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FL Supreme CourtFebruary 22, 2018Referee's findings of guilt approved; recommended consecutive suspension disapproved; attorney disbarred⭐ Notable

The Florida Bar v. Ratiner

Case No. SC13-539

The Florida Supreme Court approved a referee's findings that attorney Robert Ratiner violated Bar Rules 4-3.5(c), 4-8.4(a), and 4-8.4(d) by muttering 'lie, lie, lie' during testimony and repeatedly kicking opposing counsel's table during a post-trial hearing. The Court rejected the referee's recommendation of a second three-year suspension to run consecutively, holding that such a sanction would exceed the three-year maximum under Standard 2.3, and instead disbarred Ratiner based on cumulative, escalating incivility across three disciplinary cases.

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Key facts

  • Attorney Robert Ratiner was disciplined by The Florida Bar for conduct during a post-trial hearing, including muttering 'lie, lie, lie' during opposing counsel's testimony and repeatedly kicking opposing counsel's table.
  • A referee found Ratiner violated Bar Rules 4-3.5(c), 4-8.4(a), and 4-8.4(d), and recommended a three-year suspension to run consecutively to a prior three-year suspension.
  • +2 more key facts with a free trial

Why it matters

This is the Supreme Court's strongest statement yet that escalating incivility and unprofessionalism alone — without dishonesty or client harm — can lead to disbarment. Practitioners should note the explicit holding… — full analysis with a trial

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