Overview. Collins failed to obey five civil sanctions orders. He stipulated to facts and culpability, then tried the case only on aggravation/mitigation. The hearing judge sua sponte dismissed, but the Review Department reversed, enforcing the stipulation and recommending a 30-day actual suspension.

Key Holdings. When an attorney has actual notice of sanctions orders and does not object, seek reconsideration, or appeal, they must comply and cannot collaterally attack the orders later in State Bar proceedings. Stipulated facts are binding; the court would not revisit whether Collins was personally responsible after he had stipulated that he was jointly and severally liable.

Discipline Rationale. Even with mitigation and OCTC seeking only stayed suspension, the applicable Standard called for actual suspension (or disbarment) for willful disobedience of court orders. Given five separate orders and no proof of payment, the court imposed 30 days’ actual suspension with probation and restitution as a condition.