DCBAR October 31, 1996

Can a lawyer volunteer for the D.C. Corporation Counsel while also representing private clients against the City, and oppose the same agency she works for?

Short answer: The opinion concluded that, under the Rules of Professional Conduct, a lawyer may volunteer for the D.C. Corporation Counsel and continue representing private clients against the City, subject to Rule 1.7. Reconsidering Opinion 92, it held that the old absolute bar on opposing the same agency one works for (rooted in the discarded 'appearance of impropriety' standard) no longer applies; a lawyer may oppose her own City agency client in an unrelated matter with the informed consent of both clients. Only same-matter direct adversity is non-waivable. The government client may be a single agency rather than the whole City, so opposing a different, non-client agency may need no consent under Rule 1.7(b)(1), though Rule 1.7(b)(2)-(4) may still require it.

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This page answers the general question as of 1996. Ezel answers yours: whether it's allowed on your facts, under the current rules of professional conduct in your state, with citations.

Currency note: this opinion is from 1996
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 Not binding precedent.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) is the authoritative source for any reliance.

Plain-English summary

Opinion 268 (adopted October 31, 1996) reconsidered two conditions from Opinion 92 (1980), which had approved, under the former Code of Professional Responsibility, a program in which private attorneys volunteered to help the City manage its crowded civil docket. The intervening 1991 adoption of the D.C. Rules of Professional Conduct prompted the question whether those conditions still held.

The committee's central change concerned Opinion 92's absolute prohibition: that a lawyer could never volunteer for a particular City agency while handling a private matter against that same agency, or a "closely related" matter, even with client consent. The committee explained that this flat bar had been derived from the "appearance of impropriety" standard of former Canon 9, which the Rules of Professional Conduct dropped entirely. Under the current rules, conflicts are generally waivable; the only conflict that cannot be cured by consent is taking adverse positions for two clients in the same matter (Rule 1.7(a)). So the committee concluded that a lawyer may represent a private client against a City agency while simultaneously representing that same agency in an unrelated matter, provided both the private client and the agency are informed of the conflict and consent under Rule 1.7(b)(1) and (c). The committee stressed that whether the lawyer volunteers or is paid is irrelevant to the analysis.

The committee also rejected Opinion 92's assumption that the entire City and all its agencies must always be treated as one client. Drawing on Rule 1.2's client-autonomy principles, it concluded that the identity of the government client is established in the first instance between the lawyer and responsible government officials, and may be a single constituent agency rather than the City as a whole. Where the lawyer opposes a different agency that is not her client, Rule 1.7(b)(1) is not triggered and client notice and consent are not required on that basis. But the committee cautioned that Rule 1.7(b)(2)-(4) may still require consent if the lawyer's representation of one client would be, or likely would be, adversely affected by the other representation, or if her independent professional judgment would be affected by duties to third parties or her own interests. The lawyer must respect each client's reasonable expectation, protected by Rule 1.7, of a conflict-free representation.

Currency note

This opinion was issued in 1996, before the District of Columbia's adoption of the 2007 revisions to the Rules of Professional Conduct. Subsequent rule amendments or later opinions may have changed the analysis. Treat this page as historical context, not current guidance. Verify against current rules before relying on any specific rule, deadline, or requirement mentioned here.

Common questions

Q: Can a lawyer volunteer for the City and still sue the City for private clients?

A: Yes, subject to Rule 1.7. The committee concluded that a lawyer may give volunteer assistance to the Corporation Counsel and continue representing private clients against the City, with conflicts handled under Rule 1.7.

Q: Can the lawyer oppose the very agency she volunteers for?

A: In an unrelated matter, yes, with consent. The committee concluded that the old absolute prohibition is gone, so a lawyer may oppose her own City agency client in an unrelated matter if both clients are informed and consent under Rule 1.7(b)(1) and (c).

Q: Is the City always treated as a single client?

A: No. The committee concluded the government client may be a single constituent agency rather than the whole City, so opposing a different agency that is not the lawyer's client does not trigger Rule 1.7(b)(1).

Q: Is consent ever still required when opposing a non-client agency?

A: Possibly. The committee concluded that even where Rule 1.7(b)(1) does not apply, Rule 1.7(b)(2)-(4) may require consent if one representation would adversely affect the other or the lawyer's independent judgment.

Background and rules framework

The opinion interpreted D.C. Rule 1.7 (conflicts of interest, including the non-waivable same-matter bar of Rule 1.7(a), the own-client conflict of Rule 1.7(b)(1), and the material-limitation conflicts of Rule 1.7(b)(2)-(4)) together with Rule 1.2 (scope of representation and client autonomy in defining the client). It reconsidered Opinion 92 in light of the 1991 Rules' elimination of the "appearance of impropriety" standard.

Citations and references

Rules of Professional Conduct:

  • D.C. RPC 1.7 / Model Rule 1.7 (conflicts of interest; waivability; government-client conflicts)
  • D.C. RPC 1.2 / Model Rule 1.2 (scope of representation; defining the client)

Other opinions cited:

  • D.C. Ethics Op. 92 (1980) (reconsidered and modified by this opinion)

See also

Source

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