In re Dyer, No. 18-1645 (4th Cir.) November 9, 2018.

Attorney Dyer was reprimanded for failing to provide information to a state disciplinary body relating to a grievance filed against him. Dyer asserted that Maryland’s confidential grievance proceedings violate First Amendment free speech protections. Dyer made the same assertion of unconstitutionality to a federal show cause order concerning reciprocal discipline, which argument he reiterated on appeal to the Fourth Circuit. Without commenting on the merits of Dyer’s First Amendment claim, the Fourth Circuit vacated the district court order, noting that the order failed to disclose the basis on which it was entered.

In re Dyer (4th Cir., 2018)

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