. RPC 3.3(a) (a lawyer must not knowingly make a false statement of material fact or law to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer); Colo. RPC 4.1(a) (a lawyer must not, in the course of representing a client, knowingly make a false statement of material law or fact to a third person); and Colo. RPC 8.4(c) (it is professional misconduct for a lawyer to engage in conduct involving dishonesty, fraud, deceit, or misrepresentation).