Court: Arizona Supreme Court; July 6, 1983; Arizona; State Supreme Court
Edward Ronwin graduated from the College of Law at Arizona State University in January 1974 and subsequently took the bar exams in Arizona and Iowa, passing in Iowa but failing in Arizona. He was admitted to the Iowa Bar in June 1974 and remains in good standing. Ronwin's petitions for a review of his Arizona exam grading were denied by both the Committee on Examinations and Admissions and the Arizona Supreme Court, with certiorari denied by the U.S. Supreme Court.
In July 1974, Ronwin sought permission to retake the Arizona bar exam but was denied due to concerns about his mental fitness, as he did not meet the requirement of being "mentally and physically able" under Rule 28(c)(IV). A special committee was appointed to investigate allegations of his mental unfitness, finding that Ronwin had a personality disorder characterized by unreasonable suspicions and a tendency to make unfounded accusations. The committee concluded that his mental state would hinder his ability to practice law responsibly, and thus did not recommend him for admission.
Ronwin's petitions for review of the committee's findings were unsuccessful, and his requests to take the bar exam from 1977 to 1980 were also denied. In October 1981, the court allowed him to take the February 1982 bar exam while reserving the issue of his fitness. Ronwin failed part of that exam but passed the July 1982 exam. His current applications for admission have not been referred back to the committee.
The court holds ultimate responsibility for admitting candidates to the practice of law, as established in previous cases. In the current matter, Ronwin was allowed to support his application with a psychiatrist's report and agreed to undergo further examinations by court-appointed mental health professionals. The court referred the fitness question to Judge Paul LaPrade, who was tasked with conducting a hearing and reporting back. Ronwin and his counsel later agreed to submit the matter based on existing records without a hearing. However, Ronwin later sought to withdraw this stipulation, claiming it unduly restricted the master’s review, but this request was denied.
The master ultimately determined that Ronwin was not mentally fit for practice, although he considered documents outside the agreed-upon parameters. The court struck these extraneous materials from the report and decided against relying on the master’s findings due to their basis in evidence not included in the stipulation. The court emphasized its obligation to conduct an independent review of the record, as the practice of law is a right subject to regulation ensuring applicants possess the necessary qualities. This independent review allows the court to consider a broader scope of evidence than the master could under the stipulation. The court notified Ronwin of its decision to strike the master’s report and confirmed that its review would encompass relevant records from both its files and certain specified federal cases.
The applicant was permitted to submit a memorandum addressing the procedure and issues from the April 27 order, along with any factual evidence via affidavit or offer of proof. In response, the applicant filed a document titled 'Motion Concerning Order of April 27, 1983.' An independent review was conducted, during which expert medical opinions were evaluated. Dr. Taylor, a psychiatrist, found no current mental illness in the applicant, Ronwin, although he noted personality traits that may be viewed negatively by opponents. Dr. Taylor suggested that these traits might not hinder Ronwin's legal practice capabilities. Both a psychiatrist and psychologist appointed for an independent examination diagnosed Ronwin with a 'compulsive personality disorder' as per DSM III criteria. The psychologist indicated that this disorder would not necessarily impair Ronwin’s compliance with professional rules and ethics, and the psychiatrist affirmed Ronwin's ability to adhere to professional conduct standards.
The review acknowledged that Ronwin's compulsive personality disorder was characterized by traits such as overzealousness, paranoid attitudes, inflexibility, hypersensitivity, perfectionism, obsessive detail orientation, suspicion, and hostility. The evaluation considered whether these traits could significantly impair Ronwin's conduct as a lawyer. While the medical professionals deemed him capable, it was necessary to assess if his behavioral traits negatively impacted his ability to practice law at an acceptable standard.
Following a previous decision, Ronwin initiated several legal actions against members of the Arizona State Bar, alleging a conspiracy to block his admission. He filed various civil rights actions against members of the special committee overseeing his mental competency, the attorneys involved, and witnesses, including law school officials. Additionally, he pursued an antitrust action against the Supreme Court Committee on Examinations and Admissions and filed further civil rights actions against other related parties, including previous attorneys and court members.
Ronwin initiated a fifth civil rights action against several defendants, including a new federal judge, the Clerk of the United States District Court, and an Assistant United States Attorney, alongside members of the court. He also filed an action against a University of Arizona law student who wrote a casenote regarding a previous case, naming additional defendants including law review editors and members of the Arizona Board of Regents. These actions stem from his denial of admission to the Arizona Bar and may relate to alleged religious harassment he experienced from 1972-1974 at Arizona State University.
The document emphasizes that while lawyers have the right to express outrage and seek litigation in good faith, they cannot engage in vexatious or harassing legal actions. Arizona's legal ethics, aligned with the Model Code of Professional Responsibility, prohibit undignified conduct towards a tribunal, making false accusations against judges, and filing scandalous or frivolous claims. Lawyers must demonstrate restraint and ensure their actions are legally supported. Violating these principles can result in denial of admission to the bar. The examination of Ronwin's filings indicates that his personality disorder adversely impacts his conduct, leading to unsubstantiated allegations against various participants in his legal proceedings.
Accusations against the dean and assistant dean of the law school involve not merely legal errors but allegations of knowing misconduct and misfeasance, particularly concerning anti-Semitic behavior and participation in a fraudulent scheme to prevent Ronwin from entering the bar. Ronwin claims that the defendants manipulated judicial processes, including securing a favorable ruling from a district court judge who was friends with the defendants' lawyers, leading to the tolerance of criminal behavior. Furthermore, he alleges the Clerk of the United States District Court conspired against him by altering procedures to assign his case to a sympathetic judge, and he criticizes an Assistant United States Attorney for defending the judge instead of prosecuting him.
In separate proceedings, Ronwin asserts that other judges and members of the Arizona State Bar engaged in illegal activities and colluded to distort court decisions, including accusations of perjury and conspiracy against him by various legal representatives and bar officials. He claims that his counsel previously participated in this conspiracy. Ronwin’s filings allege widespread misconduct involving numerous judges and court officials, suggesting a systemic issue of corruption.
Additionally, Ronwin expresses that his treatment mirrors the persecution faced by Jews during the Holocaust, indicating a perceived bias against him for his stance against anti-Semitism. His derogatory remarks about the law school dean and accusations of record tampering by court clerks reflect a pattern of behavior deemed inappropriate for a lawyer. The document concludes that Ronwin's response to adversity cannot warrant special treatment, emphasizing that all bar members are held to the same standards of conduct.
Habitual litigation against adjudicatory officers, witnesses, and opposing counsel is characterized as vexatious, harassing, and intended to intimidate. Such behavior undermines the ability to resolve legal disputes in a civilized manner and diminishes public respect for the judiciary and legal profession. Attorneys must conduct themselves with care and respect in court, as turbulent or irresponsible behavior can justify denial of admission to the bar.
Ronwin asserts a First Amendment right to express himself freely. While this right is acknowledged, it is emphasized that it should not extend to courtroom conduct, where accuracy and restraint are paramount. The court references the case of Application of Levine, where a candidate's criticism of a federal agency did not preclude his admission to the bar, highlighting the essential distinction between public discourse and courtroom decorum. The court recognizes Ronwin's belief in a conspiracy against him, a recurring theme in his civil rights claims, but maintains that legal statements must be factually grounded and measured.
Ronwin's belief in a conspiracy against him does not meet the standards required for practicing law, which necessitates the ability to distinguish between fact and fantasy. His behaviors, characterized by verbal abuse and unfounded accusations, exceed occasional outbursts and indicate a persistent pattern of unreasonable reactions to adversity. This conduct is inconsistent with the expectations of restraint and self-discipline necessary for legal professionals, as it threatens the integrity of judicial proceedings. The focus is not on Ronwin's First Amendment rights but on his lack of responsibility, which disqualifies him from practicing law.
Ronwin has requested an evidentiary hearing to defend the validity of his allegations against judges and others. However, the decision asserts that such a hearing is unnecessary. The previous medical reports and testimonies he wishes to present are outdated and do not conflict with more recent evaluations. Furthermore, the court will not deny admission solely based on his civil rights complaints, but will deny it due to his persistent filing of vexatious lawsuits lacking legal merit, demonstrating that his emotional responses have overshadowed his legal understanding. This assessment is supported by the records of the United States District Court for the District of Arizona regarding the outcomes of his cases.
Ronwin's potential grounds for suing members of the bar and bench for misconduct do not justify the use of derogatory language in legal pleadings. It is possible to raise claims of civil rights violations or conspiracy without resorting to insults. The court finds that Ronwin's actions, particularly against the author of a law review casenote, are harassing and lack legal merit, as established in previous cases. His disrespectful language towards the judiciary is noted as inappropriate. Despite being allowed to submit relevant evidence, Ronwin only provided additional medical reports. The court determined that an evidentiary hearing is unnecessary because Ronwin's allegations imply a broad conspiracy by the judiciary to undermine his right to practice law, rather than addressing specific wrongful acts by individual judges or attorneys. The court emphasized that such claims should be addressed in an appropriate forum. Additionally, recusal issues arise since one judge has already recused himself due to personal involvement, leaving only four judges, all of whom have been sued by Ronwin. The court asserts that judges should not be disqualified solely because they have been sued, as this would enable abuse of the disqualification process.
Ronwin has failed to demonstrate his mental fitness to practice law, evidenced by his history of filing numerous unwarranted legal actions against individuals associated with his unsuccessful attempts to gain admission to the Arizona Bar. Despite previous indications of reluctance to criticize Ronwin for pursuing what he believed were legitimate claims, the sheer volume of actions, their dismissals, and targeting of individuals only tangentially related to his grievance indicate a pattern of irresponsible behavior. His refusal to accept the conclusions of prior adjudications, combined with the filing of vexatious and harassing lawsuits, provides sufficient grounds for denial of his application.
Additionally, Ronwin’s use of inflammatory language, lack of civility, and tendency to vilify opponents are deemed unprofessional and further justify the rejection of his admission. Previous case law noted that whether his incapacity stems from ignorance of legal conduct rules or an emotional or philosophical inability to modify his behavior, his actions reflect an unfitness to practice law. The record substantiates that Ronwin lacks essential qualities such as responsibility, fairness, and respect for the judicial system. Consequently, his application for bar admission is denied, with the possibility of reapplication contingent upon his ability to demonstrate control over his conduct that aligns with the expected standards for attorneys. The decision was supported by Chief Justice Holohan and Justices Hays and Cameron, while Vice Chief Justice Gordon recused himself from the proceedings.
In Ronwin v. von Ammon (von Ammon II), the case, filed on April 18, 1980, was dismissed on July 18, 1980, against District Court Judges for being "totally frivolous and vexatious," and against several other defendants for failure to state a claim. On January 28, 1981, additional dismissals occurred against the Clerk of District Court and the United States Attorney for similar reasons, while the claims against Supreme Court Justices were dismissed due to a lack of credible evidence of conspiracy and issues of subject matter jurisdiction. Attorneys' fees were awarded to some defendants. The cases von Ammon I and II were consolidated on appeal and affirmed by the Ninth Circuit (688 F.2d 848, 1982).
In a separate case, Ronwin v. Shapiro, filed on March 29, 1979, a defamation action was dismissed on January 25, 1980, and affirmed by the Ninth Circuit (657 F.2d 1071, 1981), with the court ruling against the Arizona Board of Regents and dismissing claims against an author and editor under privilege for fair reporting of judicial proceedings.
On May 23, 1981, Ronwin wrote to the Chief Judge of the U.S. District Court for Arizona, commenting on the federal court proceedings in the von Ammon cases. He accused counsel for the state bar of lying about a witness's testimony in official court proceedings, claiming the counsel's statements were unjustified and scandalous. Ronwin expressed outrage over the alleged dishonesty of counsel and questioned the court's tolerance of such behavior, seeking a response to his concerns regarding the perceived protection of unethical attorneys within the federal court system.
Concerns are raised regarding the integrity of the Arizona State Bar and the necessity for impartial legal application, urging resignation if this cannot be achieved. A psychiatric evaluation of the individual reveals several key characteristics:
1. He is sensitive and insecure in relationships.
2. Exhibits aggressive determination and obsessive preoccupation with perceived slights, possibly as a defense mechanism for his insecurities.
3. Holds an inflated view of his own abilities, which is partially justified by his intelligence and work ethic, yet may also stem from his interpersonal insecurities.
4. Lacks tolerance for dissent and is outspoken in his opinions.
5. Displays self-righteousness and grandiosity regarding his personal significance.
6. Maintains secrecy about his personal life, indicative of a general suspiciousness towards others.
7. While not violent, he reacts aggressively to perceived attacks, both verbally and through institutional channels, including legal means.
8. His technical and legalistic approach to problems can appear hostile and guarded, hindering casual interactions and leading to unanticipated confrontations.
9. Such traits likely result in animosity and counter-hostility from colleagues, creating a cycle of negative interpersonal relationships.
Recommendations suggest that his behavior may provoke negative reactions from colleagues and clients, leading to frequent legal disputes. Nonetheless, he possesses qualities that could ensure adequate functioning in professional roles, including intelligence, integrity, and motivation, although his judgment may be compromised by emotional biases.
The characteristics previously outlined do not justify recommending the exclusion of Ronwin from practicing his profession, for which he is trained. Reference is made to the supreme court rules, with SB-52-8 pertaining to Ronwin’s successful application to take the 1982 bar examination and SB-52-9 related to his application for admission post-examination. Ronwin contended that his waiver of an evidentiary hearing was contingent on a review based solely on written medical reports and the existing records of SB-52-8 and SB-52-9. Under Ariz.R.Evid. 201(b), the court acknowledges the existence and allegations in these cases without confirming their truthfulness beyond final judgments. Appendix A contains relevant actions filed by Ronwin.
A footnote discusses how Ronwin's hypersensitivity and aggressiveness exacerbate typical negative reactions individuals may have toward him. Dr. Gray's December 23, 1974 report found no evidence of serious mental illness in Ronwin but suggested a potential personality disorder, noting that his traits do not warrant exclusion from practice on psychiatric grounds. Dr. Barnes provided a detailed personality assessment, which Ronwin requested to be considered, despite its age and the court's reluctance to rely on it. Long-standing issues were recognized. Additionally, Ronwin has named members of the court and attorneys as defendants in a separate federal lawsuit. Mr. von Ammon, a respected member of the Arizona Bar, is involved in this litigation as counsel for the State Bar and the court, highlighting the unpleasant nature of the cases he has taken on.
