New Mexico attorney Michael E. Cain was issued a formal reprimand for his conduct during a hearing by telephone during which he argued the judge could not be impartial for what he called their "ongoing conflict" and that she should recuse herself.

State District Court Judge Lisa C. Schultz filed a complaint with the Disciplinary Board of the Supreme Court of the State of New Mexico based on Cain's appearance in a child custody visitation matter on July 13, 2020. The client began by requesting a continuance so that her recently-hired attorney, Cain, could appear. Although the client retained Cain, he had not yet entered an appearance.