## Facts

- Stephen Randall Glass, a former journalist, fabricated material in more than 40 articles published between 1996 and 1998, including false statements harming individuals and groups.
- He created false supporting materials to defeat fact-checking and attempted to avoid detection when suspicions arose.
- After exposure in 1998, he was fired and did not fully cooperate in identifying all fabrications.
- While the misconduct occurred, he was also an evening law student at Georgetown University Law Center.
- Glass applied for admission to the New York bar in 2002, but withdrew in 2004 after receiving informal notice that his moral character application would be rejected.
- In the New York process, he overstated his cooperation with publications and did not provide a complete list of fabricated articles.
- Glass passed the California bar examination in 2006 and submitted a moral character application in 2007.
- The Committee of Bar Examiners denied certification based on lack of moral character.
- After a 2010 evidentiary hearing, the State Bar Court hearing department recommended admission, crediting character witnesses, psychotherapy evidence, and Glass’s testimony.
- The State Bar Court Review Department declined to adopt that recommendation and certified the matter to the California Supreme Court.

## Issues

1. Whether an applicant with a sustained history of deliberate dishonesty and later misleading conduct carried the heavy burden of proving rehabilitation and present good moral character for admission to the California bar.
2. Whether delayed disclosures, incomplete candor in bar applications, and amends closely tied to admission efforts can be sufficient to dispel doubts about present fitness to practice law.

## Decision

- The California Supreme Court held that Glass did not carry his heavy burden to prove rehabilitation and present good moral character.
- The Court denied admission to the practice of law in California.
- The Court emphasized the seriousness, duration, and sophistication of the underlying dishonesty, and the continuation of candor problems after the misconduct was exposed.
- The Court exercised independent judgment over the admissions record and did not accept the hearing department’s recommendation on this record.

## Legal Principles

- The applicant bears the burden of proving present good moral character; where prior misconduct is grave, the burden is heavy.
- For serious dishonesty, rehabilitation generally requires sustained, exemplary conduct over an extended period sufficient to dispel reasonable doubts about present fitness.
- Full candor with bar authorities is a central component of moral character; misleading statements or omissions in admissions processes weigh strongly against a finding of rehabilitation.
- In character determinations, protection of the public, the courts, and the legal profession is the controlling consideration, not the applicant’s personal interest in admission.
- The California Supreme Court retains ultimate responsibility for admissions decisions and reviews the record independently.

## Conclusion

Because Glass’s extensive pattern of fraud, his efforts to evade detection, and later incomplete candor in bar-admission contexts left unresolved doubts about his present honesty and reformation, the California Supreme Court concluded he had not proven the requisite moral character and denied admission.


In re Glass, 58 Cal. 4th 500, 316 P.3d 1199 (Cal. 2014)