Judge Bonnie “The Actor” Rangel Slapped for Failure to Maintain a Law License Again; this is her Seventh Suspension

During its meeting on June 5-6, 2019, the State Commission on Judicial Conduct concluded a review of the allegations against the Honorable Bonnie Rangel, 171 st District Court Judge, El Paso County, Texas. Judge Rangel was advised by letter of the Commission’s concerns and provided a written response.

Judge Rangel appeared before the Commission on June 5, 2019, and gave testimony.

After considering the evidence before it, the Commission entered the following Findings and Conclusions:

FINDINGS OF FACT

1. At all times relevant hereto, the Honorable Yvonne “Bonnie Rangel” Guaderrama was the Judge for the 171 st District Court of Texas, El Paso County, Texas.

2. The Commission received two anonymous complaints alleging that Judge Rangel’s license to practice law in Texas had been administratively suspended in September 2018.

3. According to the Supreme Court of Texas’ records, Judge Rangel’s law license has been administratively suspended on the following occasions due to her failure to timely pay her bar dues: Administrative Judicial Region of Texas confirmed that Judge Turcotte submitted his recusal paperwork with their office on November 29, 2018.

According to the records, Yvonne R. Guaderrama was suspended from the active rolls for non-payment of dues and reinstatement from the date dues were paid to inception of suspension (Article Ill, Section 7(A), State Bar Rules), on the following dates respectively:

SUSPENDED

September 01, 2018
September 01, 2011
September 02, 2008
September 04, 2002
September 01, 2001
September 01, 1996
September 01, 1992

REINSTATEMENT GRANTED

October 03, 2018
September 06, 2011
February 04, 2009
September 20, 2002
December 12, 2001
October 24, 1996
October 21, 1992

4. The State Bar of Texas sends an annual notification to every licensed attorney on or about May 1 that their dues must be submitted by June 1. Attorneys are not administratively suspended for failing to pay their bar dues until September 1.

5. According to the State Bar’s records, Judge Rangel was sent an invoice on May 1, 2018, and a reminder on July 1, 2018, about her obligation to pay her bar dues. On September 3, 2018, after her law license was administratively suspended, Judge Rangel mailed a check in the amount of $235 to the State Bar of Texas. On September 18, 2018, the State Bar of Texas notified Judge Rangel that she was required to pay an additional penalty in order to have her law license reinstated. In early October 20 I 8, Judge Rangel submitted the requisite funds to the State Bar of Texas, and her law license was reinstated.

6. On October 14, 2018, El Paso Inc., a local weekly business journal, published an article entitled “What about a judge ruling without a law license?” The article reported the most recent administrative suspension of Judge Rangel ‘s law license. Judge Rangel reportedly told the journal that “her life was up in the air in August because she was moving from one home to another, and she didn’t see the notice from the state bar that her $235 annual dues payment had to be in by Aug. 31.” The judge was further quoted as saying that she “didn’t even know about it because [her] court coordinator was not diligent with the mail.”

7. In her written responses to the Commission, Judge Rangel stated that she believed the instant complaint was filed as a result of a rumor that she was going to run for the El Paso Court of Appeals, and characterized it as “hater mail, alleging disingenuous allegations that make no sense.”

8. Judge Rangel requested that the Commission “disregard all previous alleged suspensions” because they occurred at least seven years ago and that “our legal system has safeguards in place, i.e., statutes of limitations, to protect individuals from having to defend themselves after a certain period of time has elapsed.”

9. The judge stated that she “could not recall any facts” regarding her administrative suspensions in 2001, 2002 and 2008. Judge Rangel explained that up until 2010, El Paso County covered all of the judges’ bar dues, and her administrative suspension in 2011 “may have been due to the fact that [she] was unaware that El Paso County was no longer paying the Judges’ dues.”

10. Judge Rangel explained that there was a “short delay” in submitting her dues because her home “had been ransacked and burglarized on July 17, 2018” and, as a result, she moved residences on August 16, 2018.

11. The judge included an affidavit from her court coordinator, Rebecca Gonzalez, who testified, in pertinent part:

“I am presently the Court Coordinator for Judge Rangel, 171st Judicial District Court .. .In this capacity, my duties include retrieving the mail on a regular basis … the mail that I picked up in September 2018 was inadvertently put in the bottom of one of my stacks of work papers. Therefore, I did not open or disseminate this mail to Judge Rangel nor did I apprise Judge Rangel of this mail or its contents. I assume personal responsibility for this big mistake, and I realize that my actions caused Judge Rangel to be unaware of her administrative suspension at the earliest date possible and prior to public/media knowledge.”

12. Judge Rangel concluded that once she was made aware of her administrative suspension, she immediately wrote a check in the amount of her bar dues and late penalty to the State Bar of Texas.

13. During her appearance before the Commission, Judge Rangel acknowledged that it was solely her responsibility to ensure that her bar dues were timely remitted to the State Bar of Texas.

RELEVANT STANDARDS

1. Canon 2A of the Texas Code of Judicial Conduct, states, in pertinent part: “A judge shall comply with the law …. ”

2. Article V, Section l-a(6)A of the Texas Constitution provides, in relevant part, that a judge can be sanctioned for “willful or persistent conduct that is clearly inconsistent with the proper performance of his duties or casts public discredit upon the judiciary or administration of justice.”

3. Article V, § 7 of the Texas Constitution provides that “[e]ach district judge shall be …licensed to practice law in this State …. ”

4. Article III, § 3 of the Texas State Bar Rules provides that “[a]ll membership fees shall be payable at the time of enrollment as a member of the State Bar and annually thereafter on the first day of the State Bar’s fiscal year.”

5. Article III, § 5 of the Texas State Bar Rules provides that “(i]f a member is in default of payment of membership fees or any assessment levied by the Court on the thirtieth day after the due date, the clerk shall forthwith notify the member of default. If the fees and assessments are not paid on
or before sixty (60) days after the mailing of the notice of default, the defaulting member shall be automatically suspended from the practice of law. Any practice of law during such suspension shall constitute professional misconduct and subject the member to discipline.”

6. Article III, § 7(A) of the Texas State Bar Rules provides that “[ w ]hen a member, who has been suspended for nonpayment of fees or assessments, removes such default by payment of fees or assessments then owing, plus an additional amount equivalent to one-half the delinquency, the suspension shall automatically be lifted and the member restored to former status. Return to former status shall be retroactive to inception of suspension, but shall not affect any proceeding for discipline of the member for professional misconduct.”

7. The State Bar rules have the same effect as statutes. Cushnie v. The State Bar, 845 S.W.3d 358, 359 (Tex.App.-Houston [1st Dist.] 1992, writ denied) citing State Bar of Texas v. Wolfe, 801 S.W.2d 202,203 (Tex.App.-Houston [1st Dist.] 1990, no writ).

CONCLUSION

The Commission concludes from the facts and evidence presented that on five separate occasions, Judge Rangel failed to maintain her Texas law license in good standing pursuant to Article V, 7 of the Texas Constitution, in violation of Canon 2A of the Texas Code of Judicial Conduct.

Furthermore, these actions constitute willful and persistent conduct clearly inconsistent with the proper performance of her duties as a judge, and cast public discredit upon the judiciary and administration of justice, in violation of Article V, § l-a(6)A of the Texas Constitution.

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In condemnation of the conduct described above that violated Canon 2A of the Texas Code of Judicial Conduct and Article V, Section 1-a(6)A of the Texas Constitution, it is the Commission’s decision to issue a PUBLIC WARNING to the Honorable Bonnie Rangel, 171 st District Court Judge, El Paso County, Texas, pursuant to the authority contained in Article V, § l-a(8) of the Texas Constitution.

The Commission has taken this action in a continuing effort to protect the public confidence in the judicial system and to assist the state’s judiciary in its efforts to embody the principles and values set forth in the Texas Constitution and the Texas Code of Judicial Conduct

A bizarre online video surfaced late Tuesday night depicting District Court Judge Bonnie Rangel in what appears to be a fictitious television show, “Judge Bonnie’s Court.”

Rangel has been the sitting judge in El Paso’s 171st District Court since 2010. She told KTSM the video was created to explore the possibility of launching a TV show similar to “Judge Judy.” Rangel said the video, which she began working on in 2011 or 2012, did not go anywhere. She said she does not know why the video has resurfaced.

“This was a retirement plan that has not been successful,” Rangel said. “It’s a little embarrassing that my plan has not been successful.”

The nearly 4-minute long video begins with Judge Rangel driving a car and being involved in a car crash.The video then cuts to her on the bench in a fictitious court case involving a minor. In the case, the girl asks for her parents to pay for her birth control. Judge Rangel appears to counsel the parents.

“Mom and Dad, let’s do this. Let’s show her video of a birth with a vagina that’s stretching to the size of a watermelon,” Rangel said in the video. “We can show her pictures of penises oozing with puss due to a sexually transmitted disease. These are the possible consequences of having sex, sweetheart.”

Rangel said she is not worried about reaction to the video. She believes it’s true to how she counsels from the bench.

“It’s real life lessons I was trying to portray about 13-year-old kids having sex,” Rangel said. “These are consequences. I provide visual and real life consequences that hit home.”

Rangel, who is out of town and unavailable for an on-camera interview said, she is surprised the video is making the rounds on social media.

“What caught me by surprise is that my retirement plan gone awry is newsworthy,” she said. “I’m looking to invest in real estate now. Will that be newsworthy, too?”