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In Re Vohra

Citations: 762 A.2d 544; 2000 D.C. App. LEXIS 298; 2000 WL 1755090Docket: 00-BG-395

Court: District of Columbia Court of Appeals; November 22, 2000; District Of Columbia; State Supreme Court

Narrative Opinion Summary

The case involves disciplinary proceedings against a member of the District of Columbia Bar, Robert N. Vohra, who was found to have breached the District of Columbia Rules of Professional Conduct. The violations included failing to complete client tasks, misrepresenting the completion of work, and permitting claims for unearned fees. During the period of misconduct, Vohra suffered from major depression, but he has since shown improvement and maintains a successful legal practice. The Board on Professional Responsibility recommended a sanction of a thirty-day suspension, stayed for two years, subject to conditions including the acceptance of a practice monitor, ongoing mental health treatment, and submission of quarterly progress reports. The District of Columbia Court of Appeals upheld the Board's findings, citing substantial evidence and aligning the sanction with precedents in similar cases. Consequently, Vohra's suspension was ordered, stayed with a probationary period of two years, mandating supervision and treatment conditions.

Legal Issues Addressed

Consideration of Mental Health in Disciplinary Proceedings

Application: The attorney's major depression was acknowledged, affecting his conduct, yet improvements in his condition were considered in the disciplinary decision.

Reasoning: Although Vohra was suffering from major depression during these incidents, he has since improved and maintains a successful practice.

Judicial Acceptance of Board Recommendations

Application: The court accepted the Board's findings and imposed the recommended sanction, consistent with similar disciplinary cases.

Reasoning: The District of Columbia Court of Appeals accepted the Board's findings, noting substantial evidence supported them. The court imposed the recommended sanction, emphasizing its consistency with disciplinary actions for similar conduct.

Sanctions and Probationary Measures in Attorney Discipline

Application: A thirty-day suspension was stayed for two years, contingent upon compliance with monitoring and treatment conditions.

Reasoning: The Board on Professional Responsibility recommended a thirty-day suspension, to be stayed for two years contingent upon Vohra accepting a practice monitor, continuing mental health treatment, and submitting quarterly progress reports from both the monitor and therapist.

Violation of Professional Conduct by Attorneys

Application: The attorney was found to have violated professional conduct rules by failing to complete tasks, misrepresenting work, and allowing claims for unearned fees.

Reasoning: Robert N. Vohra, a member of the District of Columbia Bar, was found to have violated the District of Columbia Rules of Professional Conduct by failing to complete tasks for a client, misrepresenting that work had been done, and allowing reimbursement claims for unearned fees.