She was not disbarred. "Voluntarily inactive" simply means she has
let her license expire, and thus, "not authorized to practice law".
Why? There are many reasons attorneys allow their license to
expire. Retired. Moved to another state (as she did) and did not
wish to renew license in the past state. Personal hiatus, such as
concentrating on raising a family (as she has). Career change.
Death. At the time she voluntarily changed her status to inactive a
lawyer needed a court order approving the change.
Here is the pertinent excerpt from the Attorney Registration &
Disciplinary Commission ARDC of the Illinois Supreme Court:
"E. Supreme Court - Non-Disciplinary Action"
In addition to activity in disciplinary cases, the Supreme Court
entertains pleadings in non-disciplinary matters that affect an
attorney's status. Chart 17 reflects the orders entered in such
cases during 2000. With the amendments to Rules 756 and 770, adding
an inactive status registration category and deleting Rule 770
court-ordered inactive status, effective beginning with the 2000
registration year, transfers to inactive status are now
accomplished without Court order, and, therefore, are no longer
reflected in Chart 17. As was true in 1999 when the rule amendments
were announced, many lawyers who had transferred to inactive status
under Rule 770 petitioned to return to active status under Rule
759, with the result that the number of petitions filed under Rule
759 was significantly higher for 1999 and 2000 than in past years.
The transition stage will end during 2001, and there should be a
significant drop-off in Rule 759 filings in future years. "
1) According to the ARDC, ALL lawyers who requested inactive status
prior to 2000 had to obtain a court order in order to receive it.
2) There are NO disciplinary actions against Michelle Obama.
3) Her license is listed as "VOLUNTARILY [emphasis is mine]
In other words, before 2000, any lawyer who wanted to go on
VOLUNTARY inactive status had to get a court order to do so.
Therefore, ALL lawyers who voluntarily became inactive - did so via
COURT ORDER. There were NO disciplinary actions against Mrs. Obama.
She is eligible to return to active status at any time by paying
her fees and completing the continuing education required of all
So, the ARDC's site indicates that her VOLUNTARILY inactive status
came at HER request and was granted by a court order, as was
ROUTINE before 2000.
NOTHING on their site says or implies that there was a disciplinary
aspect to it.