Alternative Dispute Resolution
Jul. 2, 2025
The curious exclusion of inactive attorneys from mediation
In Getzels v. The State Bar of California, the Court of Appeal held that inactive attorneys are barred from serving as mediators or arbitrators -- yet disbarred lawyers and bar exam failures, who are no longer or never were licensed, can still take on those roles.
Marc D. Alexander
Attorney and Mediator
Alternative Resolution Centers (ARC)
The California Court of Appeal held that Rule 2.30 of the State Bar, which precludes inactive licensees from serving as private arbitrators or mediators, does not violate the Equal Protection Clauses of the U.S. or California Constitutions. Morris S. Getzels v. The State Bar of California, No. B338089 (2/4 pub. 6/27/25) (P.J. Zukin, Justice Mori, and Judge Daum (sitting by assignment)). The rule withstands rational basis review and is...
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