Sanction Appropriate For Pre-Admission Misconduct

The District of Columbia Court of Appeals held that reciprocal discipline may be imposed based on misconduct that led to disciplinary action in California but had taken place prior to the attorney's admission to the D.C. Bar. The attorney had contended that "his serious record of prior discipline, which includes two felony convictions and a period of incarceration" was disclosed when he was admitted. The court noted that the California discipline had been imposed a full year after his admission in D.C. Further, the court endorsed the conclusion that a lawyer who is admitted can have his license revoked "because of conduct of which he was guilty before he passed the examinations and obtained a certificate of practice (quoting a 1930 Florida case)." In addition to a five-year suspension, the attorney must provide "a candid and satisfactory explanation of the contradictions" in his submissions in the D.C. case. (Mike Frisch)