## Facts

- Clifford F. Hansen, an 88-year-old Minnesota attorney and sole practitioner, represented landlord Carl Henning in tenant litigation over a damage deposit.
- Tenants initially recovered $75 in conciliation court; the matter was removed to municipal court, and after a jury trial the tenants recovered $427, including statutory and punitive damages.
- The judgment was affirmed on further review.
- Hansen paid for polygraph examinations of Henning and Henning’s wife and concluded they were truthful; he inferred the tenants lied and that tenants’ counsel encouraged perjury.
- After the case, Hansen wrote a letter to Henning sharply criticizing the verdict and the jury’s judgment and diligence.
- Hansen sent copies of the letter to each juror, stating the jury “either lacked good judgment or were in-different to their responsibilities as sworn jurors,” and characterizing the verdict as “soaking” his client.
- A disciplinary complaint was filed; after investigation, a referee found misconduct and recommended indefinite suspension.

## Issues

1. Whether an attorney commits professional misconduct by sending jurors a postverdict letter that disparages the jury and the judicial process.
2. What discipline is appropriate for such conduct in light of the attorney’s asserted justification, prior conduct in the matter, and relevant aggravating and mitigating circumstances.

## Decision

- The Minnesota Supreme Court adopted the referee’s findings and conclusions.
- The court held that Hansen’s posttrial communication to jurors, attacking their competence and integrity, constituted professional misconduct.
- The court ordered Hansen indefinitely suspended from the practice of law in Minnesota, subject to the standard requirements governing any future reinstatement.

## Legal Principles

- Attorneys, as officers of the court, must maintain respect for the judicial process and avoid conduct that is prejudicial to the administration of justice.
- Postverdict contact with jurors that disparages, harasses, or intimidates jurors threatens the functioning of the jury system and warrants professional discipline.
- A lawyer’s belief that witnesses lied or that a verdict is unjust does not justify extra-judicial attacks on jurors; challenges must proceed through lawful procedures (e.g., motions and appeals).
- Sanctions in attorney discipline are determined by the nature and seriousness of the misconduct and any aggravating or mitigating circumstances, with a focus on protecting the public and preserving the integrity of the justice system.

## Conclusion

The court indefinitely suspended Hansen because sending jurors a disparaging letter after trial improperly attacked the jury’s role and undermined confidence in the administration of justice, and the seriousness of that misconduct justified a substantial sanction despite mitigating considerations.


In re Hansen, 318 N.W.2d 856 (Minn. 1982)