Barnard v. Utah State Bar

DURHAM, Justice:

Brian M. Barnard appeals from a district court order dismissing his complaint against the Utah State Bar and imposing sanctions against him under rule 11 of the Utah Rules of Civil Procedure.1 We affirm the dismissal of his complaint but reverse the imposition of sanctions.

FACTS

Brian M. Barnard is an attorney licensed to practice in Utah. As part of his practice, he assists clients in preparing and filing pro se divorce actions. Barnard relies on the work of paralegals (nonlawyers trained to perform legal work) in handling his case load of pro se divorce clients.

On December…