In re Snyder

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In re Snyder is a 1985 U.S. Supreme Court case about whether a lawyer’s rude letter to a court employee, and his refusal to apologize, could justify suspending him from practicing law in federal court.

The facts: Robert J. Snyder, a criminal defense attorney in Bismarck, North Dakota, handled indigent cases paid for by the Criminal Justice Act (CJA). When he submitted a request for CJA compensation that exceeded $1,000, the Eighth Circuit’s chief judge reviewed it. The secretary of the judge who handled the case told Snyder his documents were insufficient. Snyder then wrote a sharp letter to the district court secretary criticizing the CJA system and saying he would not provide more paperwork. He also told the secretary to take his name off the list of lawyers who accept CJA assignments and stated he was not satisfied with how he had been treated.

The reaction: The judge who received the letter viewed it as disrespectful and forwarded it to the chief judge. The chief judge ordered Snyder to explain why he shouldn’t be suspended. Snyder refused to apologize, though he said he would be willing to accept CJA work under a revised plan. A three-judge panel of the Eighth Circuit suspended Snyder from practicing in the Eighth Circuit and in the District of North Dakota for at least six months, unless he apologized within ten days. Snyder did not apologize, and the suspension took effect. He asked the Supreme Court to review the decision, arguing First Amendment and due process rights were violated and that the punishment was too harsh.

The Supreme Court’s ruling: The Court, led by Chief Justice Warren Burger, reversed the suspension. The decision was unanimous among the participating justices (Justice Blackmun did not take part). The Court held that Snyder’s conduct did not provide a proper basis to suspend him under Rule 46 of the Federal Rules of Appellate Procedure. The Court explained that it could decide the case on non-constitutional grounds, so it did not need to address First Amendment or due process issues.

Key point: Courts have the power to discipline lawyers for conduct unbecoming a member of the bar, but criticizing the administration of the Criminal Justice Act or complaints about how assignments are made do not, by themselves, justify suspension. Snyder’s letter and refusal to apologize did not show the kind of unfitness that would warrant discipline in this case. The suspension was reversed, and Snyder was allowed to continue practicing in federal court.