DBHAWAII April 24, 2003

Does the no-contact rule apply to a lawyer who is representing himself and the opposing party has counsel?

Short answer: The opinion concluded that a lawyer who is a party proceeding pro se is still bound by HRPC 4.2 and cannot communicate directly about the subject of the representation with another person known to be represented by counsel without that lawyer's consent or authorization by law or court order.

Apply this to your situation

This page answers the general question as of 2003. Ezel answers yours: whether it's allowed on your facts, under the current Hawaii Rules of Professional Conduct, with citations.

Currency note: this opinion is from 2003
Subsequent statutory amendments, court decisions, or later opinions or rule amendments may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.
Disclaimer: Advisory only. Not binding precedent.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official ethics opinion. The original opinion (linked on this page as a PDF) is the authoritative source for any reliance.
View original ethics opinion (PDF)

Plain-English summary

The opinion addressed whether an attorney proceeding pro se is precluded by HRPC 4.2 (communication with a person represented by counsel) from communicating directly with a person represented by counsel.

The opinion concluded that a lawyer who is a party in a matter and is proceeding pro se cannot communicate directly about the subject of the representation with another person known to be represented by counsel in the matter, without first obtaining consent from the other person's lawyer or being authorized to do so by law or a court order.

In practice

Under this opinion, a Hawaii lawyer who represents himself or herself as a party does not escape HRPC 4.2 by appearing pro se; the opinion holds that such a lawyer must still get the consent of the represented person's counsel (or rely on authorization by law or court order) before communicating directly with that person about the subject of the matter.

Common questions

Q: Does the no-contact rule apply when a lawyer represents himself?

A: Yes. The opinion concluded that a lawyer who is a party proceeding pro se is bound by HRPC 4.2 and cannot communicate directly with a represented person about the subject of the matter.

Q: How can the pro se lawyer communicate with the represented party?

A: Per the opinion, the lawyer must first obtain consent from the other person's lawyer, or be authorized to communicate by law or a court order.

Background and rules framework

The opinion interprets HRPC 4.2, the rule barring a lawyer from communicating about the subject of a representation with a person the lawyer knows to be represented by another lawyer, absent that lawyer's consent or legal authorization. It corresponds to Model Rule 4.2.

Citations and references

Rules of Professional Conduct (Hawaii; cf. Model Rules):

  • HRPC 4.2 (communication with a person represented by counsel) (cf. Model Rule 4.2)

See also

Source

Original opinion text

Best-effort transcription from a scanned PDF. Minor errors may remain; the linked PDF is authoritative.

Office of Disciplinary Counsel
Supreme Court, State of Hawaii
1132 Bishop Street, Suite 300
Honolulu, Hawai'i 96813
Telephone (808) 521-4591

FORMAL OPINION NO. 44
(Pro Se Communication)

This Opinion addresses the issue of whether an attorney proceeding pro se is precluded by HRPC 4.2 (Communication with Person Represented by Counsel) from communicating directly with a person represented by counsel. A lawyer who is a party in a matter and is proceeding pro se cannot communicate directly about the subject of the representation with another person known to be represented by counsel in the matter without first obtaining consent from the other person's lawyer or is authorized to do so by law or a court order.

DATED: Honolulu, Hawai'i, April 24, 2003.

Carroll S. Taylor
Chairperson, Disciplinary Board

Carole R. Richelieu
Chief Disciplinary Counsel

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