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In Re: Salvador R. Perricone

Citation: 263 So. 3d 309Docket: 2018-B-1233

Court: Supreme Court of Louisiana; December 4, 2018; Louisiana; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The Supreme Court of Louisiana disbarred an attorney following a disciplinary proceeding initiated by the Office of Disciplinary Counsel (ODC). The attorney, while serving as a Senior Litigation Counsel with the United States Attorney's Office, made anonymous online comments under pseudonyms that were prejudicial to ongoing investigations and trials, including the high-profile Danziger Bridge case. These actions violated several rules of professional conduct, including making extrajudicial statements and conduct detrimental to justice. Despite acknowledging these violations, the attorney claimed that his actions were influenced by complex PTSD. However, the court found no concrete evidence linking the mental condition to the misconduct, rejecting it as a mitigating factor. The court emphasized the higher ethical standards expected of prosecutors and determined that the attorney's actions severely undermined public trust in the legal system, warranting disbarment. The court ordered the attorney to bear all proceeding costs, with legal interest accruing post-judgment. The decision underscores the importance of maintaining integrity within the legal profession, particularly for those in public office, and reinforces that ethical obligations are paramount, irrespective of anonymity in social media.

Legal Issues Addressed

Costs and Interest in Disciplinary Proceedings

Application: All costs associated with the proceedings are to be borne by the respondent, with interest accruing post-judgment.

Reasoning: All costs associated with the proceedings are to be borne by Perricone, with legal interest accruing from thirty days post-judgment.

Disbarment for Professional Misconduct

Application: The Supreme Court of Louisiana disbarred the respondent for engaging in misconduct that included making inappropriate extrajudicial statements under pseudonyms, which prejudiced ongoing investigations and trials.

Reasoning: Salvador R. Perricone, an attorney licensed in Louisiana, has been disbarred by the Supreme Court of Louisiana following a disciplinary proceeding initiated by the Office of Disciplinary Counsel (ODC).

Higher Standards for Prosecutors

Application: Prosecutors, as public officials, are held to higher ethical standards, and respondent's actions undermined trust in the legal system, warranting disbarment.

Reasoning: In determining an appropriate sanction, the court highlights that public officials, especially prosecutors, are held to a higher standard.

Mental Disability as a Mitigating Factor

Application: The court did not accept PTSD as a mitigating factor due to lack of clear evidence linking the condition to the misconduct.

Reasoning: The court finds no clear evidence linking the mental condition to the misconduct, noting that the respondent's psychologist testified that individuals with PTSD can function competently.

Sanctions Based on Misconduct Severity

Application: The disbarment decision was influenced by the extent of the misconduct, its impact on prosecutions, and the damage to the USAO's reputation.

Reasoning: The respondent’s actions undermined public trust and harmed ongoing prosecutions, damaging the reputation of the USAO and the legal profession.

Violation of Rules of Professional Conduct

Application: Respondent violated multiple rules, including making prejudicial extrajudicial statements and engaging in conduct detrimental to the administration of justice.

Reasoning: The Office of Disciplinary Counsel (ODC) filed formal charges against Perricone for his conduct, alleging violations of multiple rules of professional conduct.