A Spotlight on Judicial Ethics
Judicial Ethics Bulletin
A bimonthly publication of recent issues affecting judicial ethics from the Center for Judicial Ethics.
May 16, 2025
A message from the Center for Judicial Ethics
The National Center for State Courts ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIOqyiwsFoud6u3qxN9pYQGieVdn5JT1Mg1LtaVMZceSZuLkrlA ) (NCSC) launched a new website on May 14, 2025.
The Center for Judicial Ethics ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIOuyiwvpCABK5YOUkdeOUFZ4kQaD2ySLF6R4CWgTZqvJJq1-Tg ) has a new webpage. The Judicial Conduct Report is now available in the NCSC Library eCollection ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIOyyiwviS3dtxj257_-5C9EJzgSkJiSRHCZp5Usbn-MpsD1yng ).
Save the date: National College on Judicial Conduct and Ethics, Oct. 15-17, Louisville, KY. The agenda and registration will be sent out by June 6.
All commission updates, news and final dispositions should be sent to Cathy Zacharias ( czacharias@ncsc.org ).
Recent Ethics & Discipline Cases
California
Case: In re: Jeffrey Ferguson ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIO2yiwtcRZpIf8g-2wTS-t6N4BuSiwBhE8n-kaW5L_SRGVBO7g ), April 25, 2025
Brief Facts:
On April 22, 2025, Orange County Superior Court Judge Jeffery Ferguson was convicted of second-degree murder, a felony, for the shooting death of his wife.
Holding:
Based upon the conviction of Jeffrey Ferguson, the California Commission on Judicial Performance ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIO6yiws4_tVu58aAEgXgo2AkJMpNXHS626uwFgYBypfYFx6utw ) suspended Judge Ferguson from office without salary pursuant to Cal. Const., art. VI, § 18, subd. (c).
Case: Bradley W. Sullivan ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIO-yiws8YGIS_vLsIML88S-ntQ4p7EtzFjvhnAvS1jpjhTN5Bw ), May 9, 2025
Brief Facts:
The California Commission on Judicial Performance ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIO6yiws4_tVu58aAEgXgo2AkJMpNXHS626uwFgYBypfYFx6utw ) investigated former Commissioner Bradley W. Sullivan for ex parte communication with litigants on multiple occasions as well as holding a litigant in contempt of court without following the proper procedure.
Holding:
The Commission on Judicial Performance issued a public admonishment against former Commissioner Sullivan for engaging in ex parte communication with litigants. The commission found that former Commissioner Sullivan’s conduct constituted an improper action within the meaning of article VI, section 18, subd. (d)(3) of the California Constitution.
Louisiana
Case: IN RE: Judge Eboni Johnson Rose ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPCyiwukORiDtaJ9xAuTFMgtFPuGZwALJagedslUje2QAYGxCg ), April 23, 2025
Weimer, C.J., dissents and assigns reasons. ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPGyiwsdTywXjWHi0D4P5X9fqK9xsRwV_G4K4j0M8f936ahMww )
Crain, J., dissents and assigns reasons. ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPKyiwv4H-NyAbr1fpYPmU6nlU1R69ya0pHhi4f8lxRRl0kumg )
McCallum, J., dissents and assigns reasons. ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPOyiwsIjZ0m4pAhLjRBS7wWaFmlgAp69S-coW8OuOnTNEYwug )
Cole, J., concurs in the result and assigns reasons. ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPSyiwthZEV6S64RJqZuRvuJCHlqrHv--rFs_Qor831-qSwnsQ )
Brief Facts:
The Judiciary Commission of Louisiana ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPWyiwtsPIGXPU1hxGAYdh8dcybtpkk4csULJWd3fgbAfsShpw ) received complaints regarding allegations of misconduct in four separate criminal cases by Judge Eboni Johnson Rose. The complaints in three of the cases involved allegations of serious legal errors and the complaint in the fourth case involved allegations of bias towards the district attorney’s office and used profane and offensive language, including a racial slur.
Holding:
The Louisiana Supreme Court had granted an interim disqualification of Judge Rose on August 6, 2024. The Court accepted the joint petition for consent discipline from the Commission and Judge Rose. The Court ordered that Judge Rose be suspended from judicial office, without pay, for six months, with all but two months deferred, be placed on probation for two years, and be assessed costs of $11,196 subject to an eighteen-month payment plan.
Minnesota
Case: Jay M. Quam ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPayiwvxPCdD8PqAhZp6ov-_wtPpBZl8B2EU2tT5wFvov6QzGA ), April 25, 205
Brief Facts:
A sexual harassment complaint was filed against District Court Judge Jay M. Quam for engaging inappropriate sexual contact with his law clerk, inappropriate comments made to other clerks, and behavior that made court staff feel uncomfortable.
Holding:
The Minnesota Board of Judicial Standards ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPeyiwtK1_3FfmZLvFfp3I7uyYTtDdi-Sed_wjSNiEbgNRF-Dw ) issued a public reprimand against Judge Quam. The Commission found that Judge Quam's conduct was contrary to the Minnesota Code of Judicial Conduct Rule 1.1, Rule 1,2, Rule 1.3, Rule 2.3(B), Rule 2.8(B), and Rule 3.1 (A), (C), and (E), as well as the Rules of the Board on Judicial Standards Rule 4(a)(5), and (6). Judge Quam retired from the judiciary on March 7, 2025, after the investigation commenced.
Washington
Case: In Re the Matter of The Honorable Ann Danieli ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPiyiwswVLhe6VN1mXCDQbnlqOL8Pi3MlWJPbKYdF6USCFggCA ), April 25, 2025
Brief Facts:
While investigating a complaint against part-time King County Superior Court Part-time Judge Ann Danieli, the Washington Commission on Judicial Conduct ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPmyiwvVTIhgMnm0m63cX6uc_SBxiLnZPJqACSLFEAdy3rKRBA ), it was discovered that Judge Danieli had shared numerous fundraising links on her personal Facebook page in violation of the Code of Judicial Conduct.
Holding:
The Commission admonished Judge Danieli. The Commission and Judge Danieli entered into a joint statement of facts and stipulation on Judicial Conduct that she violated Canon 1, Rules 1.1, 1.2, and 1.3, and Canon 3, Rule 3.7(B), of the Code of Judicial Conduct by sharing multiple solicitations for donations for third parties on her Facebook page.
Judge Danieli stipulated to the admonishment and provided a declaration that she had reviewed the Code.
Case: In re the Honorable David Ruzumna ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPqyiwsGTNVMX1-FQtyypCCG9TDNQQTs9W3WCHBeymQLbN3rEg ), April 25, 2025
Opinion Concurring and Dissenting ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPuyiwsKfK6HRphptiKk0X8q1RD9wOpHoFanwa2qEHsim-YCbA ) filed 4/25/2025.
Notice of Fact-Finding Hearing ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPyyiws24YMa0Du2Ap09WJxEVr9jKgqMi1wY_a16onfjDn1ACg ) filed 7/31/2024.
Answer to Statement of Charges ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIP2yiwt1rFqY0T6hd-F5RCl_4bdBDH4VfykqBTLY-CZwIuw7GQ ) filed 5/7/2024.
Statement of Charges ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIP6yiwtPq7tdBVfpdvtziwy2OfFwaPQx2CbmgvUbok6qi4OVFQ ) filed 5/6/2024.
Brief Facts:
A complaint was filed with Washington Commission on Judicial Conduct ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIPmyiwvVTIhgMnm0m63cX6uc_SBxiLnZPJqACSLFEAdy3rKRBA ) against Pro tempore Judge David Ruzumna of the King County District Court alleging that Judge Ruzamna created a fraudulent document to obtain a discounted parking rate for county employees. The document had a stamped seal of the King County District Court and a stamped signature of another Judge. Judge Ruzumna did not have permission to use either stamp.
Holding:
The Commission found Judge Ruzumna violated Canon 1, Rules 1.1, 1.2, and 1.3 of the Code of Judicial Conduct and censured Judge Ruzumna under Article IV, §31, Paragraph (8) of the Washington Constitution and recommended that the Supreme Court remove him from office. This sanction suspends Judge Ruzumna from any judicial position until a final determination is made by the Supreme Court.
Other Recent Cases
The New York State Commission on Judicial Conduct issued a decision on May 2, 2025 for the Resignation of Colonie Town Court Justice David R. Green (Albany County) ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIP-yiwtmcEKBagtPB3iuboDoWv72b3AsdXwxm_feZw12G_T-WQ ).
Recent Advisory Opinions
Colorado
Colorado Judicial Ethics Advisory Board ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIICziwsCf9PQ5Se8DGgb9WbL-iCuvQyuCBjthkV1g6goomh_fQ ) (CJEAB) issued Advisory Opinion 2025-01 ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIGziwssGeO4AvN3YAjgS9knOUvCoiWCnNvXkuWPm-DKSR116g ) on April 17, 2025.
Issue
1. Whether a judge may drive a vehicle that displays a sticker promoting a particular law firm.
2. Whether a judge may permit a member of his family to park a vehicle displaying a promotion for a particular law firm in front of his home.
3. Whether a judge may be a passenger in a vehicle with a sticker promoting a particular law firm on it.
ANSWER: “A judge may not drive a car promoting a particular law firm, nor can such a car be parked in front of the judge’s home, for two reasons. First, even though the judge recuses from this law firm’s cases, publicly disclosing an affiliation with a particular law firm creates an appearance of partiality and bias, which violates Rule 1.2, Rule 2.4, Rule 2.11(A), and Rule 3.13(A) of the Code of Judicial Conduct (“Code”). Second, driving such a car or permitting the car to be parked in front of the judge’s home could reasonably be viewed as permitting the prestige of the judge’s office to be used to advance the personal and economic interests of others, in violation of Rule 1.3 of the Code. However, the judge may be a passenger in such a car under Rule 3.13(B)(8) of the Code, which permits a judge to accept benefits associated with a profession of the judge’s spouse, so long as that benefit to the judge is merely incidental."
Florida
The Judicial Ethics Advisory Committee ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIKziwt52bWYyqqe0lMrfgxs74zylXlQ-CIsHoFqPJ_jZqQ-gg ) issued Opinion Number: 2025-10 ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIOziwtIof9u6X0v5ezOCkc23MwZNAkqBjq11H6tfKWFKY5HqQ ) on April 16, 2025.
Issue 1: May a judge appear in a documentary film about high conflict family cases where the judge would speak about trends in high conflict cases in general and also his experiences witnessing the effects on children of high conflict custody disputes. The judge would not discuss any specific cases pending in any court nor would the judge accept any payment for time or reimbursement of expenses. The documentary film may possibly be shown at a location where tickets are sold, or the film itself could be sold (such as to Netflix) for profit.
ANSWER: No.
Issue 2: May a judge allow the filmmaker to film the judge in chambers, or in the judge’s courtroom?
ANSWER: No.
New York
New York Advisory Committee on Judicial Ethics ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIISziws8583FGuUVE635k3Qavfv9GGDWxtl_l7m7UMFTOTm9KQ ) issued Opinion 25-60 ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIWziwuZDtniL4vrgd84yNomk_hVL1Q_VsYSHspBLLyZUL3yWQ ) on March 27, 2025.
Issue
The inquiring full-time judge asks about reaching out to state or federal legislators on various topics. We summarize and address these questions individually below.
ANSWER:
1. A judge may publicly support or oppose proposed legislative changes affecting the terms or conditions of judicial service, and therefore may contact his/her state representatives and urge them to abolish the so-called “death gamble” for judges.
2. A judge who is a naturalized citizen may speak to government officials, including federal legislators, to urge them to oppose proposed or enacted executive orders, policies, or legislation which seek to rescind citizenship of naturalized citizens based on their performance of judicial duties, including their judicial decisions or other statements made in their official capacity as judges. In doing so, however, the judge should not comment on what positions the legislators should take with respect to unrelated legislation and therefore the judge should not suggest filibustering every vote on all legislation.
3. A judge may speak publicly about the importance of judicial independence and the rule of law, and thus may speak to federal legislators on this topic. In doing so, however, the judge should not comment on what positions the legislators should take with respect to unrelated legislation.
4. Whether a particular federal executive or congressional decision affects a judge personally requires a fact-specific analysis.
Rules: 22 NYCRR 100.2; 100.2(A); 100.3(B)(1); 100.3(B)(6); 100.3(B)(8); 100.4(A)(1)-(3); 100.4(B); 100.4(C)(1); 100.5(A)(1); 100.5(A)(1)(iii); Opinions 23-61; 23-26; 23-15; 19-120; 17-54; 17-38.
Other News
Jim Smith has retired from the Missouri Commission on Retirement, Removal, and Discipline ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIaziwsSae9Ag1EgvlG7LQd-tGxHHgIIh5u6iuPJZxx-k-_CuQ ) (CRRD) after serving 48 years. Jeff Benoist has been appointed as the new director. The office has a new mailing address: Post Office Box 1529, Jefferson City, MO 65102.
The New York State Commission on Judicial Conduct issued its annual report on March 4, 2025: Commission Releases Annual Report of Activities for 2024 ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIeziwu-R9APn73dSgAyb1p8X6f-k5UEV8g5gdDaxXNtLgDD9A )
SB1749 ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIiziwuNPiXi43QeWxqADzAQxBoJIQfzepQRyZ_zI-CDM3pvWg ) is progressing through the Texas legislature that would extend privacy protections of personal identifying information to a current or former commissioner or employee of the State Commission on Judicial Conduct in addition to other employees of the judicial branch.
Resources
Center for Judicial Ethics ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIOuyiwvpCABK5YOUkdeOUFZ4kQaD2ySLF6R4CWgTZqvJJq1-Tg )
Judicial Conduct Reporter ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIOyyiwviS3dtxj257_-5C9EJzgSkJiSRHCZp5Usbn-MpsD1yng )
AI & the courts: judicial and legal ethics issues ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIImziwt-nHnXAa53ybdgoNiU3kLPvE0IWIWq6ZffDr4c-Zctpg )
State Judicial Conduct Organizations ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIqziwu5hD9C_-nEnN3qLaLb5_e4JWtAHkvUCTWnA8fpc2rmqA )
American Bar Association Model Code of Judicial Conduct ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIuziwtwDNZI-eQCKDzlcZP7mMg5M9aL1YHzF0FzPfRUFP8gdw )
United States Courts Ethics Policies ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIIyziwsbfOhaHfr-YTCrzJYXhvJvSiOpkLDmwO2EQ-ObdwiEfA )
United States Courts Judicial Conduct & Disability ( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBII2ziwvlKjBJ7oALxaiE1AKJNXY5urrJXZiMUeu7aI6hzrWe7g )
( Facebook.com/statecourts )
( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIM24iQtOpHasMK38_Dh78WzO2IY9sqreejHR81TgpZbPRRj3zw )
( twitter.com/statecourts )
( https://news.ncsc.org/c/AQjLzRUQzL4sGOfy74wBIM64iQtT4foYaB_qYbJoogWFfVngHlh_Jg1-SbDwFB3xKMcaGg )
Unsubscribe https://news.ncsc.org/uns/AQjLzRUQzL4sGOfy74wBetiIAWZx-DduzAgQXjAT-i9bjPa6oSpCFneGFW4x6lo
National Center for State Courts | 300 Newport Ave, Williamsburg, VA 23185