Any of the following forms of discipline may be imposed in those cases where grounds for discipline have been established:

Annotation Annotator’s note. The following annotations include cases decided under former provisions similar to this rule. Constitutionality upheld. This rule provides sufficient guidelines to impose discipline to comply with due process of law. People v. Morley, 725 P.2d 510 (Colo. 1986); People v. Varallo, 913 P.2d 1 (Colo. 1996). Standards used in determining constitutional challenges. Same standards used in determining a constitutional challenge to a statute are used in determining constitutional challenge to this rule. People v. Morley, 725 P.2d 510 (Colo. 1986). A statute passes constitutional muster for the purposes of imposing professional discipline if it prescribes the possible penalties that can be imposed for a violation of a statutory provision. People v. Morley, 725 P.2d 510 (Colo. 1986). An attorney-at-law is an officer of court exercising a privilege or franchise to the enjoyment of which he has been admitted not as a matter of right, but upon proof of fitness through evidence of his possession of satisfactory legal attainments and fair private character. People v. Howard, 147 Colo. 501, 364 P.2d 380 (1961), cert. denied, 369 U.S. 819, 82 S. Ct. 830, 7 L. Ed. 2d 784 (1962). An attorney is continually accountable to the court. People v. Howard, 147 Colo. 501, 364 P.2d 380 (1961), cert. denied, 369 U.S. 819, 82 S. Ct. 830, 7 L. Ed. 2d 784 (1962). The privilege to practice law may at any time be declared forfeited for misconduct, whether professional or nonprofessional, as shows him to be an unfit or unsafe person to manage the business of others in the capacity of an attorney. People v. Howard, 147 Colo. 501, 364 P.2d 380 (1961), cert. denied, 369 U.S. 819, 82 S. Ct. 830, 7 L. Ed. 2d 784 (1962). The power to declare a forfeiture of the privilege to practice is a summary one inherent in the courts and exists not to mete out punishment to an offender, but rather so that the administration of justice may be safeguarded and the courts and the public protected from the misconduct or unfitness of those who are licensed to perform the important functions of the legal profession. People v. Howard, 147 Colo. 501, 364 P.2d 380 (1961), cert. denied, 369 U.S. 819, 82 S. Ct. 830, 7 L. Ed. 2d 784 (1962). It is not an adversary proceeding. People v. Howard, 147 Colo. 501, 364 P.2d 380 (1961), cert. denied, 369 U.S. 819, 82 S. Ct. 830, 7 L. Ed. 2d 784 (1962). A hearing board always has discretion in determining the appropriate sanction for attorney misconduct and may impose any of the forms of discipline listed in this rule, which range from private admonition to disbarment. In re Attorney F, 2012 CO 57, 285 P.3d 322. Hearing board erred, therefore, in concluding that it was compelled by case law to impose a public censure instead of private admonition. In re Attorney F, 2012 CO 57, 285 P.3d 322. Where complaints are resolved against an attorney, the committee may recommend public censure. People v. Radinsky, 176 Colo. 357, 490 P.2d 951 (1971). Disbarment is generally appropriate when a lawyer in an official or governmental position knowingly misuses the position with the intent to obtain a significant benefit or advantage for himself or another. People v. Brown, 726 P.2d 638 (Colo. 1986). Disbarment held not to be excessive. Use of a license to practice law for the purpose of bringing into being an illegal prostitution enterprise renders disbarment the only possible from of discipline. Any lesser sanction would unduly depreciate such misconduct in the eyes of the public and the legal profession. People v. Morley, 725 P.2d 510 (Colo. 1986). Disbarment may be recommended when attorney found guilty of crime. Where the committee finds that the nature of a crime of which an attorney has been found guilty is such as to render him an unfit person to be licensed to practice law, he therefore should be disbarred, and the committee recommend such disbarment. People v. Wilson, 176 Colo. 389, 490 P.2d 954 (1971). Disciplinary recommendation of grievance committee is advisory only and is not binding on the supreme court. People v. Smith, 773 P.2d 528 Colo. 1989). Disbarment was the only available remedy to protect the interest of the public where attorney had been afforded multiple opportunities including two suspensions and court ordered rehabilitation, and where attorney’s conduct demonstrated (a) neglect of legal matters entrusted to him; (b) misrepresentation to his client and the grievance committee; and (c) a pattern of neglect followed by the respondent that had the potential of causing serious injury to his clients. People v. Susman, 787 P.2d 1119 (Colo. 1990). Disbarment proper when attorney failed to timely answer complaint, put on evidence at hearing on amount of damages, answer amended complaint which included punitive damages that the court awarded and respond to grievance committee. The attorney had history of prior discipline for seriously neglecting client matters. Additional aggravating factors included the presence of multiple offenses, failing to cooperate in the disciplinary proceedings, and having substantial experience in the practice of law. There were no mitigating factors. In the Matter of Scott, 979 P.2d 572 (Colo. 1999). Disbarment is appropriate, in the absence of aggravating or mitigating factors, where lawyer knowingly converts client property and deceives client with the intent to benefit the lawyer or another and causes serious injury to a client. People v. Mulligan, 817 P.2d 1028 (Colo. 1991). Disbarment is the presumptive sanction for conversion of client funds. Where attorney knowingly converted, used, and failed to return client funds, disbarment was warranted. The attorney’s failure to participate in disciplinary proceedings or present significant factors in mitigation further precluded any deviation from the presumptive sanction. People v. Young, 201 P.3d 1273 (Colo. O.P.D.J. 2008 ). In the absence of aggravating or mitigating circumstances, disbarment is generally appropriate when (a) a lawyer abandons the practice and causes serious or potentially serious injury to a client; or (b) a lawyer knowingly fails to perform services for a client and causes serious or potentially serious injury to a client; or (c) a lawyer engages in a pattern of neglect with respect to client matters and causes serious or potentially serious injury to a client. People v. Southern, 832 P.2d 946 (Colo. 1992). The ultimate sanction for multiple charges of misconduct generally should be greater than the sanction for the most serious conduct. People v. Schubert, 799 P.2d 388 (Colo. 1990). Conduct violating this rule in conjunction with other disciplinary rules is sufficient to warrant suspension. People v. Smith, 828 P.2d 249 (Colo. 1992). Maximum period of suspension was warranted in light of multiple instances of misconduct and necessity for respondent to complete drug rehabilitation program. People v. Schubert, 799 P.2d 388 (Colo. 1990); People v. Driscoll, 830 P.2d 1019 (Colo. 1992). Established facts demonstrating that attorney knowingly practiced law after he had been administratively suspended by Colorado supreme court for failing to comply with his CLE and attorney fee registration requirements merited short suspension of attorney from practice of law. Upon consideration of the nature of attorney’s misconduct, his mental state, the potential harm he caused, the aggravating factors, and the absence of significant mitigating factors, the ABA standards for imposing lawyer sanctions and Colorado supreme court case law both support short suspension. Of particular salience here was attorney’s failure to participate in disciplinary proceedings. People v. Swarts, 239 P.3d 441 (Colo. O.P.D.J. 2010 ). Attorney received suspension for charging excessive fee in another state. The action taken in the other state had resulted in the attorney’s receipt of a one-year conditional suspension. Usually the court will impose the same discipline as that which was imposed in the foreign jurisdiction, but because Colorado does not provide for conditional suspensions public censure was deemed appropriate. People v. Nash, 873 P.2d 764 (Colo. 1994). Applied in People v. Barbary, 164 Colo. 588, 437 P.2d 57 (1968); People v. Creasey, 811 P.2d 40 (Colo. 1991).