This is a tough one. There are a combination of factors going on here IMO. First, lawyers "in the trenches" were less shocked by JM's behavior than appellate judges, who are used to extraordinarily polite and courteous attorney behavior, with none of the messiness and emotion of a jury trial (particularly a criminal trial) (particular a murder trial) (particularly a murder trial with nationwide press attention). Second, the State Bar is very forgiving of almost anything except stealing a client's money (and BTW I haven't gone back to check what the result of the ethics complaint against him regarding the Arias trial was). Third, the appellate judges were presented with all the little statements and behaviors that made me cringe over the course of many many weeks in a condensed format--when it's presented that way, it feels like an unrelenting chain of unprofessional and defiant behavior by JM instead of like intermittent bursts of overzealousness. Fourth, last I heard JM was on paid administrative leave from MCAO. It may be that he faced internal discipline even WHILE getting raises etc.--often in government work these things are handled on two separate "tracks."