concurring.
I write separately because I disagree with both the majority’s characterization of respondent’s conduct and its conclusion that he was not obligated to obey the specific commands of the Code of Professional Responsibility (the Code).
RESPONDENT’S LEGAL OBLIGATIONS
Contrary to the conclusions of the Local Administrative Committee and the Disciplinary Commission, the majority holds that respondent was not answerable to the Code provisions requiring him to: (1) maintain records of his client’s funds and properties; (2) render appropriate accounts to his client regarding such funds and properties; and (3) promptly pay or deliver to his client on request all such funds and properties in the lawyer’s possession. See DR 9-102(B)(3) and (4). These provisions did not bind respondent because there was no putative client. At 452, 759 P.2d at 598. The court holds that these rules apply only to an attorney’s “special obligation” to a traditional client. At 452, 759 P.2d at 598.
Respondent was employed and paid as a deputy county attorney during the entire time he served as director of the Arizona Drug Control District Strike Force. I cannot agree with the idea that respondent was a lawyer for purposes of receiving his salary but not a lawyer when it came to fulfilling ethical requirements. The majority badly misinterprets the two cases on which it relies in reaching its conclusion, In re Neville, 147 Ariz. 106, 708 P.2d 1297 (1985), and In re Lurie, 113 Ariz. 95, 546 P.2d 1126 (1976).
Lurie actually held that, although acting as a businessman rather than a legal adviser, the lawyer was bound to obey the specific disciplinary rule before us today. 113 Ariz. at 98, 546 P.2d at 1129. In Neville, dealing with a different section, we held that the specific rules applied “also to transactions in which, although the lawyer is not formally in an attorney-client relationship with the adverse party, it may fairly be said that ... an ordinary person would look to the lawyer as a protector rather than as an adversary.” 147 Ariz. at 111, 708 P.2d at 1302. Surely this principle applies most strongly to a lawyer holding public office to do the public’s work. Certainly the public expects that a lawyer in public office will obey all the ethical requirements of the Code, in addition to the high standards inherent in public service. Id. at 112, 708 P.2d at 1303. Neville does not insulate respondent from the Code’s specific obligations simply because he held public office.
These views are not an Arizona legal aberration. In other jurisdictions, lawyers involved in non-attorney-client relationships have been held accountable under specific sections of the disciplinary code.1 See, e.g., Libarian v. State Bar, 21 Cal.2d 862, 136 P.2d 321 (1943) (specific rules regarding advertising applicable although advertisements were for nonlawyer services); In re Genser, 15 N.J. 600, 105 A.2d 829 (1954) (even though no attorney-client relationship, an attorney in a personal business transaction must comply with the ethical rules regarding an attorney’s handling of funds entrusted to him).
As a leading commentator has noted, an attorney is “bound to observe the [ethical rules] as fully when he becomes president of the company as when he was its general counsel.” H. DRINKER, LEGAL ETHICS 92 (1953). Not two years ago, this court espoused identical views. We said that a lawyer “does not cease to be bound by the ethical code merely because he is an officer ... of a company.” In re Kersting, 151 Ariz. 171, 177, 726 P.2d 587, 593 (1986). Even when running for public office, an attorney is “bound by the ethical rules” requiring truthful statements. Id., citing State v. Russell, 227 Kan. 897, 610 P.2d 1122 (1980).
*455FACTUAL CHARACTERIZATION
In disciplinary proceedings against a member of the state bar, this court gives great weight to local committees’ findings and conclusions. Kersting. Nonetheless, we have a duty to independently evaluate both fact and law. Id. at 172, 726 P.2d at 587; Neville, 147 Ariz. at 108, 708 P.2d at 1299. The majority finds in respondent’s conduct no more than “slip-shod and sloppy accounting practices.” At 453, 759 P.2d at 599. The record shows more.
Respondent was obligated to reimburse the county for all funds advanced to him and not expended in connection with his official duties. Expenditures, of course, were to be substantiated by appropriate receipts. Respondent failed to account and failed to return the funds for which he could not account. Because it was impossible to obtain respondent’s cooperation, the appropriate county officials turned to respondent’s supervisor, the Pima County Attorney.
Apparently quite properly perturbed at respondent’s conduct, the county attorney told respondent’s office staff “to collect and submit the necessary items.” At 450, 759 P.2d at 596. Of course, he was aware that respondent had provided no vouchers to “collect and submit.” He expected the staff to “reconstruct” the accounting by obtaining “dummy” vouchers, a practice which he believed had been followed “in the [Drug] Strike Force and throughout Pima County long before.” RT at 380. A “dummy” voucher is one “not made at or near the time that the expense was incurred.” Id. The county attorney expected the staff to provide substitute vouchers for expenses which had actually been incurred. See RT at 382. Evidently unknown to the county attorney, the administrative staff went beyond “dummy” vouchers and instead manufactured “phony” vouchers. While the former represent actual expenditures, the latter are false; they represent expenses not incurred at the place shown “or [which] had not been [incurred] at all.” RT at 382.
The majority adopts the Committee’s conclusion that there was “no dishonesty on the part of Mr. Grimble.” At 452, 759 P.2d at 598. Yet, it admits that respondent knew that “blank receipts” were to be filled in and used in his accountings. The record also reveals that respondent verified the forms to which the false receipts were attached. See RT at 91, citing deposition of Donna Larsen, Strike Force Finance Administrator, at 40. At the very least, therefore, respondent verified vouchers, without any belief that the vouchers represented actual expenses. Even giving respondent the benefit of every doubt, at the least he condoned improper conduct. The unpleasant truth of the matter is that someone in this public agency knowingly submitted false documents to the county finance department, yet no one in the agency has been held responsible.
Even these transgressions are overshadowed by the use of state money for the purchase of personal items. Again, taking a rather rosy view of dismal facts, the majority adopts the Committee’s finding that respondent “inappropriately took advantage of his official position to purchase property for his personal use with his client’s funds, and although it was done without fraudulent or dishonest intent, it did result in inappropriate use of client funds as a source of personal credit for some period of time.” At 451-452, 759 P.2d at 597-598. These kind words disguise serious misconduct. Respondent admits he purchased a desk for his personal use with state funds and by a state contract, thereby taking advantage of a state discount which would not have been available to him personally. This would have been improper behavior even if respondent had made immediate reimbursement to the state, but it is much worse because respondent not only acted without his supervisor’s authority in doing this, but did not repay the state for this furniture for a period of many months, and then only after several demands had been made upon him.
The majority describes this as “risky business at best” that can “lead to trouble.” At 453, 759 P.2d at 599. In my view, undisclosed use of public money to buy one’s personal furniture is a little more than “risky business,” especially when transacted by a law enforcement officer. If respondent’s conduct on this point was *456not theft, see A.R.S. § 13-1802(A)(2), it certainly comes close.
The record leaves many other points and questions flatly unresolved. I cannot agree with the majority’s final conclusion that respondent’s problems are attributable to his “serious ... approach to his substantive responsibilities [that resulted in a lack of] time and energy to devote to some of his administrative obligations.” At 453, 759 P.2d at 599. Whatever those important responsibilities may have been, they simply do not excuse respondent’s failure to account for public funds entrusted to him, his participation in submitting phony account-ings or his use of state money to buy personal items. I therefore cannot accept the Commission’s recommendation for censure and would remand to the hearing committee for further hearings to determine what respondent knew about the use of false vouchers and to answer other questions unresolved by this record. After such findings, this court could then accurately decide whether suspension or disbarment was the correct sanction. Believing, however, that some punishment is better than none, I reluctantly concur in the result.
. See generally Annotation, Disciplinary Action Against Attorney or Accountant for Misconduct Related to Preparation of Tax Returns for Others, 81 A.L.R.3d 1140 (1977); Annotation, Disciplinary Action Against Attorney for Misconduct Related to Performance of Official Duties as Prosecuting Attorney, 10 A.L.R.4th 605 (1981); Annotation, Misconduct in Capacity as Judge as Basis for Disciplinary Action Against Attorney, 57 A.L.R.3d 1150 (1974).