Narrative Opinion Summary
In this case, an attorney was convicted of conspiracy to defraud the United States, bribery, and conversion, violating 18 U.S.C. § 371. Following this conviction, the attorney was suspended from practicing law, and the Board on Professional Responsibility was tasked with recommending appropriate disciplinary action. The Board concluded that the attorney's offenses involved moral turpitude per se, thereby warranting disbarment under D.C. Code § 11-2503(a). Despite the attorney's efforts to postpone disbarment pending a collateral attack on the conviction, the court maintained that such proceedings do not impede the enforcement of disciplinary measures. Consequently, the attorney was disbarred effective June 1, 1993. The court emphasized that a conviction for a crime involving moral turpitude demands immediate disciplinary action to uphold the integrity of the legal profession, irrespective of any unresolved collateral attacks on the conviction. This decision underscores the primacy of maintaining ethical standards within the legal community by addressing misconduct with prompt disciplinary responses.
Legal Issues Addressed
Disbarment for Crimes Involving Moral Turpitudesubscribe to see similar legal issues
Application: The court held that an attorney convicted of a crime involving moral turpitude can be disbarred immediately, as such crimes demonstrate unfitness to practice law.
Reasoning: The Board found Matzkin’s crime involved moral turpitude per se and recommended disbarment under D.C. Code § 11-2503(a), applicable to attorneys convicted of such crimes.
Effect of Collateral Attacks on Disbarment Proceedingssubscribe to see similar legal issues
Application: The court determined that ongoing collateral attacks on a conviction do not delay or affect disbarment proceedings based on that conviction.
Reasoning: Matzkin's attempt to delay disbarment pending the outcome of a collateral attack on his conviction was denied by the court, which maintained that disbarment proceedings can continue despite ongoing collateral attacks.
Immediate Disciplinary Action Following Convictionsubscribe to see similar legal issues
Application: The court confirmed that a final judgment of conviction justifies immediate disciplinary action, reinforcing the necessity of maintaining professional standards.
Reasoning: Ultimately, Matzkin was disbarred effective June 1, 1993, confirming that his conviction warranted immediate disciplinary measures due to its classification as a crime involving moral turpitude.