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What are the CLE requirements for inactive attorneys in Missouri?

If an attorney in Missouri holds an inactive license (under Rule 6.03), they have no obligation to complete CLE hours or file an annual MCLE report during that inactive period.

However, to return to active status, the attorney must complete at least 15 credit hours of continuing legal education within the 12 months prior to applying, including at least 3 hours of ethics (with 1 hour on bias/diversity).

Details:

  • Missouri’s MCLE rules allow inactive or “non-practicing” attorneys to claim exemption from the standard 15-hour requirement during their inactive period.
  • Upon applying for return to active status under Rule 6.06, the lawyer must submit certification of completing 15 CLE credits (3 ethics, 1 on bias/diversity) in the preceding 12 months.
  • Up to 6 of the 15 hours may be earned by self-study, but self-study credit cannot satisfy the mandatory ethics or bias credits.
  • Missouri does not accredit on-demand programming; such content may only count as self-study credit, not toward the ethics/bias requirement.
  • CLE earned toward reactivation may also count for the regular MCLE reporting period under Rule 15 if the credits fall within that cycle.

Key Takeaway:
Missouri grants inactive attorneys an MCLE exemption during inactivity, but demands a 15-credit CLE package (with ethics and bias credits) within the prior 12 months to restore active status.

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