Reinstated With A Censure

Disciplinary issues in Connecticut resulted in a public censure from the New York Appellate Division for the Third Judicial Department

Respondent was admitted to practice by this Court in 1988, following her admission in Connecticut in 1987. We suspended respondent in January 2014 as a consequence of her longstanding biennial registration delinquency (Matter of Attorneys in Violation of Judiciary Law § 468-a, 113 AD3d 1020, 1024 [3d Dept 2014]). Although she cured her registration delinquency in April 2025 and has since moved for reinstatement by this Court, respondent remains so suspended to date. Respondent has also been reprimanded twice by the State of Connecticut Statewide Grievance Committee. To that end, she was first reprimanded in December 2001 following a hearing before a committee which concluded that she had engaged in various forms of misconduct, including making a false statement of material fact to a tribunal (see Conn Rules of Prof Conduct rules 3.1; 3.3 [a] [1]; 8.4 [4]). In September 2021, respondent was again reprimanded, this time upon her consent, following her admissions that she had engaged in misconduct in that jurisdiction that involved charging or collecting an unreasonable fee and failing to communicate in writing the scope of the representation or the rate of the fees and expenses to a client (see Conn Rules of Prof Conduct rule 1.5 [a], [b]). The Attorney Grievance Committee for the Third Judicial Department (hereinafter AGC) accordingly now moves for discipline to be imposed upon respondent as a consequence of her Connecticut reprimands, and respondent has been heard in response.

Notice to New York

In aggravation, AGC cites respondent’s failure to notify either the Court or AGC of her reprimands as required (see Rules for Atty Disciplinary Matters [22 NYCRR] § 1240.13 [d]; see also Rules of App Div, 3d Dept [22 NYCRR] former § 806.16 [d]), among other factors. In mitigation, respondent notes, among other factors, that her failure to notify AGC and this Court of her Connecticut reprimands was not intentional, but was rather a product of her mistaken belief that she had previously resigned as an attorney in New York

Reciprocal sanction

We are not obliged to impose the same sanction by the foreign jurisdiction (see Matter of Mendelsohn, 230 AD3d 943, 945 [3d Dept 2024]), but rather we are tasked with crafting a sanction that is appropriate to protect the public, maintain the honor and integrity of the profession, or deter others from committing similar misconduct (see Rules for Atty Disciplinary Matters [22 NYCRR] § 1240.8 [b] [2]). Here, respondent’s misconduct in Connecticut implicates many of the core obligations of an attorney, including communicating with a client concerning the scope of any representation, the rate of fees and expenses; and refraining from making false statements of material fact to a tribunal. However, mindful of respondent’s cooperation with the Connecticut authorities and AGC in this proceeding, as well as her attempts to cure her longstanding delinquency in this state and seek reinstatement in a motion that is currently before us, we censure respondent as a consequence of her misconduct in Connecticut (see e.g. Matter of Rimer, 238 AD3d at 1383; Matter of Mendelsohn, 230 AD3d at 945-946).

(Mike Frisch)