9th U.S. Circuit Court of Appeals
Jun. 12, 2026
The naughty 9th
The 9th Circuit upheld Arizona's bar admission restrictions and sanctions despite a recent 8-1 U.S. Supreme Court decision rejecting the same legal framework, raising questions about adherence to precedent, sanctions standards and judicial reasoning.
Richard W. Morris
Richard W. Morris is a retired lawyer admitted in the United States Supreme Court, two U.S. states (Arizona and California), and the United Kingdom of England and Wales.
On March 31, 2026, the Supreme Court decided Chiles v. Salazar, 146 S. Ct. 1010, ruling 8 -1 that the professional licensing context does not diminish First Amendment protection and that restrictions on professional speech must survive strict scrutiny. The Court expressly abrogated Tingley v. Ferguson, 47 F.4th 1055 (9th Cir. 2022).
Seven weeks later, a three-judge 9th Circuit panel decided Lawyers for Fair Reciprocal Admission v. Timmer...
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