The recent leak of internal Supreme Court memoranda to the New York Times, discussed earlier by Jonathan Adler and Josh Blackman—as well as by Will Baude and Jack Goldsmith elsewhere—was plainly a serious violation of the Court's confidentiality obligations. But it may also reflect serious legal-ethics violations by one of the Times article's coauthors, Adam Liptak, whom I understand to be a licensed attorney in New York and subject to that state's Rules of Professional Conduct.
* * *
There are at least two theories under which Liptak may have violated the ethics rules.
