Inactive Attorneys

New York does not have a status labeled “inactive attorney” for CLE purposes; instead, attorneys who do not practice law in New York during a reporting cycle may be exempt from CLE under 22 NYCRR § 1500.5(b)(1).

If an attorney certifies as retired (under 22 NYCRR § 118.1(g)), that attorney is exempt from CLE entirely.

Details:

• All New York attorneys are presumed to practice law in the state; to claim exemption, the attorney must show they did

Attorneys on inactive status in Maine are exempt from Maine’s mandatory CLE requirement under Bar Rule 5.

That exemption applies only during the period of inactive status; once reinstated to active status, CLE obligations resume.

Details:

• Maine Bar Rule 5 explicitly lists “attorneys in inactive status pursuant to Rule 6(c)” as exempt from the annual CLE

New Mexico attorneys on inactive status are exempt from CLE requirements while that status is in effect.

Upon reinstatement to active status, they must evaluate and cure any CLE deficits (from the year they became inactive and the year they return) and thereafter comply with the full active CLE obligations.

Details:

• Inactive status is defined under Rule 24-102.2 NMRA; members “not currently practicing law” may apply for inactive

Massachusetts does not require continuing legal education (CLE) for attorneys—active or inactive.

Since CLE is not mandatory in Massachusetts, changing to inactive status does not affect CLE obligations (because there are none).

Details:

• CLE for lawyers in Massachusetts is entirely voluntary; the state has no rule imposing mandatory CLE.
• An attorney may

There is no express provision in Mississippi’s CLE rules that explicitly exempts attorneys on inactive status from MCLE obligations.

Mississippi law classifies “inactive members” as those not engaged in the practice of law, and allows them to enroll as inactive—but the statute mandates that the Bar “shall promulgate rules … regarding continuing legal education requirements between active and inactive status.” (Miss. Code § 73-3-120)

Details:

• Mississippi’s MCLE rules require active attorneys to complete 12 CLE hours annually, including 1 hour in

If an attorney in Texas holds “inactive membership status” and is inactive for the entire MCLE compliance year, they are exempt from reporting or completing MCLE credits.

Reporting exemption is tied to membership status—not practice activity—and does not depend on whether the attorney provided legal services.

Details

• Rule 5.4 of the Texas MCLE Regulations states that an attorney who maintains inactive membership status for the full

Inactive members in Idaho are not required to meet the MCLE credit requirement during their inactive status.

Inactive status allows an attorney to retain Bar membership without fulfilling CLE, provided they do not practice law in Idaho.

Details:

• Inactive members are exempt from mandatory continuing legal education (MCLE) that active or house counsel members must

Attorneys on inactive status in Hawaii are exempt from the CLE requirement.

Upon electing active status, they must complete and report 3 hours of approved CLE (including 1 hour of ethics) within three months.

Details:

• Hawaii’s MCLE rules classify inactive members as exempt from CLE obligations.
• Upon status change to active, the

North Dakota does not provide a formal exemption for “inactive attorneys” in its CLE rules.

When a lawyer applies for re-licensure after a lapse, North Dakota Rule 8 requires CLE credits depending on how long the attorney has been unlicensed, including required ethics hours.

Details:

• Under Rule 8(A)(1), if the applicant was unlicensed less than two years, they must show 12 CLE credits (including 1

Inactive attorneys in Oregon have no MCLE obligation while in inactive status.

Upon reactivation, such members must comply with all active-member MCLE rules and meet reinstatement requirements.

Details

• Inactive Status: Members “not engaging in the practice of law” owe no MCLE, IOLTA, or PLF obligations.
• Active MCLE

Inactive, honorary, retired, and emeritus Wyoming attorneys are exempt from the obligation to obtain or report CLE credits.

This exemption is granted under Rule 8 of the Wyoming CLE rules and recognized annually for those non-active categories.

Details

• Wyoming’s CLE FAQs state that “inactive, honorary and retired members are not required to fulfill the CLE

Attorneys in Nebraska on inactive status are exempt from CLE obligations while holding that status.

When reinstating to active status, such attorneys must complete 10 hours of approved CLE in the 12 months immediately preceding their application, including 2 hours in professional responsibility.

Details:

• Rule § 3-401.5 exempts attorneys during the time they are on inactive status under Neb. Ct. R. § 3-803(B)(2).
• Section

Inactive members of The Florida Bar are automatically exempt from the CLE (CLER) requirement under Rule 6-10.3(c)(1).

When an inactive member returns to active status, any outstanding CLE or basic skills (BSCR) obligations must be satisfied before reinstatement.

Details:

• Rule 6-10.3(c)(1) explicitly exempts inactive members from the continuing legal education requirement.
• Inactive status

No CLE requirement exists for “inactive attorneys” in New Jersey—because “inactive status” is not recognized under New Jersey’s attorney regulation.

New Jersey’s CLE obligations apply only to attorneys who remain active with the Fund for Client Protection; those who do not pay or otherwise lose good standing are not placed into an “inactive” CLE-exempt category.

Details:

• New Jersey explicitly states there is no “inactive status” for attorneys, so you cannot shift into a CLE-exempt

An attorney who files an affidavit of inactivity in Indiana is exempt from the CLE (MCLE) educational and reporting requirements under Rule 29.

That exemption continues while the attorney remains in inactive status and is registered as such.

Details:

• Rule 29(c) provides that an attorney who files an affidavit of inactivity or retirement is exempt from CLE obligations.

Yes – Delaware provides CLE exemptions for attorneys on inactive, senior, or retired status, but CLE obligations resume if the attorney seeks reinstatement to active status. Inactive attorneys are not required to earn CLE credits while inactive, though reinstatement may require catch-up credits or specific courses depending on the length of inactivity.

Delaware CLE Rules for Inactive Attorneys

• Inactive exemption: Attorneys on inactive, senior, or retired status are exempt from Delaware’s mandatory CLE requirements while they remain in that status.
• Reinstatement obligation: Upon returning to active status, attorneys must satisfy CLE requirements for the period of inactivity as directed by the Delaware Supreme Court’s Commission on Continuing Legal Education.
• Extended inactivity (10+ years): Attorneys who have been inactive for 10 years or more must complete the Fundamentals of Lawyer-Client Relations course within one year of reinstatement.
• CLE credit upon reinstatement: The Commission may award CLE credit for approved courses completed during the inactive period if they meet Delaware accreditation standards.

Key Takeaway

Delaware exempts inactive, senior, and retired attorneys from ongoing CLE requirements. However, upon reinstatement to active status, attorneys must complete required CLE credits and, if inactive for more than 10 years, must take the Fundamentals course within one year.

North Carolina does not provide a CLE exemption simply for “inactive attorneys”—inactive status does not relieve the obligations that were due while active.

When an attorney petitions to return from inactive status, they must fulfill any CLE requirements applicable to the year they became inactive plus additional CLE for the period of inactivity (up to certain caps).

Details:

• Under Rule .0902, a reinstating attorney must satisfy the CLE requirement for the “subject year” (the year they left

Attorneys in Utah on inactive status are not required to meet any MCLE requirements during that period.

If returning after being inactive for 12 months or more, the attorney must complete a 12-hour accredited CLE requirement by the next June 30 compliance deadline.

Details

• Under UCJA Rule 11-605(a), lawyers on inactive status are not subject to MCLE obligations while inactive.
• Per UCJA Rule

There is no mandatory CLE requirement for attorneys in Michigan—so there is no separate rule for inactive attorneys.

Because Michigan imposes no MCLE obligations, attorneys may choose inactive status without affecting CLE obligations (since none exist).

Details:

• Michigan currently has no rule requiring attorneys (active or inactive) to complete CLE credits.
• Attorneys in Michigan

Inactive or retired Arizona attorneys are exempt from the annual CLE requirement so long as they remain in that status for the full educational year.

Details

• Rule 45(a) and its accompanying regulations state that a member who is inactive or retired for the entire educational year is exempt from the CLE obligations.
• Inactive or retired members are not required to file the annual MCLE affidavit.
• If an inactive or retired attorney seeks to return to active status, they must complete CLE equivalent to the active requirement for each of the last two years they were inactive or retired.

Key Takeaway: In Arizona, inactive attorneys don’t have to meet or report CLE credits while in inactive status — but to reactivate, they must catch up on CLE for the years they were inactive.