Wyoming’s Supreme Court found no published precedent in the state on the reinstatement of an attorney after transfer to disability inactive status, so instead consulted several other state courts to conclude that “clear and convincing” evidence of recovery is required.

A Wyoming attorney who was identified as “Attorney Doe” by the state supreme court, sought reinstatement of his license to practice law after a period of disability inactive status, according to the opinion. The Board of Professional Responsibility (BPR) recommended that the court deny that request.

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