Attorney Nicholas Tepper (State Bar Number 169610) of Laguna Beach, California, has been handed the ultimate professional penalty: permanent disbarment from the practice of law. Effective September 28, 2025, the disbarment was imposed not for new client misconduct, but for a severe failure to comply with a mandatory administrative requirement stemming from a prior disciplinary order.
Tepper’s case is a stark warning that compliance with the administrative requirements of the State Bar and the courts is non-negotiable, and willfully failing to adhere to California Rules of Court, rule 9.20 can be a career-ending offense, especially for an attorney with a disciplinary history.
The Core Violation: Failure to File Rule 9.20 Declaration
Tepper’s disbarment (Case No. 24-N-30747) was based on a single, critical violation:
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The Mandatory Affidavit: Following an earlier disciplinary order that included an actual suspension, Tepper was required to file a sworn affidavit—known as a Rule 9.20 compliance declaration—with the State Bar Court. This declaration is a public protection mechanism, where the disciplined attorney must affirm under penalty of perjury that they have:
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Notified all clients in pending matters, opposing counsel, and courts of their suspension via registered or certified mail.
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Delivered all client files and property, or made arrangements for their retrieval.
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Refunded any unearned fees to clients.
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Consequence of Non-Compliance: Tepper failed to file this crucial declaration. The State Bar Court has consistently ruled that a willful failure to comply with Rule 9.20 is grounds for disbarment or suspension and for revocation of any pending probation.
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Default Judgment: The disbarment was entered by default because Tepper failed to participate in the disciplinary proceeding against him, leading the State Bar Court to deem the charges of non-compliance as admitted.
Prior History Led to Finality
The severity of the disbarment was heavily influenced by Tepper’s extensive prior disciplinary history:
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Prior Misconduct: Tepper had a prior record of discipline, which included a suspension in 2023 for grossly negligent moral turpitude, unauthorized practice of law, and abandonment of clients across four client matters.
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The Fatal Link: Because his prior discipline was so severe, the failure to comply with Rule 9.20—an act of non-cooperation and a breach of his duty to protect clients after the initial misconduct—was viewed as the final, unforgivable act, warranting the permanent loss of his license.
The Final Sanction: Permanent Disbarment
The State Bar Court determined that the combination of severe prior misconduct and the failure to comply with the mandatory protective measure of Rule 9.20 justified the ultimate penalty:
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Permanent Disbarment: The final order is disbarment, permanently removing him from the practice of law in California.
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Effective Date: The disbarment became effective on September 28, 2025.
The ruling sends a powerful message that attorneys must take administrative compliance seriously, especially when under disciplinary supervision.
Conclusion: Compliance is Public Protection
The disbarment of Nicholas Tepper underscores a crucial element of professional regulation: Administrative non-compliance, particularly the failure to satisfy a Rule 9.20 declaration after a suspension, is a fatal professional flaw.
The State Bar relies on Rule 9.20 to protect the public by ensuring that suspended attorneys properly wind down their practice and that their clients are not abandoned. For Nicholas Tepper, his wilful failure to comply, combined with his prior record of misconduct, resulted in the permanent loss of his license.
