A coalition of more than 100 legal scholars, retired judges, and legal advocacy organizations filed a 23-page ethics complaint against former Attorney General Pamela Bondi with the Florida Bar on Wednesday, accusing her of coercing DOJ lawyers, mishandling Epstein victim records, and directing prosecutors to bring charges without probable cause.
Peggy Quince, a retired chief justice of the Florida Supreme Court and board member of Lawyers Defending American Democracy (LDAD), led the filing, with LDAD, Democracy Defenders Fund, and Lawyers for the Rule of Law joining as co-signatories. The complaint re-alleges charges from a June 2025 filing the Florida Bar refused to investigate while Bondi was in office, and adds new violations arising from conduct that occurred after that filing.
“As the former chief justice of this state’s highest court, there are key principles that we must protect,” Quince said. “Whatever legal position you have achieved, you are still bound to follow the Rules of Professional Conduct. All lawyers are alike in that regard, and no one lawyer is above the law.”
The Allegations
All four categories of misconduct in the complaint trace back to a memorandum Bondi sent to all DOJ employees on her first day as attorney general, February 5, 2025, establishing what the complaint calls a “fall-in-line-or-be-gone” philosophy.
The memo, titled General Policy Regarding Zealous Advocacy on Behalf of the United States, directed DOJ attorneys to prioritize the president’s policy objectives and threatened discipline or termination for any lawyer who “because of their personal political views or judgments declines to sign a brief or appear in court.” The complaint argues the memo violated Florida Bar rules by requiring lawyers to discard their independent professional judgment under threat of termination.
Coercion of DOJ lawyers. Bondi’s managers used the memo as a pretext to punish attorneys who complied with their ethical obligations. The complaint names Erez Reuveni, whom superiors fired after he made candid concessions to a federal judge in Maryland about why the government had deported Kilmar Garcia to El Salvador. The judge thanked Reuveni three times for his “candor.” A panel of Fourth Circuit judges later noted the administration had placed him on administrative leave “ostensibly for lack of ‘zealous advocacy'” while “the duty of zealous representation is tempered by the duty of candor to the court.”
A second case involves Denise Cheung, an assistant US attorney in Washington, DC, who refused to open a criminal investigation her supervisors sought where she and senior colleagues found the evidence insufficient. She also declined to sign a letter to a bank asserting probable cause she did not believe existed. Both attorneys lost their positions. Citing a USA Today report, the complaint notes a net loss of approximately 2,500 DOJ lawyers with an average of 14 years of experience during Bondi’s tenure.
Epstein files mishandling. Bondi failed to supervise subordinate officers reviewing and releasing the Jeffrey Epstein files in violation of the Epstein Files Transparency Act, exposing the personal information of nearly 100 individual survivors. One lawyer cited in the complaint called it “the single most egregious violation of victim privacy in one day in United States history.” The filing came days before House lawmakers are set to question Bondi about her role in the documents’ release.
Violations of court orders. Bondi permitted and incentivized DOJ attorneys to violate court orders across dozens of cases — a pattern the complaint describes as unprecedented in scope.
Charges without probable cause. Bondi and her subordinates repeatedly sought to bring charges against protesters, vulnerable parties, and the president’s “political enemies” without the evidentiary basis required under Florida Bar Rule 4-3.8(a).
Why Now
President Trump removed Bondi on April 2, 2026. When the coalition filed against her in June 2025, the Florida Bar declined to investigate, citing a rule barring it from pursuing complaints against “sitting officers appointed under the U.S. Constitution while they are in office.” The coalition challenged that position in a mandamus petition to the Florida Supreme Court, which rejected it in October 2025.
The Bar then amended its Rules of Discipline in December 2025 to formally define federal officials as “constitutional officers” — a change the complainants argued was itself evidence that the original exemption had never applied to federal officials. With Bondi out of office, that question is moot: under Rule 3-7.16(d), complainants may file against former constitutional officers within six years of the date they vacated office.
The complaint also argues the Bar is not merely permitted but required to act. Under Rule 3-7.3(a), Bar counsel must investigate any complaint alleging facts that “if proven, would constitute a violation of the Rules Regulating The Florida Bar.”
“The attorney general has the awesome responsibility to set a national example of ethical behavior — and to ensure that DOJ lawyers live up to that standard,” said James W. Conrad Jr., an LDAD volunteer and principal author of the complaint. “From her first day as attorney general, Bondi did just the opposite, personally and repeatedly violating ethical standards and coercing Department lawyers into violating their own professional responsibilities if they wanted to keep their jobs.”
Also read: Pam Bondi Diagnosed With Thyroid Cancer Weeks After Being Fired as Attorney General
The complaint invokes the federal McDade Amendment, 28 U.S.C. § 530B, which binds all DOJ attorneys — including the attorney general — to the ethics rules of the state where they hold their bar license. Because Bondi holds a Florida Bar license and is not admitted to the DC Bar, Florida’s Rules of Professional Conduct governed her conduct throughout her tenure.
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