On April 4 the Hearing Department of the State Bar Court issued a recommendation that Del Norte district attorney Jon Alexander be disbarred. If the California Supreme Court chooses to follow the recommendation, this unseating of a county prosecutor would be unprecedented.

But the true uniqueness of the decision is that Alexander would be unseated because of prosecutorial misconduct. The record shows that he denied the Sixth Amendment protection under Massiah v. U.S. to one defendant and due process under Brady v. Maryland to the co-defendant.