## Facts

- William R. Eddleman, a Seattle attorney, represented Anton R. Johansen regarding creditor claims and liens against Johansen’s commercial airplane located at Boeing Field.
- The airplane had been idle for an extended period, needed significant repairs, and was encumbered by substantial liens relative to its value.
- Eddleman proposed a plan under which Johansen would transfer legal title to Eddleman; Eddleman would use the aircraft and his credit to raise funds, pay creditors, repair the plane, and charter it.
- Under the plan, charter income would repay Eddleman’s advances and expenses and include an additional fee, after which the plane would be returned to Johansen.
- The parties never reduced the arrangement to writing; Johansen expressed concern about transferring title without documentation preserving his interest, and another attorney advised memorializing the agreement.
- Eddleman refused to document Johansen’s interest, asserting he needed to avoid creating a document that creditors could use to reach the asset.
- In litigation brought by an unpaid creditor, Eddleman repeatedly testified under oath that no agreement existed with Johansen concerning the plane, despite the prior arrangement.
- Across multiple related disputes, Eddleman gave inconsistent accounts, alternately denying any agreement and characterizing the transaction as an outright sale.
- Johansen demanded an accounting and return of the aircraft; Eddleman asserted outright ownership, then later returned the plane only after Johansen agreed to pay a substantial attorney-fee amount.
- The Washington State Bar Association charged Eddleman with breach of fiduciary duty, dishonesty and corruption, and repeated false swearing in judicial proceedings.

## Issues

1. Whether Eddleman’s acquisition and control of a client’s principal asset, coupled with refusal to document the client’s retained interest, violated fiduciary and professional duties.
2. Whether Eddleman’s repeated false and contradictory sworn statements about the transaction constituted professional misconduct warranting severe discipline.
3. What sanction was appropriate given the nature, duration, and impact of the misconduct.

## Decision

- The Washington Supreme Court rejected the Board of Governors’ recommendation of a one-year suspension with reprimands.
- The court found Eddleman engaged in serious misconduct involving breach of duty to a vulnerable client and repeated dishonest sworn testimony.
- The court ordered disbarment and directed that Eddleman’s name be stricken from the roll of attorneys.

## Legal Principles

- An attorney entering a transaction involving a client’s property while providing related legal services bears strict fiduciary obligations, including loyalty, fair dealing, and full disclosure.
- Structuring a client-property arrangement to leave the client without written protection of an equitable interest is inconsistent with fiduciary duty, especially where the lawyer’s financial interests conflict with the client’s.
- Intentional false swearing and dishonest testimony by a lawyer in judicial proceedings is incompatible with the role of an officer of the court and may justify disbarment.
- The state supreme court independently determines attorney-discipline sanctions and may impose a penalty more severe than that recommended by bar authorities to protect the public and the administration of justice.

## Conclusion

The court disbarred Eddleman after concluding that he exploited a conflicted, undocumented client-property arrangement and repeatedly gave false sworn testimony about it, demonstrating unfitness to practice law and threatening confidence in the courts and the profession.


In re Eddleman, 389 P.2d 296 (Wash. 1964)