UK Attorney Disbarred

Disbarment imposed by the New York Appellate Division for the First Judicial Department

Respondent Michael J. Little was admitted to the practice of law in the State of New York by the First Judicial Department on September 8, 2005, under the name Michael John Little. Respondent maintains a registered address in the United Kingdom, where he has been a licensed solicitor and barrister. As the admitting Judicial Department, this Court retains continuing jurisdiction over respondent (22 NYCRR § 1240.7[a][2]).

By order dated February 15, 2024, this Court deemed respondent’s April 10, 2018 federal convictions for, inter alia, obstructing and impeding the due administration of the internal revenue laws (26 USC § 7212[a]), conspiracy to defraud the IRS (18 USC § 371), aiding and assisting the preparations of false IRS forms (26 § USC 7206[2]), all felonies, and willful failure to file individual income tax returns (26 USC § 7203), a misdemeanor, “serious crimes” as defined by Judiciary Law § 90(4)(d). Respondent was immediately suspended from the practice of law until further order of the Court (Judiciary Law § 90[4][f], 22 NYCRR § 1240.12[b][2]).

This Court appointed a referee to conduct a sanction hearing and issue a report and recommendation as to final discipline (Judiciary Law § 90[4][g], 22 NYCRR § 1240.12[c][2][i] and [iv]) (225 AD3d 19 [1st Dept 2024]). By report dated March 21, 2025, the Referee recommended that respondent be disbarred, effective nunc pro tunc to the date of his interim suspension.

The Attorney Grievance Commission sought disbarment

Respondent opposes the motion and requests that a final decision be stayed pending resolution of his coram nobis appeal. In the alternative, respondent requests that “the Court consider disbarment from the date of conviction, April 10, 2018, rather than nunc pro tunc” to the date of his interim suspension.

First, there is no compelling reason to grant respondent’s request for a stay while his third appeal to the Second Circuit is pending. Respondent’s conviction was affirmed by the Second Circuit in 2020. Should he obtain coram nobis relief, he can move to have any discipline imposed by this Court based on his conviction vacated under Judiciary Law § 90(5).

Second, disbarment is the appropriate sanction in this case given the level of criminal conduct, dishonesty, and the lack of any significant mitigation found by the Referee…

Third, respondent failed to notify the AGC of his conviction within 30 days thereafter, which “failure … shall be deemed professional misconduct…” (Judiciary Law §90[4][c]), which has also been cited as an aggravating factor with respect to sanction determination (Matter of Bradshaw, 169 AD3d 200, 202 [1st Dept 2019] [failure to promptly report tax conviction cited as aggravating factor]).

The sanction was backdated to the interim suspension. (Mike Frisch)