## Facts

- Gary Lane sought readmission to the Nebraska bar after previously being admitted to practice law but no longer holding active Nebraska membership.
- The Bar Commission of the Nebraska State Bar Association investigated Lane’s present character and fitness as part of the readmission process.
- The Commission found Lane had engaged in hostile and disruptive behavior while in a law-school clinical program, including statements female professors took as threats.
- Lane told a female professor she was the type of woman who did not know how to deal with men and was intimidated by them, and he said he would not work with female students.
- Lane exhibited paranoid behavior, claiming others were talking about him and conspiring against him; he acknowledged being accused of auditory hallucinations but denied the accusation was true.
- A second major incident occurred during a bar-review course, where Lane accused another student of stealing his keys and made threats.
- Lane was described as abrasive toward other students during bar-review sessions and claimed people were against him because of racial animosity.
- Additional concerns arose from interactions with staff and workers, including rude and intimidating remarks; several events involved women, and Lane admitted he had a recurring problem of being accused of acting intimidating toward women.
- During the Commission’s investigation and hearing, Lane’s correspondence and responses were described as cavalier, sarcastic, and discourteous, and he suggested Commission members had personal or political motives against him.
- The Commission also found Lane lacked candor on his application by omitting temporary employment and failing to disclose prior bar admissions, including admission in Iowa and even his earlier admission in Nebraska.
- The Bar Commission denied readmission, and Lane sought review of that denial in the Nebraska Supreme Court.

## Issues

1. Whether Lane met his burden to prove he presently possessed the good moral character and fitness required for readmission to the Nebraska bar.
2. Whether Lane’s omissions and incomplete disclosures on the readmission application showed a lack of candor sufficient to deny readmission.
3. Whether Lane’s pattern of hostile, threatening, and disruptive conduct—together with his demeanor during the investigation—supported the Commission’s decision to deny readmission.

## Decision

- The Nebraska Supreme Court affirmed the Bar Commission’s denial of Lane’s application for readmission.
- The court concluded Lane did not carry his burden to establish present character and fitness to practice law.
- The court agreed the record supported the Commission’s concerns about Lane’s lack of candor in the application process.
- The court also agreed that Lane’s repeated hostile and threatening behavior, including conduct directed toward women and toward the Commission during the investigation, weighed against readmission.

## Legal Principles

- An applicant for bar readmission bears the burden to prove present good moral character and fitness to practice law.
- Candor in the admissions process is required; omissions or misleading answers on a bar application may justify denial of admission or readmission.
- A demonstrated pattern of threatening, hostile, or disruptive conduct is relevant to fitness to practice law and may support denial of readmission.
- The supreme court retains final responsibility for bar admissions and, on review, may uphold a commission’s denial when the record supports findings of insufficient character and fitness.

## Conclusion

The Nebraska Supreme Court upheld denial of Gary Lane’s readmission because the record supported findings that he lacked the required present character and fitness, shown by significant omissions on his application and a continuing pattern of hostile, threatening, and disruptive conduct, including disrespectful behavior during the Commission’s investigation and hearing.


Lane v. Bar Commission of the Nebraska State Bar Association, 544 N.W.2d 367 (1996)