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Attorney Grievance Commission v. Gray

Citations: 444 Md. 227; 118 A.3d 995; 2015 Md. LEXIS 495Docket: Misc. Docket AG Nos. 56, 18, 26

Court: Court of Appeals of Maryland; July 27, 2015; Maryland; State Supreme Court

Narrative Opinion Summary

The case involves the disciplinary proceedings against an attorney with a significant history of misconduct, marking her fourth sanction consideration. The attorney, already indefinitely suspended, faced additional charges for violating multiple Maryland Lawyers' Rules of Professional Conduct (MLRPC), including incompetence (1.1), lack of diligence (1.3), poor communication (1.4), and misconduct (8.4). Specific cases involved mishandling of client funds, failure to communicate, unreasonable fees, and abandonment of client representation. The attorney failed to respond to Bar Counsel inquiries, further breaching MLRPC 8.1(b). The court found violations in the representation of four clients, where she provided inadequate legal services, delayed the deposit of client funds, and failed to maintain trust account records. Despite prior sanctions including a reprimand and suspensions, the attorney's continued misconduct led to the recommendation of disbarment. The decision emphasized the need for public protection and confidence in the legal system, concluding that disbarment was the appropriate sanction for the attorney's cumulative violations and lack of cooperation during investigations.

Legal Issues Addressed

Abandonment of Client Representation

Application: The attorney abandoned clients without returning unearned fees, violating MLRPC 1.16(d).

Reasoning: Respondent did not return any portion of the $6,000 fee and did not deposit it in an Attorney Trust Account (ATA).

Attorney Misconduct and Disciplinary History

Application: The court considered the fourth sanction against the attorney due to a significant disciplinary history, including a current indefinite suspension.

Reasoning: Bar Counsel has requested the Court to review the attorney misconduct of Melissa D. Gray, who has a significant disciplinary history, marking this as the fourth sanction consideration against her.

Disbarment as a Sanction

Application: The court recommended disbarment due to a pattern of misconduct and prior disciplinary actions.

Reasoning: In this case, disbarment is recommended and agreed upon due to the Respondent’s extensive misconduct, including a pattern of violations and prior disciplinary actions.

Failure to Respond to Bar Counsel

Application: The attorney failed to respond to inquiries from the Office of Bar Counsel, violating MLRPC 8.1(b).

Reasoning: Respondent failed to provide a substantive reply to inquiries from the Office of Bar Counsel.

Misappropriation of Client Funds

Application: The attorney delayed the deposit of client funds and failed to maintain required trust account records, violating MLRPC 1.15.

Reasoning: Respondent delayed depositing it into her escrow account for several months.

Unreasonable Fees

Application: The attorney charged fees without rendering services, violating MLRPC 1.5.

Reasoning: The fee charged was deemed unreasonable due to the lack of services provided, violating Rule 1.5.

Violation of Maryland Lawyers’ Rules of Professional Conduct (MLRPC)

Application: The attorney was found to have violated several MLRPC rules, including competence, diligence, communication, and misconduct.

Reasoning: Gray has been charged with multiple MLRPC violations, including competence, diligence, communication, and misconduct, as well as violations of Maryland Rules related to attorney trust accounts and misuse of trust money.