(2) At least 7 of the 45 units will be devoted to continuing legal education specifically addressed to legal or judicial ethics. This requirement shall be effective for all three-year compliance periods beginning on or after January 1, 1992.

      (3) All registered attorneys admitted after January 1, 1979, shall become subject to the minimal educational requirements set forth in these rules on the date of their initial admission to the bar of the State of Colorado. Their first compliance period shall begin on that date and end on December 31 of the third full calendar year following the year of admission.

      (4) This subsection 4 is repealed and replaced by 201.14(3).

      (5) Upon being reinstated pursuant to Paragraphs (3) or (8) of Rule 227A, any registered attorney who has been suspended under Paragraph (2) of Rule 227A, shall become subject to the minimum educational requirements set forth in these rules on the date of reinstatement. The first compliance period shall begin on that date and end on December 31 of the third full calendar year following the year of reinstatement, provided the date of reinstatement is more than one year after the date of suspension or transfer to inactive status. Otherwise, the compliance period shall be the same as it would have been absent the suspension or transfer.

      (6) Units of continuing legal education completed after the adoption of this rule by the Supreme Court and prior to January 1, 1979, may be used to meet the minimum educational requirement for the first applicable compliance period. Units of continuing legal education completed in excess of the required units of continuing legal education in any applicable compliance period may not be used to meet the minimum educational requirements in any succeeding compliance period.

      Source: (2) amended June 20, 1991, effective January 1, 1992; entire rule amended October 13, 1994, effective January 1, 1995; (4) amended and adopted effective April 23, 1998; (4) repealed and adopted March 21, 2003, effective July 1, 2003.

      ANNOTATION

      Law reviews. For article, “Mandatory Continuing Legal Education: A Study of its Effects”, see 13 Colo. Law. 1789 (1984).

      Deprivation of due process claim requires only minimal scrutiny. A person’s “right” or “privilege” in the practice of law, has never been among those held to be “fundamental”, so only minimal scrutiny under the rational basis test is required to evaluate claims of deprivation of such a “right” without due process. Verner v. Colo., 533 F. Supp. 1109 (D. Colo. 1982), aff’d, 716 F.2d 1352 (10th Cir. 1983), cert. denied, 466 U.S. 960, 104 S. Ct. 2175, 80 L. Ed.2d 558 (1984).

      Rule does not violate prohibition against involuntary servitude. The requirement that attorneys attend education classes does not violate the thirteenth amendment prohibition against involuntary servitude. Verner v. Colo., 533 F. Supp. 1109 (D. Colo. 1982), aff’d, 716 F.2d 1352 (10th Cir. 1983), cert. denied, 466 U.S. 960, 104 S. Ct. 2175, 80 L. Ed.2d 558 (1984).

      Rule does not violate first amendment. This rule does not violate any alleged first amendment right “not to be forced to hear speeches or assemblies”. Verner v. Colo., 533 F. Supp. 1109 (D. Colo. 1982), aff’d, 716 F.2d 1352 (10th Cir. 1983), cert. denied, 466 U.S. 960, 104 S. Ct. 2175, 80 L. Ed.2d 558 (1984).

      Strict requirements may be set. If states can set strict legal proficiency related requirements for admission to the bar, it follows that they may also set strict proficiency related requirements for continuing legal practice. Verner v. Colo., 533 F. Supp. 1109 (D. Colo. 1982), aff’d, 716 F.2d 1352 (10th Cir. 1983), cert. denied, 466 U.S. 960, 104 S. Ct. 2175, 80 L. Ed.2d 558 (1984).