South Dakota Code § 16-19-91

Burden of proof in medical inactive status and reinstatement proceedings
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In a proceeding seeking a transfer of an attorney to medical inactive status under §
16-19-92
, the burden of proof shall rest with the board. In a proceeding seeking an order of reinstatement to active status under §
16-19-98
, the burden of proof shall rest with the attorney. In either case, the burden of proof shall be by clear and convincing evidence.

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