The Wisconsin Supreme Court revoked attorney Michael B. Padden's law license as reciprocal discipline following his disbarment by the Minnesota Supreme Court, the Wisconsin court announced in a per curiam decision issued Nov. 12, 2025.
The Wisconsin court held that revocation of Padden's Wisconsin law license was appropriate reciprocal discipline for the disbarment ordered by the Minnesota Supreme Court in August 2024. The court resolved the matter without appointing a referee and imposed no costs.
Padden was admitted to practice law in Wisconsin in 2002 and in Minnesota in 1986. He had no previous professional discipline history in Wisconsin, according to the decision.
The case illustrates the reciprocal discipline system that operates between states to ensure attorneys cannot escape professional sanctions by practicing in multiple jurisdictions. Under reciprocal discipline procedures, when one state takes disciplinary action against an attorney, other states where that attorney is licensed can impose similar sanctions.
The Wisconsin Supreme Court's decision was based on the Minnesota Supreme Court's disbarment order in *In re Disciplinary Action Against Padden*, 10 N.W.3d 291 (Minn. 2024). According to the Wisconsin court's opinion, Padden had a history of disciplinary violations in Minnesota that led to his disbarment.
The Minnesota disciplinary record outlined by the Wisconsin court shows a pattern of professional misconduct spanning more than two decades. In 1996, Padden received a private admonition for failing to enter into a written contingent fee agreement with a client and failing to return that client's file upon request.
In 2017, Padden received a public reprimand for agreeing to settle a case without his client's consent and failing to communicate the settlement agreement, according to the Wisconsin court's recitation of the Minnesota disciplinary history.
The progression from private admonition to public reprimand to eventual disbarment demonstrates how attorney discipline often escalates when lawyers fail to correct problematic conduct. Minnesota's decision to disbar Padden followed this pattern of repeated violations of professional conduct rules.
Reciprocal discipline proceedings typically follow a streamlined process compared to original disciplinary cases. Rather than conducting a full investigation and hearing on the underlying misconduct, the receiving state court generally accepts the findings and conclusions of the disciplining state and determines what level of discipline is appropriate in its jurisdiction.
The Wisconsin Supreme Court noted that the parties had filed a stipulation on Oct. 22, 2025, but the court rejected it by order on Nov. 6, 2025. The court returned the parties to their positions before filing the stipulation, as set forth in their pleadings and briefs. This suggests there may have been disagreement about the appropriate level of discipline or other terms.
Revocation of a law license, like disbarment, represents the most severe form of attorney discipline. It completely terminates the attorney's right to practice law in that jurisdiction. While some states distinguish between disbarment and revocation, both result in the same practical outcome: the attorney can no longer practice law in that state.
The timing of the Wisconsin action follows typical patterns in reciprocal discipline cases. Minnesota disbarred Padden in August 2024, and Wisconsin issued its revocation order in November 2025, allowing time for the reciprocal discipline process to unfold.
Reciprocal discipline serves important functions in the legal profession's self-regulation system. It prevents attorneys from forum shopping among jurisdictions to avoid the consequences of professional misconduct. It also ensures that disciplinary actions have meaningful impact even for attorneys licensed in multiple states.
The case also highlights how attorney misconduct often involves violations of basic professional duties to clients. The disciplinary violations outlined in Padden's history—failing to obtain proper fee agreements, not returning client files, settling without client consent, and poor communication—represent fundamental breaches of the attorney-client relationship.
For Wisconsin attorneys, the case serves as a reminder that disciplinary actions in other jurisdictions can have consequences for their Wisconsin practice. The state's participation in reciprocal discipline systems means that professional misconduct anywhere can affect an attorney's ability to practice throughout their career.
The per curiam nature of the Wisconsin decision indicates unanimous agreement among the justices about the appropriate discipline. Per curiam opinions are issued by the court as a whole rather than authored by an individual justice, often used for cases where the legal principles are well-established or the outcome is clear.
The revocation becomes effective with the court's order, immediately ending Padden's ability to practice law in Wisconsin. Like other severe disciplinary sanctions, revocation protects the public from future misconduct while maintaining the integrity of the legal profession.