Pursuing Client Advocacy Within the Bounds of Civility and Professional Standards: What’s Zeal Got to Do With It? (Presented by the Federal Bar Association’s Professional Development Committee, Ethics Subcommittee)

Denise M. Quinterri
Denise M. Quinterri | Law Office of Denise M. Quinterri, PLLC

Denise M. Quinterri focuses her practice on legal ethics and professional responsibility. She formerly served as Bar Counsel for the State Bar of Arizona.

Live Video-Broadcast: October 15, 2026

1 hour CLE

Tuition: $395.00
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Program Summary

 

What happens when a court reads the Preamble back to you?

In Vogt v. Walls Real Estate Co., 727 S.W.3d 813 (2025), a lawyer failed to appear for a civil trial set on a mutually agreed date. Judgment was entered against his client. The appellate court upheld the judgment, yet agreed a courtesy call would have been “the better practice.” Its authority: the Preamble, which ties “zealously” pursuing a client’s interests to “maintaining a professional, courteous, and civil attitude.”

The stakes are already concrete. Miss an agreed court date, and your client absorbs the judgment. Skip the courtesy call, and an appellate opinion names the omission. Treat the Lawyer’s Creed and the Preamble as aspirational only, and the discipline question is squarely in play. Push zeal past civility, and the duty to your client collides with your professional obligations.

Attendees leave able to spot conduct that may be viewed as a breach of professionalism. The session maps where professionalism rules overlap the ethics rules, tests the line against common hypotheticals from practice, and closes with related real-life case law. What you walk out with is a practitioner’s framework for when courtesy is optional — and when it is not.

Presented by the Federal Bar Association’s Professional Development Committee, Ethics Subcommittee

Key topics to be discussed:

  • Zeal Within Bounds
    How Vogt v. Walls Real Estate Co., 727 S.W.3d 813 (2025), and the Preamble to the Rules of Professional Conduct frame zealous advocacy within civility.
  • Courtesy Call Duties
    When circumstances may create an ethical duty to remind opposing counsel of a court date.
  • Client Versus Profession
    How far the duty to your client may conflict with your professional obligations.
  • Spotting Professionalism Breaches
    What other types of issues may be viewed as a breach of professionalism.
  • Aspirational or Enforceable
    Whether the standards set forth in the Lawyer’s Creed and the Preamble are aspirational only, and whether violations can result in discipline.
  • Overlap and Case Law
    Where professionalism rules overlap the ethics rules, tested through common practice hypotheticals and related real-life case law.

This course is co-sponsored with myLawCLE.

Date / Time: October 15, 2026

  • 2:00 pm – 3:00 pm Eastern
  • 1:00 pm – 2:00 pm Central
  • 12:00 pm – 1:00 pm Mountain
  • 11:00 am – 12:00 pm Pacific

Closed-captioning available

Speakers

Denise M. Quinterri | Law Office of Denise M. Quinterri, PLLC

Denise M. Quinterri focuses her practice on legal ethics and professional responsibility. She formerly served as Bar Counsel for the State Bar of Arizona.

  • Education & Credentials

Ms. Quinterri earned her J.D., cum laude, from the University of Arizona, James E. Rogers College of Law (2000). She received her B.A. in Sociology, summa cum laude, from the University of Arizona (1997), where she was elected to Phi Beta Kappa and earned Dean’s Honor Lists recognition, ABWA scholarships, and the Yoshino public interest award.

  • Recognition & Leadership

Ms. Quinterri has been recognized in The Best Lawyers in America© for Ethics and Professional Responsibility and is rated AV® Preeminent™ by Martindale-Hubbell.

  • Professional Involvement

She enjoys presenting at the occasional CLE seminar or conference and is an active member of the Association of Professional Responsibility Lawyers.

  • Experience

After leaving the Bar she worked for David D. Dodge, a highly respected ethics attorney, with whom she continued to collaborate until his retirement. Ms. Quinterri represents lawyers in State Bar proceedings (“Bar complaints”) and applicants in the Character and Fitness process. She also provides expert opinion letters.

Ms. Quinterri is highly experienced in lawyer discipline, having personally handled well over 500 bar complaints. She has represented over 300 applicants to the State Bar of Arizona in the Character and Fitness process. She understands various aspects of the practice, having worked at a large law firm, a small to mid-size law firm, as a solo attorney, and for a non-profit, quasi-governmental organization.

Agenda

SESSION 1 – Pursuing Client Advocacy Within the Bounds of Civility and Professional Standards: What’s Zeal Got to Do With It? | 2:00pm – 3:00pm

In a recent Missouri case, a lawyer failed to appear for a civil trial with a mutually agreed upon date. Judgment was entered against his client. The lawyer appealed, arguing that it was an abuse of discretion for the trial court to have proceeded in his absence without at least a courtesy call (by either the Court or the opposing counsel). Although the appellate court upheld the judgment, the Court agreed that a courtesy call would have been “the better practice.” In support for that statement, the Court cited a section of the Preamble to the Rules of Professional Conduct: “A lawyer has the obligation to ‘zealously’ protect and pursue his or her client’s legitimate interests within the bounds of the law ‘while maintaining a professional, courteous, and civil attitude toward all persons involved in the legal system.’” Are there circumstances in which there is an ethical duty to remind your opposing counsel of a court date? To what extent may your duty to your client conflict with your professional obligations? These concepts will be explored in this seminar.

Credits

Alaska

Approved for CLE Credits
1 Ethics

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Pending CLE Approval
1 Ethics

Arkansas

Approved for CLE Credits
1 Ethics

Arizona

Approved for CLE Credits
1 Professional Responsibility/Ethics

California

Approved for CLE Credits
1 Civility in the Legal Profession

Colorado

Pending CLE Approval
1 Ethics / Professionalism

Connecticut

Approved for CLE Credits
1 Ethics / Professionalism

District of Columbia

No MCLE Required
1 CLE Hour(s)

Delaware

Pending CLE Approval
1 Enhanced Ethics

Florida

Pending CLE Approval
1 Professionalism

Georgia

Pending CLE Approval
1 Professionalism

Hawaii

Approved for CLE Credits
1 Ethics or Professional Responsibility Education

Iowa

Pending CLE Approval
1 Ethics

Idaho

Pending CLE Approval
1 Ethics / Professionalism

Illinois

Pending CLE Approval
1 Professinalism

Indiana

Pending CLE Approval
1 Ethics

Kansas

Pending CLE Approval
1 Ethics / Professionalism

Kentucky

Pending CLE Approval
1 Ethics

Louisiana

Pending CLE Approval
1 Professionalism

Massachusetts

No MCLE Required
1 CLE Hour(s)

Maryland

No MCLE Required
1 CLE Hour(s)

Maine

Pending CLE Approval
1 Ethics / Professionalism

Michigan

No MCLE Required
1 CLE Hour(s)

Minnesota

Pending CLE Approval
1 Ethics

Missouri

Approved for CLE Credits
1.2 Ethics

Mississippi

Pending CLE Approval
1 Other (Professional Responsibilty)

Montana

Pending CLE Approval
1 Professional Fitness and Integrity

North Carolina

Pending CLE Approval
1 Ethics

North Dakota

Approved for CLE Credits
1 Ethics

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
1 Professional Responsibility

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
60 Ethics / Professionalism minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
1 Ethics / Professionalism

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for CLE Credits
1 Ethics / Professionalism

Nevada

Pending CLE Approval
1 Ethics / Professionalism

New York

Approved for CLE Credits
1 Ethics / Professionalism

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Pending CLE Approval
1 Professional Conduct

Oklahoma

Pending CLE Approval
1 Ethics / Professionalism

Oregon

Pending CLE Approval
1 Ethics

Pennsylvania

Approved for CLE Credits
1 Ethics / Professionalism

Rhode Island

Pending CLE Approval
1 Ethics / Professionalism

South Carolina

Pending CLE Approval
1 Ethics / Professionalism

South Dakota

No MCLE Required
1 CLE Hour(s)

Tennessee

Pending CLE Approval
1 Dual

Texas

Approved for CLE Credits
1 Ethics / Professionalism

Utah

Pending CLE Approval
1 Professionalism & Civility

Virginia

Not Eligible
1 Ethics / Professionalism Hours

Vermont

Approved for CLE Credits
1 Ethics

Washington

Approved via Attorney Submission
1 Other (Professional Development) Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Pending CLE Approval
1 Ethics

West Virginia

Pending CLE Approval
1.2 Ethics / Professionalism

Wyoming

Pending CLE Approval
1 Ethics / Professionalism

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