ABA Delegate Report: 2025 ABA Annual Meeting in Toronto by R. Jonathan Shirts

man at podium at ABA conference with Idaho in the front image
Michelle A. Behnke, President of the ABA, welcomes the delegates to the conference in Toronto.

This year’s ABA Annual Meeting was held in the beautiful city of Toronto, Ontario.[i] The meetings were held in the historic Fairmont Royal York, directly across the street from the historic Union Station.[ii] The Royal York (as it’s known to locals) is just shy of 100 years old and is an absolutely stunning architectural wonder. The little boy inside of me was astounded to be staying at the same hotel Queen Elizabeth II, President Ronald Reagan, and Andrew Lloyd Webber (among countless other celebrities and world leaders) had stayed in. I spent way too much time staring at the oil painted ceiling of the Ballroom during the celebration for the incoming ABA President, admiring the intricate gilded carvings in the elevators (and almost missing the floor for my room more than once), and being blown away at the floral arrangements in the lobby that were replaced every day. But when I wasn’t distracted by those things, I was doing my best to represent Idaho and ensure our voice was heard.

This particular Annual Meeting was far and away the busiest of the meetings I’ve been fortunate to attend. There were more than 60 resolutions, including 15 revisions or amendments,[iii] and more than 400 requests to speak in favor or against various Resolutions were submitted.[iv] By mid-afternoon on Monday, everyone’s favorite person was a Delegate from Michigan who, it turns out, was asked to step in and request the debate on a Resolution be stopped. At one point during a particularly passionate (read: lengthy) debate on a Resolution, Idaho’s Young Lawyer Delegate, Kendall, leaned over and asked when he was going to get up. Almost on cue, “the Angel of Death” (as he called himself) stood up. We both got a really good chuckle out of that.[v]

The Meeting was also a bit of an interesting one for anyone who is a constitutional or bylaw nerd.[vi] Article 16 of the ABA Constitution requires a review of the membership of the Association every ten years.[vii] The entire text of this section reads,

Beginning in 2005 and once every ten years thereafter a review shall be conducted of the House of Delegates, the Board of Governors and the Nominating Committee. With respect to each body the review shall include an examination of its size and a consideration of its composition to ensure appropriate representation of constituencies.[viii]

Two Meetings ago, the ABA leadership formed a working group to undertake that review and make recommendations. While there’s not much direction to go on from that section, the Decennial Commission took its work seriously, hosting several town halls over the past three Meetings, gathering input and soliciting ideas, then reporting back to the House of Delegates and Board of Governors how they thought the House of Delegates and Board of Governors needed to be adjusted in terms of representation.[ix] After a significant amount of debate, the House voted to keep the composition of both the House of Delegates and the Board of Governors as they are currently.[x] Many people thought it would be best for the Board of Governors and House of Delegates to be downsized in order to be more efficient; but as someone said during the debate, “We [the ABA] decided long ago that inclusion was more important than efficiency.” Clearly.

Fairmont Royal York hotel in Toronto
The Fairmont Royal York hotel in Toronto, this year’s location of the ABA Annual Meeting.

I feel compelled to take a brief interlude to discuss the word, “inclusion.” Over the last decade or so, this word has taken on a very politicized meaning, to the point there have been Executive Orders from the last two Administrations using that term, each purporting to be an attempt to accomplish the same thing.[xi] Merriam-Webster defines inclusion as, “the act of including: the state of being included;”[xii] while Black’s Law Dictionary, which I’m sure everyone reading this is more than familiar with, defines “include” as, “To contain as a part of something.”[xiii] Even though the word has been politicized, I want to say that I have felt included as a member of the Idaho State Bar from the day I started law school, and that our Bar feels (for the most part) inclusive for new attorneys. Sure, the very nature of our profession requires us to be adversarial at times, but I have never felt—as a whole—attorneys in our State could not sit down for a drink together, regardless of which side of the “vs.” they may have been on.[xiv]

One aspect of inclusion that the House of Delegates voted on this Meeting was a change to the Constitution that gave the United States Virgin Islands and the Pacific Territories representation on the Board of Governors as “States.”[xv] While speaking in favor of the Resolution, the Delegate from Guam, a person I have gotten to know well the last few Meetings, said this is something that has been in the works for over 40 years. Passage of this Resolution meant a lot to me as a Delegate from one of the smaller States because there are times when I feel the voices of the three to four of us representing our State could be drowned out by the Delegations from California, Illinois, or Texas—all States with more than 20 Delegates. But enough of that, let’s move on.

Some of the more important Resolutions taken up by the House of Delegates this Meeting included Resolutions on upholding the Rule of Law in our society,[xvi] freedom of speech in academia,[xvii] and freedom of the press against spurious defamation claims.[xviii] I think these should be the most important Resolutions passed by the House of Delegates this meeting, but I am afraid they will likely go down as mere footnotes in history unless we, as a profession, decide we will not allow our profession to be attacked, and stand up for our judges who are doing their best to judge cases fairly, and our press who impartially report on the issues we face in society.

But I want to end by discussing two Resolutions which both involved bullying: in the legal profession against each other,[xix] and against the judiciary and the legal profession in general.[xx] This topic, to me, hits close to home, not only because of my job in the judiciary and as an attorney, but on a very personal level. This is not something I have spoken about much, outside of my family and a very small group of people, because it is such a painful subject. I grew up in a tiny little town where my high school graduating class was less than 90 people (imagine my shock moving to Coeur d’Alene for my Senior year where the graduating class was bigger than the entire high school I had just left). In fifth grade, I made two “mistakes” that nearly destroyed me: I beat one of the more popular eighth graders in the finals of the school’s Geography Bee, and, after dropping a pass on the playground one fall morning, said I was “really junky at this game.” Kids being kids, I was saddled with the nickname “Junky” for the rest of time I lived there. I was relentlessly harassed because I was incredibly book smart, but not all-that athletically gifted (even though I tried, so very hard). When I tried to stand up for myself, I wouldn’t do it the right way and found myself in fights on a frequent basis (one day in sixth grade, I was in a fight before school started, another at lunch, and one during the afternoon recess). I was the geeky kid who was caught during class in fifth grade reading, A Brief History of Time by Stephen Hawking instead of doing my math work, who constantly got in trouble for not doing any homework then passing the tests (this drove my seventh grade math teacher, in particular, up the wall), and who ran his mouth off about becoming the starting quarterback my sophomore year even though I had never played a single down of organized football. I went home a great many days depressed, hurt, and thinking it just would be better for everyone else if I simply wasn’t there. I wanted so badly to fit in, to just be part of a group, but never felt that I was. Even now, I find myself chasing and craving things that seem so easy for everyone else, but always just out of reach for me.

CN tower in downtown toronto
The CN Tower in Toronto.

Looking back now, I recognize I did not do much to help myself with any of those problems; I was quick to anger, easy to take offense at everything, and saddled with mental health conditions that I somehow always suspected but was not diagnosed with until I was in my 30’s. I don’t say this to throw a pity party for myself—I say it to reflect on the impact being bullied has had on my entire life and continues to have today. I would simply caution all of us as attorneys to be mindful of the way we treat those around us, including other attorneys and staff, and recognize that our actions today could have either a detrimental or uplifting impact on someone else. The words we speak, or the actions we don’t take, can have ripple effects beyond what we might be able to conceive right now. We should think about how putting wanted posters featuring judges in the halls of Congress impacts not only those judges and their families, but it also impacts their staff and their families, as well.[xxi]

I will close with something the current President of the ABA, Michelle Behnke of Wisconsin, said during her introductory speech, “If you want to go fast, go alone; if you want to go far, go together.”[xxii] I look forward to going far with each of you.

headshot of Shirts, Jonathan

R. Jonathan Shirts graduated from the University of Idaho College of Law in 2018 and is currently the Staff Attorney for the Hon. Randy Grove of the Third District. He has also worked as the Staff Attorney for Hon. Nancy Baskin and Hon. George Southworth. He enjoys good books and spending time outdoors with his wife, daughter, and two sons.


[i] https://www.abajournal.com/web/article/aba-celebrates-long-standing-ties-with-canadian-lawyers-at-annual-meeting

[ii] https://www.fairmont.com/en/hotels/toronto/fairmont-royal-york.html.

[iii] See https://www.abajournal.com/web/article/aba-house-adopts-policy-on-law-firm-intimidation-immigration-issues for a discussion on some of the various Resolutions that were considered, and https://www.americanbar.org/groups/leadership/house_of_delegates/2025hodannualmeeting/ for links to all of the Resolutions, Amendments, and Revisions considered during this Meeting.

[iv] A list of Delegates who submitted electronic requests to speak can be found here: https://www.americanbar.org/content/dam/aba/administrative/house_of_delegates/2025-annual-supplemental-materials/movants-and-speakers-25am.pdf; however, that list is not complete as the House of Delegates has a procedure where a Delegate can submit a request to speak during the meeting itself. The line for doing that was a dozen people deep when the Meeting was called to order on Monday, and it never fully disappeared until the Meeting was adjourned on Tuesday afternoon.

[v] We both missed the presence of our Idaho Delegation leader, Jenn, who was caught up in depositions and unable to join us. Hopefully we’ll be at full-strength in San Antonio in February.

[vi] I am on the fringes of being this type of nerd, but I know there are some lawyers out there who are incredibly passionate about this kind of thing.

[vii] A full copy of the Constitution’s text can be found on the ABA’s website: https://www.americanbar.org/content/dam/aba/administrative/house_of_delegates/constitution-and-bylaws/constitution-and-bylaws.pdf. It will be cited or referred to as “ABA Constitution” or “ABA Const.”

[viii] ABA Const., Art. 16, §16.1.

[ix] See Daily Journal of the ABA House of Delegates, specifically the Proposed Constitutional Amendments 11-4A(1-4), 11-4B(1-6), 11-4C(1-2), and 11-4D(1). https://www.americanbar.org/content/dam/aba/administrative/house_of_delegates/daily-journals/2025-annual-daily-journal.pdf.

[x][x] Id.

[xi] See, e.g., the Biden Administration’s Executive Order 13985, “Advancing Equity and Racial Justice Through the Federal Government” (https://bidenwhitehouse.archives.gov/equity/); and the current Trump Administration’s Order 14151, “Ending Radical And Wasteful Government DEI Programs And Preferencing” (https://www.whitehouse.gov/presidential-actions/2025/01/ending-radical-and-wasteful-government-dei-programs-and-preferencing/).

[xii] https://www.merriam-webster.com/dictionary/inclusion.

[xiii] INCLUDE, Black’s Law Dictionary (12th ed. 2024).

[xiv] I say, “as a whole,” because there will always been some people and personalities who just don’t get along or play nicely together. But even so, I think the collegiality of our Bar would allow them to at least behave civilly towards each other, most of the time.

[xv] See https://www.americanbar.org/news/reporter_resources/annual-meeting-2025/house-of-delegates-resolutions/11-2/, and as revised https://www.americanbar.org/content/dam/aba/administrative/house_of_delegates/2025-annual-supplemental-materials/11-2-rev.pdf.

[xvi] https://www.americanbar.org/news/reporter_resources/annual-meeting-2025/house-of-delegates-resolutions/512/.

[xvii] https://www.americanbar.org/news/reporter_resources/annual-meeting-2025/house-of-delegates-resolutions/513/.

[xviii] https://www.americanbar.org/news/reporter_resources/annual-meeting-2025/house-of-delegates-resolutions/514/.

[xix] https://www.abajournal.com/web/article/aba-house-takes-aim-at-bullying-in-the-legal-profession, https://www.americanbar.org/content/dam/aba/directories/policy/annual-2025/523-annual-2025.pdf  

[xx] https://www.americanbar.org/content/dam/aba/directories/policy/annual-2025/509-annual-2025.pdf

[xxi] See https://www.wyomingnews.com/news/local_news/judges-lawyers-describe-perils-of-attacking-judiciary-at-grand-teton-national-park-gathering/article_7c7695e1-0489-41f0-a8ac-aa8379452df5.html (discussing the impact of the Wanted posters and other attacks on the judiciary); https://www.courthousenews.com/citing-escalating-threats-judiciary-urges-congress-to-set-aside-more-cash-for-court-security/ (discussing escalating security concerns); and https://www.americanbar.org/news/reporter_resources/annual-meeting-2023/house-of-delegates-resolutions/200/ (encouraging policymakers at all levels to consider mental health assistance and the impact of trauma on court staff).

[xxii] https://www.abajournal.com/web/article/aba-president-elect-michelle-behnke-recommits-to-defending-the-rule-of-law.