PROFESSIONAL LIABILITY
The Ethics of Plagiarism
The Narcissism of
Small Differences
By David L. Brandon
Courts and professional
associations have offered
direction that will assist
attorneys so that they
may avoid the pitfalls
associated with using
others’ work without
proper attribution.
“When a thing has been said and said well, have no
scruple. Take it and copy it.”
—Anatole France, winner of the Nobel
Prize in Literature, 1921.
This political season, plagiarism has
become one of the hot topics. Did Melania Trump, in her speech at the Republican
National Convention, plagiarize portions of
speeches given by Michelle Obama in 2008
and 2012? See, e.g., Did Melania Trump
plagiarize Michelle Obama?, http://www.
cbsnews.com (July 19, 2016) . Did President
Obama plagiarize Donald Trump, Jr., when
using the phrase “this is not the America I know,” or did Trump, Jr., plagiarize it
from Obama? Or did the phrase originate
with President George H.W. Bush or Walter Cronkite? See, e.g., Aaron Blake, Trump
Jr. Says Obama Plagiarized His Quote, but
Not Before He Borrowed It from Obama and
Both President Bushes, http://www.washingtonpost.com (July 28, 2016). By the time that
this article is published, this story may have
faded from public attention. (Commentators on both sides of the political aisle
claim that voters’ short attention spans
spell disaster for the nation. See, e.g., Tom
Purcell, The Consequences of Short Attention Spans, townhall.com (July 14, 2015)
Josh Sager, The Shockingly Short Political
Memory of the American People, http://www.
theprogressivecynic.com (Oct. 2014).)
The potential short attention span of
the public notwithstanding, these accusations provide lawyers with the opportunity to consider: What is plagiarism? Is it
ever permissible in a legal setting? Is it per
se unethical? Is self-­plagiarism acceptable
in all situations? If there are ethical considerations, what are the consequences of
crossing the line?
There is no single answer. Generally
speaking, lawyers should avoid pure plagiarism, i.e., using outside source material
without proper attribution. In addition,
lawyers are usually permitted to recycle
David L. Brandon is a partner in the Los Angeles and San Francisco office of Morris Polich & Purdy LLP. He currently chairs
the DRI Professional Liability Committee. He is a current member and past chair of the Los Angeles County Bar Association’s
Professional Responsibility and Ethics Committee and serves as an adjunct professor of Appellate Law at Loyola Law School
in Los Angeles. His practice focuses on the defense of professionals, commercial litigation, and appeals. Mr. Brandon wishes
to acknowledge the invaluable research assistance provided by Ronna Kinsella of Glassman, Wyatt, Tuttle & Cox, P.C., without
which this article would not have been possible. This article has been partly “plagiarized” from Mr. Brandon’s article “To Copy or
Not to Copy: That Is the Question,” published in the September 2016 issue of the Los Angeles County Bar Association Update.
(Title paraphrased from a quote by Malcolm Gladwell, author.)
■ © 2016 DRI. All rights reserved.
For The Defense October 2016 55
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PROFESSIONAL LIABILITY
their own material. But there are situations
in which even self-­plagiarism raises ethical concerns.
What Is Plagiarism in a Legal Setting?
“When you have wit of your own, it’s
a pleasure to credit other people for
theirs.”
—Criss Jami, author.
Black’s Law Dictionary defines plagiarism
as “[t]he deliberate and knowing presentation of another person’s original ideas
or creative expressions as one’s own.…”
Black’s Law Dictionary (10th ed. 2014).
But as some commentators have noted, in
many settings this is precisely what lawyers do when representing their clients, and
representing them effectively. See, e.g., Benjamin Shatz and Colin McGrath, Beg, Borrow, Steal: Plagiarism vs. Copying in Legal
Writing, California Litigation 26:3 (2013);
Peter Joy and Kevin McMunigal, The Problems of Plagiarism as an Ethics Offense,
Criminal Justice, 26:2 (2011).
Lawyers routinely utilize litigation and
transactional forms available online or in
libraries. They appropriate portions of contracts or briefs received from other counsel,
even opposing counsel. They get inspiration for their legal analyses from law review
articles, presentations, and court opinions. They recycle their own work when it
is suitable to the needs in a new situation.
Is any of this plagiarism? And, if so, is it
improper?
General Guidelines
“I get a lot of big ideas, and occasionally I actually come up with one myself.”
—Bauvard, author.
In many situations a lawyer may appropriate language from other sources. This
article will discuss some of the more common instances. But it is beyond the scope
of this article to discuss every instance
where a lawyer may be involved in the
use of material from sources other than
the lawyer’s own creativity. There is, however, a common concept that may be used
in determining whether the use of outside
sources crosses an ethical line: the duty of
honesty toward clients and courts.
As noted by the Illinois Supreme Court,
honesty is “fundamental to the functioning of the legal profession.” In re Lamberis,
93 Ill.2d 222, 228 (Ill. 1982). See also In re
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Zbiegien, 433 N.W.2d 871, 879 (Minn. 1988)
(Kelley, J., dissenting) (“Honesty is universally recognized as the character trait
most fundamental to the practice of law.”).
Courts have described a lawyer’s duty as
one of honesty. See, e.g., Capital Care Corp.
v. Hunt, 847 A.2d 75 (Pa. Super. Ct. 2004);
Trousdale v. Henry, 261 S.W.3d 221 (Tex.
App. 2008).
The ABA Model Rules make this principal universal and emphasize the need
for honesty by lawyers. Model Rule 8.4(c)
defines “professional misconduct” as
engaging “in conduct involving dishonesty, fraud, deceit or misrepresentation.”
The rules also impose an affirmative duty
on lawyers to report another lawyer’s dishonest conduct: ABA Model Rule 8.3(a)
provides that “[a] lawyer who knows that
another lawyer has committed a violation
of the Rules of Professional Conduct that
raises a substantial question as to that lawyer’s honesty, trustworthiness or fitness as
a lawyer in other respects, shall inform the
appropriate professional authority.” Lawyers also have a duty of candor toward the
tribunal before which they practice. ABA
Model Rule 3.3.
Clear cases of plagiarism are particularly offensive to this notion of honesty
and candor, even when not directed toward
a client or a court. In Lamberis, 93 Ill.2d
at 222, an admitted lawyer enrolled in an
LLM program, and as part of a required
thesis, he submitted a paper that incorporated excerpts from two published works
without crediting the sources; the effect of
this was that the lawyer misrepresented the
work of others as his own. The law school
expelled the lawyer for plagiarism and filed
a complaint with the Attorney Registration
and Disciplinary Commission. Id.at 225.
The Illinois Supreme Court rejected the
lawyer’s argument that there was no basis
to discipline him for conduct outside of the
practice of law, finding that discipline can
be warranted for illegal conduct or fraud
on the court. But while no illegal conduct
or fraud on a court existed in this case,
the Illinois Supreme Court found it appropriate to impose discipline. The conduct
demonstrated the lawyer’s “complete disregard for values that are most fundamental in the legal profession” as well as “an
extreme cynicism towards the property
rights of others.” Id. at 226–227. The pla-
giarism “amounted to at least a technical
infringement of the publishers’ federally
protected copyrights” similar to conversion of personal property, which Illinois
and other states had held warrants discipline. Id. at 227 (citing In re Abbamonto, 19
Ill.2d 93 (Ill. 1960), Stratmore v. State Bar,
14 Cal.3d 887 (Cal. 1975), and In re Gunderson, 75 A.D.2d 706, 427 N.Y.S.2d (N.Y. App.
Div. 1980)). The Illinois Supreme Court
concluded that the use of the misappropriated material displayed “a lack of honesty
which cannot go undisciplined.” Lamberis,
93 Ill.2d at 228.
It is not just lawyers who can be criticized or sanctioned for plagiarism in a legal
setting. The Supreme Court of Michigan
approved of the public censure of a sitting
judge in Matter of Brennan, 433 Mich. 1204
(Mich. 1989), for submitting a law review
article that incorporated several portions
of articles by other authors without attribution. The court concluded that the judge’s
plagiarism constituted “[c]onduct clearly
prejudicial to the administration of justice.” Id. at 1205.
As we shall see, when analyzing the different situations that may be considered
plagiarism, courts often examine whether
the lawyer is being honest toward the court
or the lawyer’s own client. In addition,
courts recognize that when a lawyer plagiarizes another source, the lawyer “does
not do his client or the Court any favors by
cribbing material from a judicial opinion
without adding any additional analysis.”
C.L. ex rel. K.B. v. Mars Area School Dist.
2015 WL 3968343, at *6 (W.D. Pa. 2015).
The Use and Modification of PrePrinted Forms from Outside Sources
“Behind every Plagiarism there is
Google.”
—Vikash Shrivastava, author.
Many lawyers copy material from form
books when drafting court documents
and contracts. Indeed, there are a plethora
of publications that exist for the primary
purpose of being copied for the creation of
litigation documents such as pleadings or
notices. Others contain forms to be used in
the creation of contracts. See, e.g., Westlaw,
Federal Procedural Forms (2016) (described
as “a comprehensive set of forms, ‘how to’
text, and practice aids for use in the federal courts and administrative agencies);
Westlaw, Nichols Cyclopedia of Legal Forms
Annotated (2016) (“an encyclopedia that
has a collection of more than 230 transactional legal chapters with related analysis”);
Westlaw, Westlaw Official Forms (2016)
(providing users with the “full text” of various state and federal forms, which “can
be viewed in PDF format and can be completed and printed for filing.”). In addition,
individual lawyers and law firms maintain
brief banks, which they consult and share
with other lawyers. Shatz and McGrath,
supra. This avoids the need to “reinvent
the wheel.” (Idiom of unknown origin.) See
What Does “Reinvent the Wheel” Mean?,
http://www.wisegeek.com.
Using such forms without attribution
could hardly be considered plagiarism
unless the lawyer claims one as original
thought. Black’s Law Dictionary, supra. At
least one court has specifically approved of
this practice as long as the attorney utilizing the form adopts the pre-printed form
as the attorney’s own, “thus becoming the
‘drafter’ in the sense that [the attorney] accepts responsibility for it.” Federal Intermediate Credit Bank of Louisville v. Kentucky
Bar Ass’n, 540 S.W.2d 14, 16 n.2 (Ky. 1976).
In contrast, the use or modification of
such forms by non-lawyers can be fraught
with peril, and it may constitute the unauthorized practice of law without a license.
That was the holding in Federal Intermediate Credit Bank of Louisville, 540 S.W.2d
at 16. There, a lending institution created a
real estate mortgage by using a form that
had been prepared by Lawyer A, modifying the form by adding a title description prepared by Lawyer B, and presenting
that mortgage to the borrower. However,
the lender failed to have the final document reviewed by a lawyer. The Supreme
Court of Kentucky concluded that the lender’s presentation of the document without
obtaining a lawyer’s review constituted the
unlicensed practice of law, a misdemeanor
under Kentucky law. Id. at 16; Ky. Rev. Stat.
Ann. §524.130. Other states have also criminalized the unauthorized practice of law.
See, e.g., Cal. Bus. & Prof. Code §6126; Va.
Code Ann. §54.1-3904.
It is a common practice for lawyers to
prepare contracts and other legal documents for use by their clients. The prudent
practitioner may wish to advise a client not
just that the use of the document provided
may not be appropriate in a different setting, but also that modifying the document
without then seeking review by an attorney
may lead to criminal penalties as the unauthorized practice of law.
The Dangers of Ghostwriting
for Non-lawyers
“[G]hostwriters… have as much right
to think of themselves as good writers as academics, poets, or literary
novelists.”
—Sara Sheridan, author.
Some lawyers may be engaged by clients
to prepare documents to be filed with a
court under the client’s signature as a pro
per party, without disclosing to the court
that the lawyer is the true author. Perhaps
the client cannot afford to pay the lawyer’s
standard retainer fee. Perhaps the lawyer
is unable to determine whether to take the
case prior to the running of an imminent
statute of limitations. Whether this conduct subjects the lawyer to possible adverse
consequences will depend on the rules of
the particular jurisdiction.
For example, California specifically permits such submissions. California Rule of
Court 3.37(a) provides that “[i]n a civil proceeding, an attorney who contracts with
a client to draft or assist in drafting legal
documents, but not to make an appearance in the case, is not required to disclose
within the text of the documents that he
or she was involved in preparing the documents.” California Rule of Court 5.425(f)
(1) contains a similar provision in family
law matters. The ABA Standing Committee on Ethics and Professional Responsibility concluded that this practice did
not violate ethical rules. ABA Formal Op.
07-446 (2007).
Other jurisdictions have reached contrary conclusions. In particular, the practice is condemned by some federal courts,
which view ghostwriting by lawyers for
pro per parties “as a deliberate evasion of
the responsibilities imposed on counsel by
[Federal Rule of Civil Procedure 11.” Johnson v. Board of County Com’rs for County of
Fremont 868 F. Supp. 1226, 1231 (D. Colo.
1994), aff’d in part, disapproved in part, 85
F.3d 489 (10th Cir. 1996).
What we fear is that in some cases actual
members of the bar represent petitioners, informally or otherwise, and pre-
pare briefs for them which the assisting
lawyers do not sign, and thus escape
the obligation imposed on members of
the bar, typified by F. R. Civ. P. 11, but
which exists in all cases, criminal as
well as civil, of representing to the court
that there is good ground to support the
assertions made. We cannot approve of
such a practice. If a brief is prepared in
The prudent practitioner
may wish to advise a client
not just that the use of the
document provided may
not be appropriate in a
different setting, but also
that modifying the document
without then seeking review
by an attorney may lead to
criminal penalties as the
unauthorized practice of law.
any substantial part by a member of the
bar, it must be signed by him.
Id. (citing and quoting Ellis v. Maine 448
F.2d 1325, 1328 (1st Cir.1971). See also
Ricotta v. State of Cal., 4 F. Supp. 2d 961, 987
(S.D. Cal. 1998), aff’d sub nom., Ricotta v.
State of Calif., 173 F.3d 861 (9th Cir. 1999)
(calling such conduct “unprofessional”); In
re Compact Disc Minimum Advertised Price
Antitrust Litigation, 456 F.Supp.2d 131, 165
(D. Me. 2006); In re Mungo, 305 B.R. 762,
768 (Bankr. D.S.C. 2003).
At least one state Supreme Court has
approved of this logic. Iowa Supreme Court
Bd. of Professional Ethics and Conduct v.
Lane, 642 N.W.2d 296, 299 (Iowa 2002).
Accordingly, before a lawyer agrees to
ghostwrite a document for a pro per party,
the lawyer should review the applicable
law in the particular jurisdiction or federal circuit.
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PROFESSIONAL LIABILITY
The Use of Sources in Legal
Briefs Without Attribution
“To steal ideas from one person is
plagiarism; to steal from many is
research.”
—Steven Wright, comedian.
Lawyers may be tempted to make use of analyses prepared by others with more experience
in the field, or who simply are better writers.
Lawyers may be tempted
to make use of analyses
prepared by others with
more experience in the field,
or who simply are better
writers. Doing so without
attribution can have adverse
consequences ranging from
embarrassing notations
by courts in opinions,
public rebukes by courts,
and referrals by courts to
disciplinary agencies, to
monetary sanctions, and
in the extreme, discipline
including suspension from
the practice of law.
Doing so without attribution can have adverse consequences ranging from embarrassing notations by courts in opinions, public
rebukes by courts, and referrals by courts to
disciplinary agencies, to monetary sanctions,
and in the extreme, discipline including suspension from the practice of law.
The mildest action taken by a court is
the mere mention of the plagiarism within
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a written opinion. For example, in U.S. v.
Bowen, 194 Fed. Appx. 393, 402 fn.3 (6th
Cir. 2006), the court of appeal “discovered”
that approximately 20 pages of an appellate
brief “was copied almost verbatim from a
published district court decision,” which
“was not even cited” in the brief. The lawyer responsible got off easy: The Sixth Circuit
merely noted the plagiarism in a footnote,
stating that the court had “made it very clear
to [the attorney] during oral argument this
behavior is completely unacceptable and
reiterate it here as an admonishment to all
attorneys tempted to ‘cut and paste’ helpful analysis into their briefs.” Id. Other examples of this mild form of rebuke can be
found in U.S. v. Lavanture, 74 Fed. Appx.
221, 224 fn.2 (3rd Cir. 2003), U.S. v. Jackson
64 F.3d 1213, 1219 fn.2 (8th Cir. 1995) (“we
do express our disapproval of a style of briefwriting that appropriates both arguments
and language without acknowledging their
source”), and Vasquez v. City of Jersey City,
2006 WL 1098171, at *8 fn.4 (D. N.J. 2006)
(“this Court shall use this opportunity to
express its displeasure with counsel and to
set forth its expectation that all future submissions from City of Jersey City attorneys
will be properly cited”).
Monetary sanctions have been assessed
against lawyers based on plagiarism charges,
including lawyers who may not have been responsible for the plagiarism but who signed
the offending brief. In Lohan v. Perez, 924
F. Supp. 2d 447 (E.D.N.Y. 2013), the district
court found that most of the plaintiff’s opposition to a defense motion to dismiss was
plagiarized, a finding that was not disputed
by the plaintiff’s attorneys. Id. at 460. The
court found that the conduct violated New
York State Rule of Professional Conduct 8.4,
prohibiting “‘conduct involving dishonesty,
fraud, deceit or misrepresentation.’” Id. at
461 fn.9. The court ruled that such conduct
could be sanctioned under the court’s inherent powers. Id. at 460. The plaintiff’s lawyers
argued that sanctions were inappropriate
because it was unclear which of the two lawyers had actually written the plagiarized
portion of the brief; in fact, they were pointing fingers at each other. In an act perhaps
reminiscent of the Judgment of King Solomon suggesting to cut the baby in half to determine the identity of its mother in 1 Kings
3:16-28, the district court easily resolved this
dilemma by sanctioning only one of the law-
yers: the one who signed the brief. The district court reasoned that the lawyer signing
the brief has a non-­delegable responsibility to the court and is the appropriate target for sanctions. Lohan, 924 F. Supp. 2d at
460. The clear lesson of Lohan: be careful
what briefs you sign.
Lawyers have also been publicly censured
for plagiarism. In Matter of Steinberg, 206
A.D.2d 232, 620 N.Y.S.2d 345 (1994), a lawyer who had long been qualified to represent
criminal defendants facing misdemeanor
charges was urged to seek an upgrade to
the felony panel. He submitted two writing
samples, both of which had been prepared
by other attorneys, and which he simply retyped under his own name. The lawyer was
suspended from the criminal court panel
and publicly censured. Id. at 233. And in In
re Hinden, 654 A.2d 864 (D.C. 1995), an attorney was publicly censured when it was
found that 23 pages of his 56-page chapter
in a legal treatise were “copied verbatim or
substantially verbatim from the article of
another author.”
Plagiarism may also support the extreme
disciplinary sanction of suspension from
the practice of law. In Columbus Bar Assn.
v. Farmer, 111 Ohio St.3d 137 (Ohio 2006),
a convicted criminal defendant hired a new
lawyer to take over the appeal after a predecessor attorney had prepared and filed the
appellate brief. The new lawyer told the defendant that if he was hired, he would have
to write and file a new brief because the existing brief was insufficient. When the lawyer filed the new (and supposedly improved)
appellate brief, it was discovered that it was
virtually verbatim the same brief that has
been filed by the predecessor counsel. Id. at
138–39. The Supreme Court of Ohio held that
the lawyer had violated several Ohio Disciplinary Rules, including those prohibiting
dishonesty and charging an excessive fee;
in fact, the court noted that “accepting fees
and failing to provide promised services in
return is tantamount to theft of the client’s
money.” Id. at 142–43, 147–48. This and
other violations warranted the actual suspension from the practice of law. Id. at 148.
Self-plagiarism
“Self-plagiarism is style.”
—Alfred Hitchcock, director.
As noted previously, it is a common practice for lawyers to recycle their own work
product, or those of other members of their
firms. In most situations, there is nothing
improper about a lawyer reusing his or her
own previous work. However, lawyers can
get into trouble for using their own work
for improper purposes.
For example, in Kim v. Westmoore Partners, Inc., 201 Cal. App. 4th 267 (Cal. Ct.
App. 2011), an appellate lawyer requested
an extension of time to file a brief by claiming that he needed additional time to conduct research to deal with the complex issues
raised in the case. But when he finally submitted his brief, the court of appeal determined that the brief was virtually identical
to a brief that the same lawyer had filed in
an earlier case. This was clearly inconsistent with the lawyer’s claimed need for an
extension. The court sanctioned the lawyer
$10,000 under its power to sanction counsel
for the filing of frivolous motions. Id. at 292–
94. Because of the amount of the sanction,
the court forwarded a copy of its opinion to
the California State Bar. Id. at 295. (California Business and Professions Code section
6086.7(a)(3) requires a court to notify the
state bar of the imposition of non-­discovery
sanctions in the amount of $1,000 or higher.)
Recycling one’s own work product can
also cause problems if the work product
is billed improperly. Lawyers often recycle
work product, such as discovery or briefs,
in their matters. This is entirely appropriate when the matter at hand raises issues
that have been raised in other matters that
the lawyer has handled, and in fact, it can
result in significant savings to the client
who is not paying for original research or
work product. But if a lawyer decides to bill
the client for the work product as if it were
newly created, ethical lines may be crossed.
This scenario was recently addressed by
the California State Bar Committee on Mandatory Fee Arbitration. Cal. Bar Comm. on
Mandatory Fee Arb., Arb. Advisory 201602 (2016), www.calbar.ca.gov (analyzing potential bill padding). There, the committee
noted with approval an ABA opinion stating,
‘A lawyer who is able to reuse old work
product has not re-earned the hours previously billed and compensated when the
work product was first generated.… the
lawyer who has agreed to bill solely on the
basis of time spent is obliged to pass on the
benefits of these economies to the client.’
Id. (quoting ABA Formal Op. 93-379 (1993)).
The committee also cited an ethics opinion concluding that “[a]bsent clear disclosure to the client, attorneys billing on an
hourly basis cannot properly add additional
hours to a client’s bill when revising such
an ‘in-house’ form to reflect the time spent
preparing the original (template) form.” Id.
(quoting Orange County Bar Ass’n Formal
Op. 99-001 and Paul Vapnek et al., California Practice Guide: Professional Responsibility, ch. 5, ¶ 5-945 (2012). The committee
concluded that failing to disclose the premium (i.e., the billing for the prior work)
may be evidence of bill padding. Id.
It is also possible that billing a client for
preexisting work product may be considered an attempt to collect an unconscionable fee. The committee noted that when a
lawyer bills two clients for the same time,
for example, by charging “two clients the
full five hours it took [the lawyer] to attend
two court hearings for the two separate
clients on the same morning in the same
court,” the resulting fee may (depending on
the circumstances) be considered unconscionable. Id.
Lawyers who charge their clients for
work that they did not perform are at risk
of being sanctioned and of being required
to disgorge their fees. In In re Burghoff,
374 B.R. 681 (2007), a lawyer billed his client over $5,700 for 25.5 hours of work preparing briefs that were mostly plagiarized
from an article that the lawyer found on
the internet. The bankruptcy court found
this amount unreasonable because the
court concluded that the lawyer could not
have spent that many hours cutting and
pasting the article into his brief and making slight modifications. The court found
that the lawyer had violated Iowa Rules of
Professional Conduct Rule 32:1.5, which
prohibits attorneys from charging or collecting an unreasonable fee. Id. at 685. The
court imposed a sanction by requiring the
lawyer to take a remedial course in ethics.
Id. at 686. In addition, the court ordered
that the lawyer disgorge all of the fees
charged for the brief. The court reasoned
that “[w]here an attorney bills for work not
performed, the court may deny fees and
order disgorgement of fees already paid.”
Id. at 687. Here, the court concluded that
based on the low quality and utility of the
work, any amount charged would be unreasonable. Id.
Conclusion
“You stole my story and something’s got
to be done about it.”
—Stephen King, author.
Lawyers should recognize the potential pitfalls of using the work of others without
proper attribution. It is not difficult to provide appropriate citations in legal briefs.
Citing the proper authorities also gives a
It is not difficult to
provide appropriate
citations in legal briefs.
Citing the proper
authorities also gives
a brief more credibility.
Practitioners should err
on the side of providing
too many citations
instead of too few.
brief more credibility. Practitioners should
err on the side of providing too many citations instead of too few.
Lawyers should also take care when they
prepare documents for clients, who may
wish to use them for purposes for which
they were not originally intended. Lawyers who provide ghostwritten briefs need
to be certain that such submissions are permitted; if not, nothing prevents the lawyer
from inserting a sentence in the document stating that the brief was prepared
with the assistance of the lawyer. And lawyers should be certain that they trust their
co-authors before signing jointly written
briefs.
Finally, and above all, lawyers must
examine their actions and be certain that
they are being completely honest with the
courts and their clients, particularly when
submitting briefs and invoices.
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