The Oklahoma Supreme Court dismissed disciplinary proceedings against attorney Jason Martin Lile on Monday, refusing to impose additional sanctions despite his suspension from practicing before tribal courts. The decision highlights the complex jurisdictional issues surrounding attorney discipline across state and tribal legal systems.
Lile, a lawyer licensed to practice in Oklahoma, received a one-year suspension of his license to practice law before the Muscogee (Creek) Nation. The tribal court suspension prompted the Oklahoma Bar Association to invoke Rule 7.7 of the Oklahoma Rules Governing Disciplinary Proceedings, which addresses reciprocal discipline for attorneys sanctioned in other jurisdictions.
Under Rule 7.7, when an attorney faces discipline in another jurisdiction, the Oklahoma Bar Association can seek parallel disciplinary action in state courts. The rule is designed to maintain consistency in professional standards and prevent attorneys from simply avoiding consequences by practicing in different jurisdictions.
Following standard procedure, the Oklahoma Bar Association filed documentation of Lile's suspension by the Muscogee (Creek) Nation Supreme Court with the Oklahoma Supreme Court. The state's highest court then directed Lile to show cause why a final order of discipline should not be imposed against him by the Oklahoma court system.
The procedural posture of the case reflects the careful balance courts must strike when dealing with reciprocal discipline. Lile responded to the show cause order by requesting that no further discipline be imposed and that no hearing be conducted. His position was that the tribal court suspension was sufficient and that additional state discipline would constitute double jeopardy in the professional context.
The Oklahoma Bar Association took the opposite position, requesting that the Oklahoma Supreme Court impose identical discipline and suspend Lile's Oklahoma bar license for one year. The Bar's position reflected the traditional approach to reciprocal discipline, where sanctions in one jurisdiction typically trigger parallel sanctions in others where the attorney is licensed.
After conducting what the court characterized as a "de novo review" of the matter, the Oklahoma Supreme Court reached a conclusion that diverged from the Bar's recommendation. The court found that no further discipline was warranted beyond what Lile had already received from the tribal court system.
The court's decision to dismiss the disciplinary proceeding represents a nuanced approach to the intersection of state and tribal jurisdiction over attorney conduct. While the opinion does not detail the specific reasoning behind the dismissal, the outcome suggests the court considered factors beyond simple reciprocity in making its determination.
This case illuminates the complex relationship between state bar authorities and tribal court systems in regulating attorney conduct. Native American tribes maintain their own court systems with jurisdiction over legal matters within their territories, including the authority to license and discipline attorneys practicing before their courts.
The Muscogee (Creek) Nation operates one of the more sophisticated tribal court systems in Oklahoma, with its own supreme court and established procedures for attorney discipline. The nation's legal system handles a wide range of civil and criminal matters, requiring attorneys who practice before its courts to meet specific professional standards.
Rule 7.7 of the Oklahoma Rules Governing Disciplinary Proceedings typically operates to ensure that attorneys cannot escape consequences for professional misconduct by maintaining licenses in multiple jurisdictions. The rule generally presumes that discipline imposed in one jurisdiction should be mirrored in others, subject to limited exceptions.
The Oklahoma Supreme Court's decision to dismiss the proceeding despite the Bar's request for parallel discipline suggests the court may have found distinguishing factors that made additional punishment inappropriate. These could include the nature of the underlying conduct, the adequacy of the tribal court's sanctions, or jurisdictional considerations unique to the tribal-state relationship.
For attorneys practicing in Oklahoma, particularly those who appear before tribal courts, this decision provides important guidance about how reciprocal discipline rules may be applied. The ruling suggests that automatic imposition of parallel sanctions is not guaranteed, even when requested by bar authorities.
The case also reflects the evolving relationship between state and tribal legal systems in Oklahoma, where 39 federally recognized tribes maintain significant governmental operations. Recent Supreme Court decisions, including McGirt v. Oklahoma, have reinforced tribal jurisdiction over certain matters, potentially influencing how professional discipline cases are handled.
Lile's case was decided as State of Oklahoma ex rel., Oklahoma Bar Association v. Lile, with the Oklahoma Supreme Court issuing its order on Feb. 10, 2026. The proceeding was designated as case number SCBD-7941 and received the citation 2026 OK 6.
The dismissal of disciplinary proceedings represents a relatively uncommon outcome in reciprocal discipline cases, where state courts typically defer to sanctions imposed by other jurisdictions. The decision may influence how similar cases involving tribal court disciplines are handled in the future, particularly in states with significant Native American populations and active tribal court systems.