Ryan v. Astra Tech, Inc., No. 13-2251 (1st Cir. 2014)Annotate this Case
During the underlying litigation, Attorney Jeffrey Ryan, counsel for the plaintiff, attempted to engage in allegedly surreptitious communication with his client while a question was pending at a deposition. The district court granted Defendants’ motion for discovery sanctions, concluding that Ryan did indeed attempt to communicate surreptitiously with his client, that Ryan manufactured false evidence, and that Ryan lied to the court. The court ordered Ryan to pay monetary sanctions and directed him to show cause why it should not revoke his permission to practice pro hac vice for the plaintiff for flagrant violations of the Massachusetts Rules of Professional Conduct. After considering Ryan's response and conducting a de novo review of the entire record, the district court again found that Ryan lied to the court and opposing counsel and submitted false evidence and issued an order revoking Ryan’s pro hac vice admission. The First Circuit affirmed the orders revoking Ryan’s pro hac vice admission and imposing monetary sanctions, holding that the court did not abuse its discretion in issuing the sanction for Ryan’s misbehavior.