GOFF v. STATE BAR

NOTICE: NOT FOR OFFICIAL PUBLICATION.
UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL
AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE
ARIZONA COURT OF APPEALS
DIVISION ONE

RYAN C. GOFF, Petitioner/Appellant,

v.

STATE BAR OF ARIZONA, et al., Respondents/Appellees.

No. 1 CA-CV 26-0208
FILED 09-21-2026

Appeal from the Superior Court in Maricopa County
No. CV2025-036469
The Honorable Gregory Como, Judge

AFFIRMED

COUNSEL

Ryan C. Goff, Phoenix
Petitioner/Appellant

State Bar of Arizona, Phoenix
By James D. Lee
Counsel for Respondents/Appellees

MEMORANDUM DECISION

Judge Daniel J. Kiley delivered the decision of the Court, in which Presiding
Judge Andrew M. Jacobs and Chief Judge Randall M. Howe joined.

GOFF v. STATE BAR, et al.
Decision of the Court

K I L E Y, Judge:

¶1 After investigating an allegation that Ryan C. Goff had
engaged in the unauthorized practice of law (“UPL”), the State Bar of
Arizona (the “State Bar”) notified Goff by letter that the investigation was
being closed. The letter also informed Goff that the “investigation into the
matter will remain a matter of public record unless the superior court enters
a protective order[.]” Goff then petitioned for the entry of a protective
order, asking the superior court to “direct[]” the “removal of the file from
public records.” The superior court denied his petition. We affirm.

FACTS AND PROCEDURAL HISTORY

¶2 A business entity jointly owned by Goff and his sister filed a
lawsuit against a third party in superior court. Although he is not a licensed
attorney, Goff participated in the lawsuit on behalf of the entity.
Concluding that Goff had performed legal services without a license, the
assigned judge referred the matter to the State Bar.

¶3 After conducting a UPL investigation, counsel for the State
Bar sent Goff a letter in April 2025 informing him that the State Bar had
dismissed the charge.1 According to counsel’s letter, the State Bar
determined that Goff had, in fact, “engaged in the unauthorized practice of
law.” In light of its determination, however, that he “did not engage in the
practice of law as a business,” and instead was “attempting to assist [his]
sister and a business [they] co-owned,” the State Bar decided to dismiss the
charge with “an educational comment” informing Goff that “an owner of
[a] company may not represent [a] company in legal proceedings unless
s/he is an attorney or legal paraprofessional.” The letter concluded by
stating that the investigation “will remain a matter of public record unless
a superior court enters a protective order pursuant to Arizona Supreme
Court Rule 80(b)(6).”

¶4 Goff petitioned for a protective order to require the State Bar
to “remov[e]” the file “from public records,” alleging that the “[r]etention”
of the file, “despite no misconduct finding, imposes continuing harm . . .
and undermines his professional reputation.” Goff further argued that
making the file available to the public “violates due process” and “[e]qual
[p]rotection.” Finally, Goff alleged that the retention of the file “[v]iolates

1 A “charge” is “any allegation or other information of misconduct or
incapacity that comes to the attention of the state bar.” Ariz. R. S. Ct.
46(h)(4).

2

GOFF v. STATE BAR, et al.
Decision of the Court

the [Americans with Disabilities Act]” in light of his “documented
disabilities” and “need for accommodation.” In a later filing, he disputed
the State Bar’s assertion that he is a “nonlawyer,” insisting that he was an
“Accredited Representative” of the Executive Office for Immigration
Review (“EOIR”) and was authorized to “represent clients in immigration
proceedings.”

¶5 The State Bar opposed Goff’s petition, and the superior court
set the matter for an evidentiary hearing on January 14, 2026.

¶6 Before the hearing, the State Bar moved the court to take
judicial notice of the EOIR’s roster of accredited representatives as of
January 12, 2026, on which Goff’s name did not appear. See Ariz. R. Evid.
201. Goff opposed the State Bar’s motion, arguing that it “improperly seeks
to substitute administrative rosters for jurisdictional analysis, ignores
federal preemption, and mischaracterizes [his] federally protected
activities.” Although the record does not contain a transcript of the January
14 evidentiary hearing, the minute entry from the hearing reflects that the
superior court granted the State Bar’s motion and took judicial notice of the
EOIR roster.

¶7 After the hearing, the court issued a ruling denying Goff’s
petition. In so ruling, the court found that although the UPL charge was
dismissed, the State Bar “did in fact make an adverse finding” that Goff
“engaged in the unauthorized practice of law.” “A dismissal,” the court
noted, “is not the same as an exoneration.” The court further found that
Goff presented no evidence that the State Bar’s retention of the UPL file
constituted “extraordinary or inequitable treatment” or that failing to seal
the file would cause him “irreparable injury.” Denying all requested relief,
the superior court entered final judgment.

¶8 Goff timely appealed. We have jurisdiction under A.R.S.
§§ 12-120.21 and -2101(A)(1).

DISCUSSION

¶9 Goff argues that the court erred in denying his petition for a
protective order to remove his UPL investigation file from the public
record.2

2 In his opening brief, Goff contends that he merely requested the
“[t]emporary sealing” of “portions” of the State Bar’s file. This assertion is

3

GOFF v. STATE BAR, et al.
Decision of the Court

¶10 This Court reviews “the interpretation of a court rule de novo
and according to the principles of statutory interpretation.” Goldman v. Sahl, 248 Ariz. 512, 522, ¶ 29 (App. 2020). We review a ruling on a protective
order for an abuse of discretion. Zwicky v. Premiere Vacation Collection
Owners Ass'n, 244 Ariz. 228, 233, ¶ 22 (App. 2018). A court “abuse[s] its
discretion if it commit[s] an error of law in formulating its ruling.” Mobilisa,
Inc. v. Doe, 217 Ariz. 103, 107, ¶ 9 (App. 2007) (citation omitted). “We defer
to the court's factual findings unless they are clearly erroneous or
unsupported by substantial evidence.” Advantage Pool & Spa Plumbing, Inc.
v. Miles, 261 Ariz. 509, 512, ¶ 8 (App. 2026) (citation omitted).

¶11 Authority to regulate the practice of law in Arizona is vested
in the Arizona Supreme Court. Scheehle v. Justices of the Sup. Ct. of Ariz., 211
Ariz. 282, 290, ¶ 29 (2005). The procedure governing UPL proceedings is set
forth in the Rules of the Supreme Court of Arizona (the “Supreme Court
Rules”). Ariz. R. S. Ct. 75(a). Rule of the Supreme Court of Arizona (“Rule”)
80(b) provides that records of dismissed UPL cases are generally “open to
the public.” Ariz. R. S. Ct. 70, 80(b)(1)(A). Subsection 6 of Rule 80(b)
provides, however, that “[u]pon motion by a party . . . and for good cause
shown, the superior court . . . may order that a portion of the . . . state bar
file be sealed[.]” Ariz. R. S. Ct. 80(b)(6).

¶12 Goff argues that the superior court did not properly evaluate
his petition under the standards set forth in Rule 80(b)(6). Specifically, he
contends that the court “failed to properly evaluate irreparable harm.” But
the minute entry reflects that the court found that Goff failed to establish
that the failure to seal the file would cause “irreparable injury.” Because
Goff has not provided us with a transcript of the hearing, we must presume
that the evidence presented at the hearing supports the court’s ruling. See
McGlothlin v. Astrowsky in and for County of Maricopa, 255 Ariz. 449, 460, ¶ 35
(App. 2023) (“A party is responsible for making certain the record on appeal
contains all transcripts or other documents necessary for us to consider the
issues raised on appeal. When a party fails to include necessary items, we
assume they would support the court’s findings and conclusions.” (citation
omitted)).

¶13 In any event, Rule 80(b)(6) does not require a court to consider
“irreparable harm” in determining whether to seal a file. Instead, the rule

not consistent with his petition, which made no request that the sealing be
“temporary” or that only “portions” of the file be sealed. On the contrary,
the petition flatly asked the court to order the State Bar to “remove File No.
24-1582” — i.e., the entire file — from public view and “expunge” it.

4

GOFF v. STATE BAR, et al.
Decision of the Court

provides that a court may order that a file be sealed upon a showing of
“good cause.” Although the Supreme Court Rules do not define the term
“good cause,” the determination of good cause is a fact-intensive, case-
specific inquiry. Cf. Gila River Indian Cmty. v. Dep't of Child Safety, 238 Ariz.
531, 536, ¶ 20 (App. 2015) (noting that while the Indian Child Welfare Act
does not define “good cause,” “good cause is ultimately a matter of
discretion, which is to be exercised in light of myriad factors specific to a
given case.”) (citation modified). Goff thus bears the burden of establishing
specific facts and circumstances to warrant sealing the file from public view.
Ariz. R. S. Ct. 80(b)(6) (providing that a sealing order may be entered “for
good cause shown”); see also Center for Auto Safety v. Goodyear Tire & Rubber
Co., 247 Ariz. 567, 572, ¶ 20 (App. 2019) (“A party asserting good cause [for
entry of a protective order] bears the burden, for each document it seeks to
protect, of showing that specific prejudice or harm will result if no
protective order is granted.” (citations omitted)).

¶14 Goff has wholly failed to make the required showing. In his
opening brief, he asserts that the court’s “denial of injunctive or protective
relief” has allowed the “[c]ontinued dissemination of unproven
allegations,” causing “[o]ngoing reputational and professional damage,”
“[o]ngoing exclusion and prejudice,” and “[i]nterference with professional
opportunities.” His opening brief, however, is devoid of references to the
record and identifies no factual support for his arguments. He does not
identify, for example, any evidence of “reputational” harm, nor does he
explain how he purportedly suffered “exclusion and prejudice.” Likewise,
Goff does not identify any “professional opportunities” that have been
denied him. Goff’s conclusory assertions fail to establish any prejudice from
the denial of his petition to seal the UPL file. Center for Auto Safety, 247 Ariz.
at 572, ¶ 20 (“Broad allegations of harm will not suffice.” (citations
omitted)). And although Goff complains that the court “fail[ed] to consider
relevant factors,” he does not identify any specific factors that the court
purportedly failed to consider. In the absence of a transcript, we have no
basis for second-guessing the court’s determination. McGlothlin, 255 Ariz.
at 460, ¶ 35; see Kohler v. Kohler, 211 Ariz. 106, 108, ¶ 8 n.1 (App. 2005) (“In
the absence of a transcript, an appellate court will presume that the record
supports the trial court’s rulings.”).

¶15 In his briefing, Goff cites Paul v. Davis, 424 U.S. 693 (1976) for
the proposition that “reputational harm becomes actionable when coupled
with a tangible deprivation.” In Paul, Davis, an accused-but-not-convicted
criminal defendant brought claims against police officers who publicly
identified him as an “active shoplifter,” asserting that they violated his
rights under the Fourteenth Amendment to the United States Constitution

5

GOFF v. STATE BAR, et al.
Decision of the Court

and 42 U.S. 1983. In rejecting his argument, the United States Supreme
Court held that although Davis stated a viable claim for defamation under
state law, he had identified “no specific constitutional guarantee” that the
police officers purportedly “invaded.” Id. at 699, 700. Injury to reputation
alone, the Paul court held, does not constitute an unconstitutional
deprivation of liberty or property. Id. at 709, 712. In so holding, the Court
distinguished case law recognizing constitutional claims in circumstances
in which, for example, a government entity’s designation of certain
organizations as “Communist” cost members of those organizations their
jobs and harmed their employment prospects. See id. at 703-04. Paul thus
stands for the proposition that a state actor’s stigmatizing designation of an
individual may support a claim for deprivation of constitutional rights if
the designation is coupled with a deprivation of federally-protected liberty
or property interests. See Chaudhry v. Aragon, 68 F.4th 1161, 1170 (9th Cir.
2023) (citing Paul for the proposition that “[a]lthough . . . damage to
reputation—without more—is insufficient to implicate the Fourteenth
Amendment’s Due Process Clause, a ‘stigma-plus’ due process claim may
lie where reputation harm is accompanied by some additional deprivation
of liberty or property.” (citations omitted)).

¶16 Because Goff has never asserted a claim for deprivation of his
constitutional rights, and because he cites to no evidence in the record
suggesting that he suffered any “reputational harm,” much less an
accompanying “deprivation” of liberty or property, Paul does not aid Goff
in this appeal.

¶17 Goff also cites Sperry v. Florida, 373 U.S. 379 (1963), for the
proposition that “state action cannot interfere with federally authorized
conduct.” In Sperry, a Florida state court enjoined Sperry, a practitioner
registered to practice before the United States Patent Office, from “holding
himself out” as “an attorney” or “engaging in the practice of law.” Id. at 382.
Vacating the state court’s order, the United States Supreme Court held
federal law governing the practice of law before the Patent Office
preempted conflicting state licensing requirements. Id. at 384-85.

¶18 Because Goff cites no evidence that he is authorized to
practice law before any federal agency, nor any evidence that the State Bar’s
retention of the UPL investigation file otherwise interferes with any
federally authorized activity, Sperry provides no support to Goff’s position.

¶19 In his briefing, Goff suggests that the court’s denial of his
petition infringed on rights protected by the Individuals with Disabilities
Education Act (“IDEA”), 20 U.S.C. §§ 1400-1482. According to Goff, “state-

6

GOFF v. STATE BAR, et al.
Decision of the Court

law restrictions cannot be applied in a manner that nullifies” the rights of
“parents participating in IDEA proceedings.” Goff does not explain the
IDEA’s relevance to this case, or the basis for his contention that the court’s
ruling somehow “nullified” the rights of “parents.” Further, nothing in the
record suggests that Goff presented this argument in the superior court. We
therefore do not address it. State v. Bolton, 182 Ariz. 290, 298 (1995)
(declining to consider “issues raised for the first time on appeal” and
arguments “insufficient[ly]” developed “for appellate review.”).

¶20 In his reply brief, Goff argues, for the first time, that the court
erred in denying his petition without “conduct[ing] the balancing required
by [Arizona Rule of Civil Procedure] 65.” Because Goff did not raise this
argument in his opening brief, we will not address it. See Dawson v.
Withycombe, 216 Ariz. 84, 111, ¶ 91 (App. 2007) (“We will not consider
arguments made for the first time in a reply brief.”).

¶21 Because Goff has failed to establish any error in the court’s
denial of his petition, he is entitled to no relief.

CONCLUSION

¶22 We affirm. The State Bar may recover its costs upon its
compliance with ARCAP 21.

MATTHEW J. MARTIN • Clerk of the Court
FILED: JR

7