No Reason Not To Disbar

Disbarment is warranted, absent compelling circumstances, for repeated intentional misappropriation, false representations to clients and the fabrication of pleadings to conceal the misconduct, according to a decision of the Maryland Court of Appeals. There were no such compelling circumstances here.

One interesting aspect of the decision notes that the attorney had self-reported the misconduct. A concurring opinion allows for the possibility of a lesser sanction for a “true” self-report of misconduct. Here, the report was made after the misconduct had been discovered. (Mike Frisch)