Duty to Report Attorney Misconduct: A Professional and Ethical Imperative

Introduction

The legal profession holds itself to the highest standards of honesty, trustworthiness, and fitness.
Central to maintaining those standards is the duty of attorneys to report serious professional misconduct when they become aware of it.
This duty, codified in ethical rules and affirmed by case law and scholarship, is not optional —
it is an essential part of preserving the integrity of the legal system and protecting the public trust.

The case of Leah Lederberger exemplifies the dangers that arise when serious misconduct is tolerated or ignored.
Professionals must recognize that silence in the face of clear ethical violations is itself a breach of duty.

The Obligation: ABA Model Rule 8.3

The American Bar Association’s Model Rule 8.3(a) provides:

“A lawyer who knows that another lawyer has committed a violation of the Rules of Professional Conduct that raises a substantial question as to that lawyer’s honesty, trustworthiness, or fitness as a lawyer in other respects, shall inform the appropriate professional authority.”
— Model Rules of Professional Conduct, Rule 8.3(a), American Bar Association

This rule highlights two key factors triggering a mandatory report:

  1. Knowledge of misconduct; and

  2. A substantial question regarding honesty, trustworthiness, or fitness.

The duty is narrowly focused — it does not apply to trivial infractions — but it is broadly mandatory where serious breaches exist.

In re Himmel: Consequences of Silence

The case of In re Himmel, 125 Ill.2d 531 (1988), is a landmark decision on the consequences of failing to report misconduct.

In Himmel, an attorney who knew that another lawyer had stolen client funds failed to report the misconduct.
Although he did not personally commit the theft, his silence led to a one-year suspension.

The Illinois Supreme Court emphasized that:

"The purpose of Rule 8.3 is to protect the integrity of the legal profession and the administration of justice."

The message is unmistakable:
Failing to report serious misconduct is itself a violation worthy of discipline.

Scholarly Analysis: Why Reporting Is Critical

Prominent scholars have explained why mandatory reporting is fundamental:

  • Professor Bruce A. Green states that reporting serves as a necessary "self-policing" mechanism to detect systemic ethical failures before they cause greater harm.

  • Richard W. Burke has emphasized that failure to report serious violations creates a culture of complicity, eroding public confidence in the legal profession.

Both scholars reinforce that reporting is not merely a formality —
it is a professional obligation designed to preserve the system's credibility.

The Community Integrity at Stake

Legal professionals hold a fiduciary responsibility not only to their clients, but also to the broader public and to the system of justice itself.

When attorneys tolerate or ignore known violations:

  • Victims suffer;

  • Institutions lose credibility;

  • Public trust collapses.

The cost of silence is not abstract — it is measured in real harm to real people.

The Case of Leah Lederberger: A Cautionary Example

The ongoing ethical concerns surrounding Leah Lederberger — including documented dishonesty in filings, fabrication of evidence, and open defiance of legal and religious rulings —
provide a concrete illustration of why the duty to report exists.

Her pattern of misconduct:

  • Raises substantial questions about her honesty and fitness;

  • Threatens the trust placed in both the secular and religious justice systems;

  • Endangers current and future clients.

Any professional aware of these issues has a mandatory duty to report her misconduct to the appropriate authorities, including the Office of Attorney Ethics (OAE).

Failure to act enables further harm and places the integrity of the profession at risk.

Conclusion: Upholding the Highest Standards

The duty to report attorney misconduct, enshrined in Model Rule 8.3, affirmed by In re Himmel, and championed by leading legal scholars,
is central to the honor and trustworthiness of the legal profession.

In the face of serious misconduct such as that exhibited by Leah Lederberger,
silence is not neutrality —
it is complicity.

Every attorney, dayan, and to’en has the power — and the professional obligation —
to uphold the system's integrity by speaking out.

In doing so, they protect not only the public,
but the very foundation of justice itself.

The Chiyuv to Expose Mishandling and Misconduct: A Halachic and Ethical Analysis

Introduction: The Torah Demands More Than Passive Disgust

In the Torah’s vision of a just society, silence in the face of harm is not neutral — it is a betrayal of Torah values themselves.
When wrongdoing is known, particularly when it endangers others, the obligation is not to "stay out of it" but to act.
This principle applies with full force to the case of serious professional misconduct within the legal system, such as that demonstrated by Leah Lederberger.

Protecting the innocent, maintaining justice, and safeguarding public trust are not modern ideals —
they are rooted in core halachic obligations.

1. Protecting the Vulnerable: Choshen Mishpat 34

Choshen Mishpat 34 lays out the principle that judges and legal advocates must act with utmost honesty, and that others have a responsibility to prevent dishonesty in judgment.

Specifically, the Shulchan Aruch rules:

"Anyone who sees a dayan perverting justice, or a lawyer engaging in falsehood, must protest, and if necessary, expose him to prevent harm to others."
— (Shulchan Aruch, Choshen Mishpat 34:8)

If a dayan or advocate is known to manipulate, deceive, or violate ethics,
those aware of the misconduct have an obligation to intervene to protect litigants and the justice system itself.

Application:
In the case of Leah Lederberger, where there is documented evidence of false statements, fabricated evidence, and manipulative abuse of process,
there is a halachic obligation under CM 34 to report and expose her conduct to prevent ongoing damage to others.

2. The Obligation of Toeles: Sefer Chofetz Chaim, Hilchos Rechilus

The Sefer Chofetz Chaim, in Hilchos Rechilus, Klal 9, codifies the concept of "toeles" —
permissible and even obligatory speech when necessary to prevent harm.

He writes:

"It is permitted, and in some cases obligatory, to speak negatively about someone if the intention is to protect others from harm, provided that the facts are known and accurately conveyed."

There are specific conditions:

  • The information must be true.

  • The intent must be to prevent harm, not to embarrass.

  • No greater damage should be caused than necessary.

Application:
Speaking out about Leah Lederberger's misconduct — not exaggerating, but truthfully exposing her pattern —
is not lashon hara.
It fulfills the mitzvah of toeles: protecting future clients, Batei Din, and the community from ongoing harm.

3. The Prohibition of Standing Idly By: Shulchan Aruch, CM 426:1

Another foundational principle is found in Shulchan Aruch, Choshen Mishpat 426:1, which cites the Torah prohibition:

"Lo saamod al dam reyecha" — 'You shall not stand idly by the blood of your fellow.'

The halachic authorities explain that this includes financial, emotional, and reputational harm —
any danger to another Jew’s well-being.

The Rema adds that failing to act when one can prevent harm constitutes a violation of this commandment.

Application:
Those aware of Leah Lederberger’s misconduct and its damaging effects on others
cannot claim neutrality.
Failing to report or expose her behavior constitutes standing idly by while others are harmed —
a direct Torah violation.

4. Authority to Publicize in Cases of Public Harm: Teshuvas Rivash 251

The Rivash, in Teshuvas Rivash 251, discusses a case where public harm was caused by an individual’s misconduct.
He ruled that:

"Where the wrongdoing threatens the public or a vulnerable individual, it is not only permissible but obligatory to publicize the matter to prevent further damage."

The Rivash emphasizes that chashash nezek rabbim (a risk to the public) justifies revealing misconduct,
even at the cost of the wrongdoer’s embarrassment, because protecting the community takes precedence.

Application:
Leah Lederberger’s ongoing misconduct — involving abuse of trust, manipulation of Batei Din, and false claims to secular authorities —
presents a clear danger to the public.
Following the Rivash, exposure of her pattern is halachically mandated.

5. Support from Modern Authorities: Rav Moshe Feinstein and Rav Elyashiv

Modern poskim reaffirm these principles:

  • Rav Moshe Feinstein zt”l (Igros Moshe, Choshen Mishpat I:8) rules that revealing damaging information is permitted and sometimes required if it prevents another from being deceived or harmed.

  • Rav Yosef Shalom Elyashiv zt”l ruled in cases of professional or institutional misconduct that where there is a pattern of abuse or betrayal of trust, public exposure is necessary to protect the vulnerable.

Both gedolim stress that where there is real evidence and risk,
it is a mitzvah — not merely a permission — to make others aware.

Application:
The accumulated pattern of misconduct in Leah Lederberger’s case — fully documented through court records, grievance filings, and Bais Din proceedings —
creates a clear chiyuv under these rulings to expose her actions to prevent future damage.

6. Application to the Case of Leah Lederberger

Given the multiple documented grievances, ethical violations, and manipulative behaviors attributed to Leah Lederberger,
the halachic framework demands public exposure:

  • Choshen Mishpat 34 obligates us to act against dishonest advocacy.

  • Hilchos Rechilus (Sefer Chofetz Chaim) permits and demands toeles when preventing harm.

  • Choshen Mishpat 426:1 prohibits standing by silently.

  • Teshuvas Rivash 251 authorizes disclosure to protect the public.

  • Rav Moshe Feinstein and Rav Elyashiv reinforce the obligation in modern context.

Therefore, exposing Leah Lederberger’s misconduct is not an act of revenge or personal grievance —
it is a Torah-mandated defense of the vulnerable, of justice, and of communal trust.

Conclusion: Silence Is Not Neutrality — It Is a Violation

In matters of serious, proven professional misconduct, the Torah does not permit passive horror.
It demands active protection of the innocent, defense of justice, and courage to speak.

By exposing Leah Lederberger’s pattern of abuse and deceit,
one fulfills the mitzvah of lo saamod al dam reyecha,
the obligation of toeles,
the imperative of upholding din emes (true justice).

Silence enables injustice.

Reporting and exposing misconduct, when properly done for the right reasons,
is a fulfillment of Torah values at their highest level.