Petition to Increase Licensing Fees

This petition does not involve any rule amendments, but the Supreme Court invites comments about this proposal. Due to the size of the files, the petition is presented in 9 parts: the petition itself, all exhibits and Tabs A – G.
Petition to Increase Licensing Fees (.6MB)
Exhibits (2MB)
Tab A (6MB)
Tab B (3MB)
Tab C (1MB)
Tab D (1MB)
Tab E (.4MB)
Tab F (.1MB)
Tab G (4MB)

Utah Courts

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21 thoughts on “Petition to Increase Licensing Fees
  1. James Rupper

    The proposed increase in licensing fees unfairly discriminates against those members of the bar who receive the least services from the bar: the inactive and the inactive with full service (i.e. we receive a magazine that allows us to keep up with our colleagues in Utah.) The bar proposes to raise the rate of an Inactive member by $65.00. The current fee is $50.00. This represents an increase of 130% (65/50=130%). The increase for Inactive Full Service is $70. This represents an increase in fees of 87.5% (70/80=87.5%) The active members under three years experience an increase of $60 dollars and increase in fees of 31.5% increase (60/190=31.5%) The largest and most served section of the bar, Active members, experience a $75.00 increase which represents a 23% increase in fees (75/325=23%). As anyone can see the proposed fee increase places a disproportionate burden on the backs of the elderly, retired lawyer. Of course, not all inactive lawyers are old, but they certainly should not have their fees increased by 130% when the fully active have their fees increased by 23%. I respectfully request that the Supreme Court modify the Petition to increase fees to equally share the the burden.

  2. Joanna

    What are the chances that the Bar could/would create a category with a reduced fee for Active Government Attorneys? A flat fee does not reflect the difference in our incomes and $425 is a lot to ask of those of us earning well less than the average attorney in private practice, whose firm pays the fee anyway.

  3. Lynn D. Wardle

    Memo to: Utah Supreme Court and Judicial Council
    From: Lynn D. Wardle
    Date: 28 January 2010
    Re: Proposed Increase in Bar Dues
    I am a little concerned about the proposal for a significant increase in bar dues (not that some increase after 20 years is not warranted) primarily for two reasons. First, if I read it correctly the 2009 Report of the ABA Division for Bar Services on State and Local Bar Dues, Fees, etc., that was attached to the petition shows that Utah is (was in 2009) tied for 17th most expensive in bar dues and total cost to practice in the jurisdiction, nearly 20% above the median state’s cost. I would suspect that our per capita income for Utah lawyers is not 17th in the nation, much less 20% above the median state’s average lawyer income, so I wonder if Utah bar dues may not already a bit out of balance. An increase does not seem justified by that data, and would only exacerbate that. We do not need a Cadillac or gold-plated state bar association to provide first-rate and professional service.
    Second, we are in a recession, and many small-firm and solo attorneys may not be particularly flush right now. I think it may not be particularly good timing to propose to raise bar dues by another 20% or so. As private sector jobs have experienced freezes or even reductions in budgets and salaries, and some public sectors have experiencec furloughs and other virtual salary and budget cut-backs, I think the state bar might set the example of holding the budget line for a year or two (for as long as it takes for the economy to ramp up and start moving). By focusing on the core needs and critical perspective of the members of the bar a significant dues increase might be avoided or postponed.

  4. Sandra K. Allen

    This is a bad year to ask for an increase in fees. The State is cutting the budgets of almost every State agency. The legislature is proposing cuts to employee retirement and health benefits. There are many layoffs in the private sector. Everyone is looking for ways to economize. Surely, the Utah State Bar can find some ways to live within its curent budget.

  5. J. Spencer Ball (5186)

    Why don’t IOLTA funds help finance at least the service portions of bar expenses if not more?
    Why raise fees during a recession?

  6. J. Spencer Ball (5186)

    Why don’t IOLTA funds help finance at least the service portions of bar expenses if not more?
    Why raise fees during a recession?

  7. Joseph Bodine

    The Petition does make a valid argument for an increase in fees. However, the arguments are only centered around the needs of the Bar and not the impact on the attorneys. The proposed increase comes at a most inopportune time. All sectors of the economy are dealing with falling revenue and attorneys are not excepted from the impact of these economic realities. New attorneys, in particular, are struggling with not only finding and keeping employment but, as tuition has increased due to lower state funding, with the burden of increasing student loan obligations. An increase of Bar dues at this time just adds to the burden of overextended budgets. Perhaps a curtailing of some services would better serve the membership rather than saddle individual attorneys with increased financial obligations. I understand that attorneys who have never had a private practice, are/were employed by a larger firm, or left the private sector many years ago do not have a sense of the financial difficulties associated with private practice; payroll, lease/mortgage, technology upgrades, office supplies, CLE, insurance, (well you get the idea). So the high hourly rate seen by the court, government attorneys, and others, gets eaten up rather quickly. I believe the majority of attorneys do not make anywhere near the salaries that the public, and sometimes, the Court believes attorneys make. This is particularly true in the areas of public defense, divorce, and other domestic legal services. Given the current state of the economy I believe business law is fast joining that list.
    There is no disagreement that services have increased and the members now have a much wider range of services than in the past. Many of these services have been undertaken without a cost to the members and, as the members have found these services useful, the use of these of these services has increased. Characterizing this increased use as “demand” is at best questionable. An increase in the use of these services is more a reflection of the increase focus attorneys are required to put on the business end of their practice than a demand that the Bar provide the service.
    Bottom line – An increase is most likely warranted, but the Court should consider the impact on the financial resources of the attorneys it will impact. A stepped approach might be best, or delaying the increase three to four years until the economy shows signs of sustained recovery. That’s my two cents!

  8. Harrison Colter

    I am sorry, but the Bar seems to be saying “We are getting more members, so we need more money.” Fine, but with more members paying dues, the Bar is getting more money. Thus, to me, the argument seems to indicate that the marginal cost of each additional member increases, rather than decreases, the Bar’s costs. I am not aware of a successful business having a cost structure wherein each additional sale has a higher marginal cost.
    If that is indeed the case here, I would suggest we have an unsustainable business model, and we should shut it down before it gets any worse. At a minimum, the Bar should be asked to do less; I wonder whether the vast majority of members would even notice a difference. They will, however, notice a 20% increase in annual dues, one that would bring us up to the level of Texas and above California (not exactly similar states in terms of bar size or problems).

  9. David R. Bird

    I wish to wholeheartedly support the Utah State Bar’s Petition for an increase in Bar dues. As an active member for over 30 years, I have watched and been actively involved in Bar activities. The Bar has prudently used the monies paid by its members to benefit the profession and all of us. It has delayed requests for justifiable increases for many years. The reasonable increase requested is long overdue.

  10. David Milliner

    With regard to the proposed Utah State Bar licensing fee increases I note the following:
    1. Even without the proposed increase, at 17th in the nation Utah remains solidly in the top half of the states in terms of cost to maintain a license to practice law. I don’t know where Utah currently ranks among the states in terms of average income, but I’d bet that it’s lower than 17th.
    2. The Bar’s current financial position would be better but for the ill-advised investment of a large portion of our reserves in a single bond from a single issuer, Lehman Bros., which recently resulted in a significant loss when that company went bankrupt. The widely-understood rules of diversification of risk should have been followed here, but apparently were ignored. This suggests that there is significant room for improvement in the Bar’s financial operations.
    3. The lengthy fee increase proposal talks about all the different sections of the bar that need to be maintained, but I didn’t see where the separate annual membership fees currently charged to participate in each section come into play. Perhaps I missed it? If the sections are not already paying their own way, then it seems more appropriate to charge higher fees for these voluntary memberships than to increase the fees of all Bar members to subsidize the activities of the sections.
    4. Similarly, rather than imposing a blanket increase on all Bar members to support Bar-sponsored services that are utilized by only a few, serious consideration should be given to imposing surcharges on those who are actually using the services.
    David Milliner

  11. Rusty Vetter

    I believe that time is not right for an increase in Bar fees or dues. I have not seen an immediate crisis for the Bar to justify an increase at this time. We are in the middle of the most significant economic downturn in the past 80 years. Governmental entities throughout the State are working hard to avoid any tax or fee increase. The Bar is a quasi-governmental agency that should follow the examples of the state, county and municipal agencies in Utah that have found ways to make meaningful cuts to their budgets.
    I am very familiar with the Bar’s budget and operations of the Bar. Since 1991, I have been an active volunteer for the Bar. This has included service as chair or co-chair of different Admissions-related committees. I have served on the Bar Commission’s Executive Committee and I am presently serving my second term as a Bar Commissioner.
    Any increase in our mandatory dues must be justified. I have reviewed in detail the Bar’s information used to support the arguments for the increase in dues. I fully support the excellent work of the people involved with the Bar, but believe that they must be circumspect about any increase in Bar dues. Legal work has slowed significantly. Many law firms have stopped hiring new lawyers and some have laid-off employees. Even an increase of $75 per person can have an impact on individual attorneys or firms with dozens of lawyers.
    In addition to considering increasing fees for all members of the Bar, I believe the Court should consider the benefit of allowing members to pay only for services they utilize. Mandatory dues could be reduced from $425 to approximately $225 and then let members choose to pay for additional benefits. Approximately one half of the Bar’s budget goes to its regulatory functions: management, licensing, admissions, OPC and general counsel (see page 78 of Exhibits to Bar Petition). For many attorneys, such as most government lawyers that I represent, these are the only services of the Bar that are utilized. Mandatory dues should be paid to cover only these expenses. Members should be able to choose to pay for other Bar services, and should not be required to pay for benefits that not useful to them.
    This is an opportunity to evaluate how the role of the Bar has changed over time and make sure it makes sense for us to be spending the money we are spending. The needs of members are much different today compared to 23 years ago when I started practicing. Most members don’t think they need the Bar as much today compared to the past. Splitting our dues to give attorneys the option to spend their money on non-regulatory functions would make the Bar stronger. Other states have successfully adopted this approach.
    Before the Court should allow any increase in fees, the following questions should be considered:
    • Shouldn’t the Bar be required to make cuts to its budget similar to other governmental entities? Last year, Utah State departments cut their budgets by 15%. Additional cuts are expected this year. Salt Lake City departments have cut their budgets by 10% twice in the past year. Most non-profit entities are experiencing similar cuts to their budgets. Government salaries are staying flat or being reduced. Until the Bar makes similar cuts, it will be hard for government attorneys to support a dues increase.
    • Shouldn’t the Court reject the assumption that the Bar be allowed to increase expenses faster than increases in revenue? Bar leaders have been too willing to accept the inevitable position that the Bar’s expenses will necessarily increase by 5% over time, when revenues will only increase by 3%. There is no reason why we can’t choose to keep increase in expenses at the same rate of increase in revenues. Assuming that expenses would be kept in line with increases in revenue, it should not be hard to hold off on dues increases.
    • Aren’t the Bar’s $1 million in cash reserves adequate? One of the aspects of the dues increase that has been discussed is the need to increase cash reserves. Our risks to operations are minimal and primarily related to the Bar’s building. The mortgage on the building has been paid off. While I agree that we want to responsibility plan for upkeep of the building, we don’t need to panic. If necessary, we can responsibly incur debt to cover building related expenses.
    • Is the argument fair that a dues increase is appropriate now because it has been 20 years since the last dues increase? The argument fails to recognize the fact that the Bar previously made attorneys pay dues twice in one year to cover a financial crisis. A large budget surplus was built up and over the years, the surplus has been spent. Now the Bar is asking the court to allow the Bar to build up a surplus of $1million over the next five years and then allow it to spend the surplus over time. In the past, the Bar’s surplus has been spent to support new programs proposed by Bar Presidents and the Bar Commission. Unfortunately, so long as there is a surplus in funds available, it is too easy to spend those funds and not retire programs that are not effective.
    • Shouldn’t a requirement be put into place to limit expenses for the Bar Commission and special projects? The Bar Commission is the voluntary governing body of the Bar. Unlike the boards of most non-profit organizations, the cost for the Bar Commission is significant. Furthermore, the spending for the Commission and special projects often exceeds their budget, which shows the Bar’s inability to control this spending. This past year, the budget for these expenses was $85,000, while actual expenditures were $145,000. For the current year, the budget is $98,700. In the past year, when Commissioners were asked to vote to reduce their allowance from 3 days to 2 days to attend the Summer Convention at the resort Sun Valley, Idaho – they rejected the request. This expense is approximately $20,000 per year. Another recent example of the excessive spending was the Commissioners’ decision to send 4 people to a resort in Hawaii to attend the Western Bar Conference, only weeks after announcing that a Bar dues increase may be necessary.
    • Shouldn’t there be some justification for raising dues for inactive members? The primary reason that an inactive member continues to pay annual dues is to avoid the necessity of taking the Bar exam in the future, if he or she wants to become an active member. The expense to the Bar to deal with inactive members is minimal. Presently, the Bar profits from the inactive fees that are paid. I’m not aware of any reason why inactive members should be charged more.
    I could support an increase in dues if it were justified. I don’t believe that the case has been made to support a dues increase. Adequate attempts have not been made to keep increases in Bar expenses in line with increases in revenue. At a time when so many people are struggling financially, the Bar needs to keep its expenses down. Furthermore, it isn’t appropriate to raise fees only to have those fees pay for services that are utilized by a limited number of Bar members.
    Thank you for considering my comments.
    Rusty Vetter

  12. Eric

    The Bar fee is already a disincentive to continued practice in lower pay attorney jobs, including full time access to justice positions, service to rural communities, and part time work amenable to young parents. The new lawyer discount is appreciated, but does not go far enough.
    The Bar’s responsibilities do include public education and access to justice but it may best fulfill these obligations by helping to reduce impediments to lawyers who sacrifice financially to focus on public needs, rather than assisting better paid attorneys fulfill their professional responsibility to serve the public on the side. The Bar’s paid pro bono coordinators do great work, but the Bar has a disproportionately urban impact in public outreach, CLE, and networking. The bar’s petition confuses optional programs which might fit within its responsibilities with truly essential services.
    Those established attorneys who choose to participate in networking programs of the bar should fund their individual interests. With proper management, the thousands of dollars already paid by the average attorney over a career should more that cover the Bar’s administrative/discipline costs for the average attorney.

  13. Skip

    So, wait a second. This is our Utah Bar Association we’re talking about, right? The same Bar Association that sits in its beautiful and nearly new multi-million dollar ivory tower office complex downtown while private attorneys all over the state are trying to find ways to pay rent and make ends meet. The same Bar Association that can’t seem to find a way to host its annual convention/elbow-rub golf tourneys inside the home state, gathering at Sun Valley instead. And now they want us to give them even more money? For what? So the handful of wealthy members can have even more out of state get-togethers in the future? Vail or Tahoe next year, perhaps?
    Do any of these people live and work in the real world? Do they give pro bono service to neighbors? Have they tightened their belts like the rest of us and cut every imaginable unnecessary expense just to keep their heads above water before holding their hands out to ask for more? Where is the sense of perspective here?
    Millions of other Utahns and thousands of Utah attorneys are doing their best right now to live off of less, or even to do without when the bank balance gets too low. Our Bar Association has a lot of nerve to demand more at the worst possible moment. This makes no sense at all.

  14. Ken Bradshaw

    Along with others, I believe that time is not right for an increase in Bar fees or dues. I have not seen an immediate crisis pending before or threatening the existence or efficacy of the Bar to justify an increase at this time. It is clear to the most casual observer that we are in the middle of the most significant economic downturn in the past 80 years.
    Governmental entities throughout the State are working hard to avoid any tax or fee increase. The Bar should be no different in its response to, and the adjustments required to its operations on account of, this current down-turn than other governments OR THE BAR’S OWN MEMBERS!!
    I’m sorry, but it is unconscionable that The Bar, as a quasi-governmental agency, is attempting to avoid the bitter decisions or consequences that other governments and THE BAR’S OWN MEMBERS are faced with each day by passing on costs BEFORE bona fide retrencement is undertaken and in place. The Bar should lead in this, as other areas, or it could merely follow the examples of the state, county and municipal agencies in Utah that have found ways to make meaningful cuts to their budgets. Here, in the current proposal however, we don’t even see signs of good followership.
    Clearly, any increase in our mandatory dues must be justified. Understand, I have no quarrel with those who work tirelessly on behalf of the Bar. I fully support the excellent work they have done individually and collectively. However, as a matter of public policy and perception (politically, perception being reality) the Bar must be circumspect about any proposed increase in Bar dues or other costs.
    It will not come as a surprise to anyone that legal work has slowed significantly particularly for many of our newer members who struggle during the best of times. Many law firms have stopped hiring new lawyers and some have laid-off employees. Even an increase of $75 per person can have an impact on individual attorneys or firms.
    I believe, along with others who have commented here that the Court would be well advised to consider the benefit of allowing members to pay only for services they utilize. For example, mandatory dues could be reduced from $425 to approximately $225 and then members might be allowed to choose to pay for additional benefits if and as desired.
    Since approximately one half of the Bar’s budget goes to its regulatory functions: management, licensing, admissions, OPC and general counsel, as noted by other commentors, for many attorneys, such as most government lawyers, these are the ONLY services of the Bar that are utilized and are rightly a part of mandatory dues and should be thus limited. As noted above, Members, then, should be able to choose to pay for other Bar services they find useful, and should not be required to pay for benefits that are NOT useful or essential to them.
    For reasons cited by other of my colleagues commenting in this forum, most of who’s comments and arguments I readily accept, I encourage the Court to decline to adopt the proposed Mandatory Fee increase until and unless the Bar demonstrates fiscal restraint appropriate to the current economic situation AND a study can be undertaken to ascertain the feasibility of limiting Mandatory Bar Dues to essential and only essential regulatory functions.
    Thank you for considering my comments.
    Ken Bradshaw


    Dear Members of the Utah State Bar & Honorable Justices of the Utah Supreme Court:
    1. I reiterate my opposition to an increase in bar dues expressed in my Letter to the Editor published in the Utah Bar Journal, Volume 21, No. 2, Mar./Apr. 2008.
    2. In my 37 years as a member of the Utah Bar I have seen the bar move away from lawyer referral to embrace political lobbying and expansion of utopian activities outside the scope of the bar’s established purpose.
    3. The reason stated for increasing bar dues 600% was to fund the construction of the Law and Justice Center.
    4. The encumbrance on that fine edifice evidently was retired some years ago.
    5. Yet the powers that be in the bar seem to feel they know how to use our discretionary income better than we do as individuals and continue to ask for more and more of it.
    6. “The bureaucratic monster has an insatiable appetite.” It must be reigned in and subdued.
    7. We must be careful not to fall into the trap. We don’t need increased bar dues. We need a decrease.
    8. We do need to use enough of dues to fund at least one or two live human beings as operators to receive calls for lawyer referral. Nevada still does so as well as other states.
    9. I heard on the news just today that contrary to public opinion, still 1/3rd of the population of the United States does not have access to the internet. How are these 100 + million fellow citizens receiving lawyer referral?
    10. It is time we get back to the basics of providing licensing and support for the men and women who are members of the bar and get out of social and political action without representation.
    11. On point is the shock I received when I heard the other day that “the bar” opposed the Utah Legislature’s bill to require the Chief Justice of the Supreme Court to be appointed by the Legislature. Beside the point is my own opinion on the matter. What was offensive to me was the impression all 10,000 members of the bar oppose the bill. I certainly wasn’t given a chance to voice my opinion before the bar made a blanket statement in opposition on behalf of ALL of its members.
    12. These things should not be nor should the bar take it upon itself to increase dues under the guise they do not have enough funds to do such and other irrelevant “projects” other than licensing and support of its bar members.
    13. Another important point is when the 600% increase in bar dues to fund construction of our Law and Justice Center was made, not long after, Continuing Legal Education was also implemented. This tacked on many hundreds of dollars in expense to maintain our update in the law in order to remain active members. We do not need more expense but less.
    14. I am heartened that the great majority of the comments of fellow bar members so far are in agreement with me.
    14. Rather than increasing bar dues, lets decrease them, slim our “projects”, and return to the fundamentals of licensing and support of bar members.

  16. R. Clayton Huntsman

    I agree with all of the comments below except for the one that says, this rate increase is probably justified, or words to that effect. This is not the time to sock it to attorneys once again. Most of us are inundated with bar schemes to provide free or discounted services to those who should be hiring us during this recession. This fee increase now just shows how clueless and arrogant those who would manage our law practices can be. Let’s have a fee decrease and use bar funds to subsidize attorneys who buy into all of the free programs the bar thinks are so wonderful. Why do dysfunctional and abusive parents deserve more consideration than attorneys do from our bar? I have talked with more than a dozen attorneys and every single one without exception opposes this unconscionable and untimely increase. I have never seen such exploitation of dependent professionals as I have with this bar. But we are at your mercy–for better or for worse.
    R. Clayton Huntsman

  17. Paul W. Mortensen

    Dear Honorable Justices of the Utah Supreme Court:
    In considering any request for a fee increase the Supreme Court should hold a public hearing to allow public member comments and to have Bar Commissioners and other officials present to answer questions by members of the Bar. Other taxing authorities have to follow this type of procedure. It is troublesome to have one branch of government possess the power to legislate, to regulate, to adjudicate, to discipline, and to tax, with no separation of powers and no means of review outside of the one branch of government. A public hearing would help alleviate the potential for problems arising out of this concentration of powers.
    Some questions I would ask: To what degree is the increase in fees intended to cover the several hundred thousand dollars lost through investments gone bad? What procedures have been implemented to prevent a repeat of this unfortunate loss of members’ dues? Are there any hidden agendas for use of dues not disclosed in the petition? Why do not the yearly additions of many more dues-paying lawyers provide the needed income?
    The amount of increase requested does not concern me as much as the purposes to which the funds might be used. About a decade ago the Bar increasingly moved to assert itself into social causes. I remember one bar commissioner suggesting that the Bar give a hundred thousand dollars (or thereabouts) of Bar funds to charity. I have observed less of this in recent years, but it is hard to forget the past.
    I would like to emphasize that I am not suggesting that anyone has done, or intends to do, anything improper. The petition is well presented on its face. I believe the Court has properly steered the issue before the Bar members. I do, however, believe there are systemic problems which cannot be ignored. Please hold a public hearing and thoroughly advertise the hearing to members of the bar to allow maximum participation.
    Respectfully submitted,
    Paul W. Mortensen

  18. Todd

    I strongly oppose an increase in fees. As a solo practitioner every dollar is important, and paying additional fees when the current fees and costs of mandatory cles is exorbitant is very difficult. Please work to lower our existing fees and costs; do not increase them.

  19. Lee M. Andelin

    This is a classic case of scope creep. Those who run the bar want to do more, so they charge us more (without our consent). Bar dues should reflect no more than the bare administrative cost of attorney admissions and discipline. The cost of all other services and activities should be charged to those who use them. Better yet, let’s make membership in the state bar voluntary and have the Utah Supreme Court administer attorney admissions and discipline, similar to what some other states have done.

  20. Elizabeth A. Hruby-Mills

    Chief Justice Durham:
    On behalf of the Board of Trustees of Legal Aid Society of Salt Lake, I write in opposition to the proposed increases in bar dues. Civil legal service organizations such as Legal Aid Society of Salt Lake provide much needed services to victims of domestic violence, low-income and disadvantaged members of our communities. These organizations operate on very tight budgets, the majority of which goes towards paying for staff that provide direct services. As a charitable organization, Legal Aid Society of Salt Lake relies on donations, grants, and fundraisers. Many of these sources of revenue are decreasing because of the poor economy. Conversely, the poor economy and financial pressures on families has only increased the request for services to civil legal service providers.
    Attorneys, paralegals and support staff who are employed at these organizations are dedicated to providing services to those most in need in our communities and are paid at rates much lower than the private and governmental sectors. Legal Aid Society of Salt Lake employs five full-time attorneys. Any increases in bar dues will result in even fewer resources that Legal Aid Society of Salt Lake has available to provide services to victims of domestic violence and low-income individuals in family law cases.
    In the event the court authorizes an increase in bar dues, Legal Aid Society of Salt Lake would respectfully request that the Supreme Court implement a waiver of the proposed increase for attorneys who are employed at 501(c)(3) non-profit organizations that provide free or low-cost legal services to low income and at-risk individuals and families. Such a waiver would allow qualified civil legal service providers to pay the current bar dues rates. By authorizing such a waiver, the Utah Courts and Utah State Bar would demonstrate their stated commitment to supporting access to justice to all citizens of Utah.
    Respectfully submitted:
    Elizabeth A. Hruby-Mills,
    President, Board of Trustees
    Legal Aid Society of Salt Lake

  21. Tracy R. Justesen

    Chief Justice Durham
    Utah State Supreme Court
    Salt Lake City, Utah
    Re: Proposed Increases to Bar Dues
    Chief Justice Durham:
    On behalf of the Disability Law Center (DLC),I write to oppose the proposed increases to bar dues. The DLC provides critical services to thousands of Utah’s citizens with disabilities and their families each year. The DLC’s work of enforcing and strengthening laws that protect the opportunities, choices, and legal rights of people with disabilities is increasingly strained by costs that detract from our ability to meet the needs of our communities.
    The DLC operates on a shoestring budget dependent on contributions from generous benefactors, state and federal grants, and limited federal funding sources. Today’s poor economic conditions further reduce our efforts to enhance even minimal services.
    Attorneys and staff of the DLC do not receive salaries or other benefits comparable to those working for the private bar. To impose an increase in bar dues at this time would be burdensome on our attorneys.
    If the court allows an increase in bar dues, the DLC respectfully requests that the Supreme Court implement a waiver of increases for attorneys who are employed at nonprofit organizations that provide free or low-cost legal services to those who qualify for services. This waiver would help ensure that many of Utah’s citizens have access to qualified legal representation.
    Respectfully submitted,
    Tracy R. Justesen
    Managing Attorney
    Disability Law Center
    205 North 400 West
    Salt Lake City, UT 84103