Quick Facts
Byron E. Siegel, P 20428, Bingham Farms, Michigan.
Transfer to disability inactive status in Michigan.
Reciprocal discipline following an Arizona Supreme Court disciplinary order.
No. The status remains in effect until reinstatement under Michigan Court Rules.
No.
Case Information
- Attorney: Byron E. Siegel (P 20428)
- Case No.: 25-024-RD
- County: Oakland
- City: Bingham Farms, Michigan
- Document Type: Notice of Transfer to Disability Inactive Status
On December 23, 2025, the Attorney Discipline Board ordered the transfer of Byron E. Siegel to disability inactive status pursuant to Michigan Court Rules governing reciprocal discipline and attorney incapacity.
The transfer was ordered after a Tri-County Hearing Panel determined that the respondent did not meet the burden required to show that reciprocal discipline in Michigan would be clearly inappropriate.
Applicable Court Rules
This matter proceeded under Michigan Court Rules governing reciprocal discipline and disability inactive status, including:
- MCR 9.120(C) – Reciprocal discipline procedures
- MCR 9.121(A) – Disability inactive status
- MCR 9.121(E) – Reinstatement requirements
As with all attorney discipline matters, this action falls within the framework of Michigan Court Rules, Chapter 9, including the Attorney Discipline Board’s authority under MCR 9.115.
Underlying Conduct
The Grievance Administrator filed a Notice of Filing of Reciprocal Discipline pursuant to MCR 9.120(C), attaching a certified copy of an order issued by the Presiding Disciplinary Judge of the Supreme Court of Arizona.
That Arizona order transferred Siegel to disability inactive status effective January 23, 2025, in In the Matter of a Suspended Member of the State Bar of Arizona Byron E. Siegel, Case No. PDJ 2024-9105-D.
Hearing Panel Findings
Following the filing of the reciprocal discipline notice, the Attorney Discipline Board issued an order directing the parties to state whether there was any objection to imposing reciprocal disability inactive status in Michigan and whether a hearing was requested.
Siegel objected to the transfer and requested a hearing under MCR 9.120(C)(1). The matter was assigned to Tri-County Hearing Panel #3. After briefing by both the respondent and the Grievance Administrator, the panel determined that a hearing was not necessary.
The panel concluded that Siegel failed to satisfy his burden of demonstrating that reciprocal transfer to disability inactive status in Michigan would be clearly inappropriate.
Sanction
The hearing panel ordered that Byron E. Siegel be transferred to disability inactive status, effective December 23, 2025, pursuant to MCR 9.120(C) and MCR 9.121(A).
No costs were assessed. The transfer remains in effect until reinstatement in accordance with MCR 9.121(E).
Why This Matters
Disability inactive status is not a finding of misconduct. It is a regulatory mechanism used to protect the public, the courts, and the attorney when a lawyer is determined to be unable to practice due to incapacity.
This case also illustrates how reciprocal discipline operates across jurisdictions. When another state’s highest disciplinary authority imposes disability inactive status, Michigan courts will generally mirror that action unless the attorney can demonstrate a clear basis for exception under Michigan Court Rules.
