Texas Rule of Disciplinary Procedure 17.06(A) prohibits the imposition of discipline for professional misconduct occurring more than four years before the allegation of misconduct is received by the Commission for Lawyer Discipline (CLD). In Lane v. Commission for Lawyer Discipline, the Court addressed the issue of whether Rule 17.06(A) operates in reciprocal discipline cases. Specifically, as it pertained to the facts of Lane, the issue was whether the CLD could impose reciprocal discipline on Lane who self-reported in January 2023 the entry of a February 2023 judgment of discipline against her by a foreign jurisdiction when the subject conduct of the discipline occurred in 2017, more than four years prior to the self-report. 

The CLD took the position that no statute or rule of limitations governs reciprocal discipline proceedings. The Court disagreed holding that Rule 17.06(A) “applies to…