Question juridique clé
Whether the appellant was denied the right to be heard regarding the alleged refusal to return the client's file.
Solution extraite
The cantonal appeal court relied on a matter on which the appellant had not been heard, so the decision was procedurally defective on that point.
Motifs extraits
The disciplinary appeal court could examine the issue ex officio, but before relying on contested facts not sanctioned by the first instance it had to allow the lawyer to comment and adduce evidence.