Florida Supreme rejects referee's recommended sanction and disbars suspended lawyer found guilty of contempt.  [Added 3/2/10]

    While suspended from the practice of law, Lawyer used her Florida Bar card to get access to a friend who was incarcerated.  Lawyer unsuccessfully attempted to get the friend to sign a lease giving her an interest in an auto.  Lawyer then went to a towing business, again used her Florida Bar card to represent herself as the friend's counsel, and had the auto released to herself.  The friend later had to file a replevin action to get her auto back.

    The Florida Bar filed a petition to hold Lawyer in contempt.  The referee found that Lawyer's actions constituted contemptuous conduct by a suspended attorney.  The referee recommended a 30-day suspension and a 3-year probation upon reinstatement.  The Bar petitioned for Supreme Court review.

    The Court disbarred Lawyer.  Lawyer's actions, her disciplinary history, and case law were cited in support of the Court's decision.  "[Lawyer]'s disregard for the Court’s authority, based upon her belief that she was justified in her actions, casts doubt upon her fitness to practice law within the confines of ethical standards.  Such misconduct also adds to the public’s negative perception of lawyers, thus causing injury to the legal profession.  Moreover, by using her Florida Bar identification card to misrepresent her status as an attorney, both to enter the jail and obtain immediate and private access to a  prisoner and to obtain the prisoner’s vehicle from the impound lot, [Lawyer] acted deceitfully and engaged in misrepresentation.  Consequently, jail officials sustained injury, where their policy prohibiting members of the public from immediate and private access with prisoners, presumably for purposes of security, was eluded.  Finally, the owner of the vehicle had to take legal action to ultimately recover the vehicle from [Lawyer]."  Florida Bar v. Bitterman, __ So.3d ___ (Fla., No. SC07-1071, 2/25/2010).

Florida Supreme Court rejects stipulation for reinstatement of suspended lawyer due to her failure to pay restitution and costs.  [Added 2/19/10]

    Lawyer, who had been suspended from the practice of law, and the Florida Bar stipulated to Lawyer's reinstatement.  Apparently the referee approved the stipulation.  On review, however, in an order the Florida Supreme Court disapproved the referee's report and rejected the stipulation.

    Two justices dissented to the Court's decision.  Lawyer apparently had not paid the restitution ordered at the time of her suspension ($1600 to one client and $800 to another), nor paid the costs of more than $4600.  According to the Bar, Lawyer had not paid "due to financial constraints."  Justice Pariente, in her dissent joined by Justice Perry, stated:  "Neither the Bar nor the referee found any evidence of bad faith.  The Bar, after determining the respondent’s financial inability to pay, reimbursed the clients and thus the respondent now owes The Florida Bar Client Security Fund.  The Bar agreed to a payment plan, approved by the Board of Governors and the referee, and the repayment would be a condition of her probation.  I would thus grant the petition for reinstatement and require compliance with the payment plan to be a condition of probation.  If the Court is going to require either full repayment or at least a certain amount to be repaid, even where there are no financial means, we should set forth those requirements in a clearly enunciated rule rather than on an ad hoc basis without prior notice or explanation."  Florida Bar re: Thompson (Fla., No. SC09-263, 2/18/1020).

Florida Supreme Court rejects referee's recommendation of lesser sanction and suspends lawyer for 1 year for violations relating to candor and conflict of interest.  [Added 1/9/10]

    Lawyer represented Clients in a mortgage foreclosure dispute that led to Clients filing bankruptcy.  Clients owed the lender money, and also ended up owing Lawyer money for legal work.  Clients obtained financing to pay off the mortgage.  At the closing on the refinancing, Lawyer sought a payment of $10,000 for his outstanding fees.  The primary reason for the refinancing was to pay off the mortgage creditor, but the $10,000 payment to Lawyer from the loan proceeds "prevented the achievement of this goal."  Lawyer filed two different HUD statements regarding the transaction.

    Additionally, Lawyer made filings that the bankruptcy court later found "disingenuous," and that court also found that Lawyer's conducted created a conflict with his clients and violated provisions of the Bankruptcy Code.  Lawyer filed a "Suggestion of Bankruptcy" for his law firm, but never petitioned for bankruptcy.

    The Florida Bar charged Lawyer with violations of the Florida Rules of Professional Conduct.  The referee assigned to try the case found Lawyer guilty of violating Rule 4-3.3 (falsely representing to court that law firm filed for bankruptcy protection), Rule 4-1.7 (conflict of interest with Clients by accepting $10,000 payment that kept Clients from paying off creditor), Rule 4-3.1 (filing frivolous pleading by filing false suggestion of bankruptcy), Rule 4-4.1 (false statements to bankruptcy trustee by filing suggestion of bankruptcy), Rule 4-8.4(c) (engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation), and Rule 4-8.4(d) (engaging in conduct in connection with the practice of law that is prejudicial to the administration of justice).  The referee recommended that Lawyer be suspended from practice for 60 days.

    On review requested by the Bar, the Florida Supreme Court rejected the recommended discipline and instead suspended Lawyer for 1 year and thereafter until he proves rehabilitation.

    "[Lawyer] argues that his misconduct was 'minor.'  Contrary to his perspective, the Court does not view violations of rule 4-8.4(c) . . . and rule 4-8.4(d) . . . as minor.  The Court has clearly stated that 'basic, fundamental dishonesty . . . is a serious flaw, which cannot be tolerated' because dishonesty and a lack of candor 'cannot be tolerated by a profession that relies on the truthfulness of its members.'  Fla. Bar v. Rotstein, 835 So. 2d 241, 246 (Fla. 2002).  Dishonest conduct demonstrates the utmost disrespect for the court and is destructive to the legal system as a whole."

    The Court also rejected Lawyer's contention that he lacked intent to engage in misconduct.  "[I]t is well established in disciplinary case law that 'in order to satisfy the element of intent it must only be shown that the conduct was deliberate or knowing.'"  (Citations omitted.)

    The Court also confirmed the finding of a conflict of interest.  "[Lawyer] knew his clients were unable to pay his fee unless they used money from the refinancing loan.  In accepting the $10,000 from the refinancing, he knew his clients would be unable to pay off their primary creditor, Turner.  Paying Turner in full had been the main objective for the refinancing loan.  Thus, [Lawyer]’s action created a conflict of interest that proved detrimental to his clients.  See R. Regulating Fla. Bar 4-1.7(b) (prohibiting a lawyer from representing a client when the lawyer’s exercise of independent professional judgment may be materially limited by the lawyer’s own interests)."  Florida Bar v. Head, __ So.3d ___, 35 Fla.L.Weekly S30 (Fla., No. SC07-2398, 1/7/2010), 2010 WL 26532.

Florida Supreme Court disbars lawyer for two instances of engaging in unlicensed practice of law.  [Added 11/18/09]

    The Florida Supreme Court disbarred Lawyer for two instances of engaging in the unlicensed practice of law.  The two instances were separate and involved significantly different circumstances.  The "Contempt Case" involved Lawyer's practice of law in Florida while he was suspended from the Florida Bar, and the "Disciplinary Case" involved Lawyer practicing law in Illinois where he was not licensed.  The two instances were filed as separate cases but were consolidated for trial before a single referee.

Contempt Case.  Lawyer had been suspended from practice.  He continued to occupy his former law office.  While suspended Lawyer wrote a letter to a California attorney.  The first sentence of the letter "stated:  'I am counsel to counsel to Anglo Bio Tran' and affirmatively stated that he had provided legal opinions about the sufficiency of a complaint filed against Anglo Bio Tran and had discussed the legal course he would advise for his 'client' in the extant or contemplated litigation."  The letter provided legal opinions about the "client's" case.  The referee found that Lawyer had engaged in the practice of law while suspended.  On review, the Florida Supreme Court agreed.  "We conclude that the referee's findings of fact, that [Lawyer] engaged in the practice of law while suspended and that he held himself out as a lawyer while suspended, are supported by competent, substantial evidence in the record."

Disciplinary Case.  While still a member in good standing of the Florida Bar, Lawyer wrote two letters on behalf of a Florida client to an Illinois attorney.  Lawyer was not admitted to practice in Illinois.  The letters were "in contemplation of a legal malpractice action" by Lawyer's Florida client against the Illinois attorney.  Furthermore, Lawyer "researched Illinois law on the Internet" and assisted his Florida client in filing and amending an Illinois civil action against the Illinois attorney.  The client's complaint showed the client's address as being the same as Lawyer's office address.  The referee found that Lawyer engaged in the unlicensed practice of law in Illinois and thus recommended that he be found guilty of violating Rule 4-5.5(a), Rules Regulating The Florida Bar.  Additionally, "[b]ecause [Lawyer] knowingly and intentionally permitted, and even assisted, [the Florida client] in filing a false pleading in Illinois (by allowing [the Florida client] to use [Lawyer]'s law office address as [the client]'s address in a civil action), the referee recommended that [Lawyer] be found guilty of violating Rules Regulating the Florida Bar 4-8.4(c) (a lawyer shall not engage in conduct involving dishonesty, fraud, deceit, or misrepresentation) and 4-8.4(d) (a lawyer shall not engage in conduct in connection with the practice of law that is prejudicial to the administration of justice)."

    The Supreme Court approved the referee's findings and recommendation in the Disciplinary Case, but the Court's analysis left it somewhat unclear as to where the line was drawn between permissible and impermissible conduct.  The Court stated that Lawyer's two letters to the Illinois attorney "standing alone do not constitute a violation.  However, [Lawyer] engaged in further conduct.  The record and testimony establish that [Lawyer] was not licensed to practice law in Illinois and did not seek pro hac vice status.  [Lawyer] admitted researching Illinois law on the Internet to work on this case.  In addition, the record demonstrates that while [Lawyer] was suspended, [Lawyer] used a paralegal so he could assist [the Florida client] to proceed "pro se" in the Illinois matters."  Florida Bar v. D'Ambrosio, __ So.3d ___, 34 Fla.L.Weekly S621 (Fla., Nos. SC07-1369, SC08-256, 12/12/2009), 2009 WL 3763081.

Florida Supreme Court sanctions disbarred lawyer who submitted numerous filings seeking readmission.  [Added 9/2/09]

    Lawyer was disbarred in 1997 for 20 years.  Even though disbarred until at least 2017, Lawyer submitted numerous filings to the Florida Supreme Court seeking readmission.  The Court entered an order to show cause why Lawyer should not be sanctioned for "submitting frivolous filings."

    Despite Lawyer's response, which made the "inapt assertion that he is an industrious professional who is 'not inclined to firvolity,'" the Court imposed sanctions.  Specifically, the Court instructed the Clerk of the Court "to reject for filing any future pleadings, petitions, motions, notices, or other filings submitted by [Lawyer] that are related to his judgments of disbarment or his potential readmission to The Florida Bar, unless the filings are signed by a member in good standing of The Florida Bar."  Florida Board of Bar Examiners re: Anthony Eladio Ramos, 17 So.3d 268 (Fla. 2009).

Trial court erred in granting summary judgment for law firm sued on fee-sharing agreement by disciplined attorney.  [Added 8/11/09]

    Lawyer was suspended from practice.  Lawyer then entered into a written agreement with Law Firm (which was not the firm to which Lawyer had belonged).  Under the agreement Law Firm assumed responsibility for Lawyer's unfinished cases, which included both hourly fee and contingent fee matters.  Law Firm agreed to pay Lawyer as an "independent contractor" for working on the cases, and to compensate him for unpaid fees and advanced costs when the contingent fee cases were resolved.  The Second DCA summarized the financial terms of the agreement:  "[U]nder the agreement, the Law Firm was to pay [Lawyer] compensation at an hourly rate for paralegal work performed by him after the date of the agreement.  For work performed before [Lawyer] suspension from the practice of law, the Law Firm agreed to pay [Lawyer] on a quantum meruit basis when the cases concluded.  Any payments made for work done at an hourly rate were to be credited against the amounts that might be due [Lawyer] in quantum meruit for work he had performed before he was suspended.  The agreement between [Lawyer] and the Law Firm was reviewed and approved by The Florida Bar."

    The agreement was entered into in October 2003.  In March 2005 Lawyer submitted a petition for disciplinary resignation with the Florida Supreme Court.  The Court granted his petition effective nunc pro tunc July 2003.  In 2006 Lawyer sued Law Firm, alleging that the firm owed him money under their agreement.  Law Firm moved for summary judgment, claiming that Lawyer "'chose for his own benefit to voluntarily resign from [T]he Florida Bar and thus make it impossible for him to represent his client'" and that, consequently, he was barred from receiving compensation under Faro v. Romani, 641 So.2d 69 (Fla. 1994) (lawyer who on own volition withdraws from contingent fee case before contingency occurs forfeits right to compensation).  The trial court granted Law Firm's motion for summary judgment.  Lawyer appealed.

    The Second DCA reversed, concluding that Faro's holding was inapplicable.  "Unlike the situation in Faro and similar charging lien cases, here [Lawyer] is not seeking to impose a charging lien on any client's settlement or award.  Nor does he seek the recovery of fees against any of his former clients.  Instead, [Lawyer] is seeking to enforce a written contract with the Law Firm, a successor that assumed a number of his pending cases and agreed to pay him a fee based in quantum meruit for the work he had done and the expenses he had incurred in connection with those cases during the period of time that he was authorized to practice law.  The Law Firm was fully informed about [Lawyer]'s status as a suspended lawyer when it entered into the agreement, and it sought and obtained approval of the agreement from The Florida Bar.  The Law Firm certainly expected to receive benefits from the arrangements that it made with [Lawyer], or it would not have entered into the agreement.  There is nothing in the agreement providing that [Lawyer]'s disciplinary resignation or disbarment would result in the forfeiture of his contractual rights.  Furthermore, the Law Firm does not contend that the conduct which led to [Lawyer]'s suspension and disciplinary resignation had anything to do with any of the cases for which [Lawyer] seeks compensation under the agreement.  Under these circumstances, Faro and similar charging lien cases are simply inapposite."

    The court also cited with approval several opinions of the Florida Bar Professional Ethics Committee:  Florida Ethics Opinions 90-3, 72-16, 66-20, and 65-21.  Regarding Law Firm's contention that the opinions were not authoritative, the court stated:  "We agree that the ethics opinions of The Florida Bar are not controlling; nevertheless, they are persuasive authority and, if well reasoned, are entitled to great weight.  See Estate of Schwartz v. H.B.A. Mgmt., Inc., 673 So.2d 116, 118 (Fla. 4th DCA 1996) (citing Krivanek v. Take Back Tampa Political Comm., 625 So.2d 840, 844 (Fla. 1993), approved, 693 So. 2d 541 (Fla. 1997).  We find The Florida Bar ethics opinions cited above to be persuasive and well-reasoned.  Moreover, these opinions are in accord with well-reasoned decisions on the subject from courts in other jurisdictions."  (Citations omitted.)  Chastain v. Cunningham Law Group, P.A., 16 So.3d 203 (Fla. 2d DCA 2009).

Florida Supreme Court refuses reinstatement for a lawyer who engaged in the "practice of law" while suspended; definition discussed.  [Added 7/13/09]

    In 2006 Lawyer was suspended by the Florida Supreme Court for negligently misappropriating trust funds.  Lawyer subsequently petitioned for reinstatement.  While suspended he had performed paralegal work for two attorneys and also earned "substantial sums as a private consultant with a consulting business he created to advise arcades."  Before his suspension Lawyer had practiced primarily in the gaming law area.

    The referee who presided over the reinstatement hearing found that Lawyer's financial situation was unstable, that he owes a substantial sum to the IRS, that he was "horrible at financial management," and that he failed to take a law office management course for which he had enrolled.  Additionally, while suspended Lawyer cashed checks that were made out to him but were to be used to pay for the legal services of an attorney. and Lawyer did not keep adequate financial records for his consulting business.  The referee recommended that Lawyer be reinstated, but with conditions.  The Bar opposed reinstatement and petitioned for Supreme Court review.

    The Court agreed with the Bar and denied reinstatement.  Contrary to the referee's conclusion, the Court concluded that Lawyer's activities while suspended constituted the practice of law.  "[A]lthough [Lawyer] informed his clients that he could not dispense legal advice, he was not simply identifying applicable statutes and ordinances with regard to opening arcades.  In fact, [Lawyer] testified that he would find the ordinances applicable to the jurisdiction in which an arcade was located and admittedly provided this advice based on his legal skill, which is greater than that possessed by the average citizen.  Further, as stated above, [Lawyer] gave advice on opening arcades, reported on changes in the law applicable to this area, reviewed leases, researched ordinances applicable to new arcade sites, and consulted with a representative of a state attorney’s office on the proper interpretation of gaming law for an attorney’s criminal client.  Based on the definition in [State ex rel. Florida Bar v.] Sperry [140 So.2d 587, 591 (Fla. 1962)], trading on one’s enhanced legal skill and knowledge to advise clients on how to legally proceed with a business transaction and on changes in the law based on statutory research and legal interpretation is the province of licensed attorneys.  Accordingly, the referee’s conclusion that [Lawyer]’s actions did not constitute the practice of law is erroneous and is disapproved."

    The Court further concluded that Lawyer had deposited funds that "were certainly in the nature of trust funds" into his business account on which a lien later was placed.  Lawyer's "poor judgment in accepting, managing, and depositing these checks, along with the fact that his financial management skills are 'horrible,' demonstrates his financial irresponsibility, a disqualifying factor in reinstatement proceedings.  See R. Regulating Fla. Bar 3.10(f)(1)(G).  This factor weighs especially heavy here because this same weakness caused or contributed to the conduct that led to [Lawyer]’s suspension in the first place."

Lawyer's restatement was denied and the Court ordered that he could not reapply for at least one year.  Florida Bar re: Michael Howard Wolf, 21 So.3d 15 (Fla. 2009).

Florida Supreme Court again imposes harsher disciplinary sanctions than recommended by referee, and refuses to recognize personal financial loss and embarrassment in mitigation.  [Added 5/26/09]  --  Florida Bar v. Ticktin, 14 So.3d 928 (Fla. 2009).

Florida Supreme Court disbars lawyer for sexual misconduct, falsifying evidence, and trust account violations.  [Added 5/1/09]  --  Florida Bar v. Tipler, 8 So.3d 1109 (Fla. 2009).

Florida Supreme Court imposes 18-month suspension on lawyer who started business that competed with one of his clients.  [Added 2/24/09]  --  Florida Bar v. Herman, 8 So.3d 1100 (Fla. 2009).

Supreme Court advises Governor that suspended lawyer who was elected to circuit judgeship is not eligible to take judicial office.  [Added 2/4/09]  --  Advisory Opinion to the Governor re: Commission of Elected Judge, 17 So.3d 265 (Fla. 2009).

Rejecting lesser sanction, Supreme Court suspends lawyer (who was just elected to the circuit bench) for disrespectful conduct toward a presiding judge.  [Added 1/10/09]  --  Florida Bar v. Abramson, 3 So.2d 964 (Fla. 2009).

Florida Supreme Court again imposes harsher disciplinary sanction than that recommended by referee and sought by Bar.  [Added 10/21/08]  --  Florida Bar v. De la Torre, 994 So.2d 1032 (Fla. 2008).

Florida Supreme Court again imposes harsher disciplinary sanctions than those recommended by referee and sought by Bar.  [Added 9/26/08]  --  Florida Bar v. Varner, 992 So.2d 224 (Fla. 2008).

Florida Supreme Court disbars rather than suspends lawyer for having what "was in essence a partnership" with nonlawyer for immigration practice.  [Added 6/30/08]  --  Florida Bar v. Glueck, 985 So.2d 1052 (Fla. 2008).

In "disciplinary case of first impression," Florida Supreme Court rejects recommended discipline and suspends lawyer for misconduct related to adoption.  [Added 6/14/2008]  --  Florida Bar v. Dove, 985 So.2d 1001 (Fla. 2008).

Lawyer who is subject of disciplinary proceedings barred from further pro se filings in case by Florida Supreme Court.  [Added 3/21/08]  --  Florida Bar v. Thompson, 979 So.2d 917 (Fla. 2008).  NOTE:  The Supreme Court subsequently permanently disbarred the lawyer.  Florida Bar v. Thompson, 994 So.2d 306 (Table).

Finding additional conflict of interest violation, Florida Supreme Court rejects recommended discipline and suspends lawyer.  [Added 1/24/08]  --  Florida Bar v. Brown, 978 So.2d 107 (Fla. 2008).

Florida Supreme Court rejects referee's findings of mitigating factors and imposes disbarment rather than recommended suspension.  [Added 1/14/08]  --  Florida Bar v. Valentine-Miller, 974 So.2d 333 (Fla. 2008).

In disciplinary case, Florida Supreme Court approves referee's rejection of drug addiction as "physical or mental disability" mitigating factor.  [Added 12/15/07]  --  The Florida Bar v. Bloom, 972So.2d 172 (Fla. 2007).

Florida Bar prosecutors absolutely immune from civil liability for actions taken in connection with their official duties, even if actions taken intentionally and maliciously.  [Added 11/24/07]  --  Spano v. Hoffman, 968 So.2d 674 (Fla. 4th DCA 2007).

Lawyer suspended for 91 days for failing to disclose to opposing counsel settlement agreement procured by lawyer's client and purportedly signed by opposing counsel's client.  [Added 7/13/07]  --  Florida Bar v. Nicnick, 963 So.2d 219 (Fla. 2007).

For first time, Florida Supreme Court readmits on conditional basis lawyer who resigned for disciplinary reasons.  [Added 6/17/07]  --  Florida Board of Bar Examiners re: Mark Stephen Barnett, 959 So.2d 234 (Fla. 2007).

"As a matter of policy" Florida Supreme Court orders respondent lawyer to pay Bar's costs of seeking review of referee's recommended discipline, even though respondent did not seek review.  [Added 6/15/07]  --  Florida Bar v. Martinez-Genova, 959 So.2d 241 (Fla. 2007) (opinion on rehearing).

Florida Supreme Court rejects referee's recommendation and imposes reprimand rather than diversion in case involving lawyer's "sharp practice."  [Added 6/9/07]  --  Florida Bar v. Cocalis, 959 So.2d 163 (Fla. 2007).

Florida Supreme Court discusses use of "failure to acknowledge wrongful nature of conduct" as aggravating factor in disciplinary cases.  [Added 5/21/07]  --  Florida Bar v. Germain, 957 So.2d 613 (Fla. 2007).

Florida Supreme Court holds that Rule 4-5.6(b) is constitutional, and imposes fee forfeiture and stiff discipline on 2 lawyers who entered undisclosed engagement agreement with clients' adversary.  [Added 5/8/07]  --  Florida Bar v. Rodriguez, 959 So.2d 150 (Fla. 2007); Florida Bar v. St. Louis, 967 So.2d 108 (Fla. 2007).

Rejecting referee's recommendation, Florida Supreme Court suspends rather than disbars lawyer convicted of felonies.  [Added 4/25/07]  --  Florida Bar v. Del Pino, 955 So.2d 556 (Fla. 2007).

Supreme Court suspends lawyer for 90 days, rather than 2 years as recommended by referee, for violating competence and conflict rules.  [Added 4/17/07]  --  Florida Bar v. Maurice, 955 So.2d 535 (Fla. 2007).

Florida Supreme Court disbars lawyer charged with misappropriating client funds, despite mental health mitigation and referee's recommendation of 3-year suspension.  [Added 4/4/07]  --  Florida Bar v. Brownstein, 953 So.2d 502 (Fla. 2007).

Florida Supreme Court disbars lawyer who practiced while suspended.  [Added 2/26/07]  --  The Florida Bar v. Walkden, 950 So.2d 407 (Fla. 2007).

Florida Supreme Court refuses to order lawyer to pay restitution to third party in disciplinary case.  [Added 12/15/06]  --  Florida Bar v. Walton, 952 So.2d 510 (Fla. 2006).

Lawyer's trial conduct leading to trial court's imposition of sanctions results in 91-day suspension by Supreme Court (rather than 10-day recommended suspension).  [Added 11/2/06]  --  The Florida Bar v. Tobkin, 944 So.2d 219 (Fla. 2006).

Lawyer who failed to properly supervise employee had requisite "intent" and was found guilty of violating Rule 4-8.4(c) and suspended for 3 years.  [Added 10/6/06]  --  The Florida Bar v. Riggs, 944 So.2d 167 (Fla. 2006).

Lawyer's "mere attendance at a courtroom proceeding," without more, not sufficient to support conclusion that lawyer practiced law while suspended.  [Added 10/23/06]  --  The Florida Bar v. D'Ambrosio, 944 So.2d 977 (Fla. 2006).

Suspended lawyer who failed to provide evidence of alcohol and drug rehabilitation denied reinstatement.  [Added 10/20/06]  --  The Florida Bar re: Alan R. Hochman, 944 So.2d 198 (Fla. 2006).

Fourth DCA upholds perjury conviction of lawyer's former employee who filed bar grievance containing untrue statement.  [Added 10/18/06]  --  Rutherford v. State, 939 So.2d 328 (Fla. 4th DCA 2006).

Fee refunds may be ordered only under limited circumstances in disciplinary cases, per Florida Supreme Court.  [Added 6/29/06]  --  The Florida Bar v. Feige, 937 So.2d 605 (Fla. 2006).

Lawyer suspended for 91 days for "inappropriate courtroom behavior."  [Added 6/26/06]  --  The Florida Bar v. Morgan, 938 So.2d 496 (Fla 2006).

Florida Supreme Court warns that it is moving toward stronger sanctions for lawyer misconduct.  [Added 6/8/06]  --  The Florida Bar v. Broome, 932 So.2d 1036 (Fla. 2006).

Bar's unexplained delay in prosecuting disciplinary case is factor in Court's decision to impose 2-year, rather than 3-year, suspension.  [Added 2/24/06]  --  The Florida Bar v. Wolf, 930 So.2d 574 (Fla. 2006).

Florida denies reinstatement to suspended lawyer who has not been readmitted to bar of his home state.  [Added 2/20/06]  --  The Florida Bar re: Untracht, 923 So.2d 457 (Fla. 2006).

"Managing attorney" for nonlawyer's immigration business suspended for one year for assisting UPL and fee-splitting with nonlawyer.  [Added 1/18/06]  --  The Florida Bar v. Abrams, 919 So.2d 425 (Fla. 2006).

90-day suspension for lawyer who acted as counsel of record for disbarred lawyer and thus allowed him to provide legal services for his clients and commit UPL.  [Added 11/28/05]  --  The Florida Bar v. Stein, 916 So.2d 774 (Fla. 2005).

Lawyer who practiced law while suspended sanctioned; no willful contempt due to mental health mitigation.  [Added 10/18/05]  --  The Florida Bar v. Shoureas, 913 So.2d 554 (Fla. 2005).

Florida Bar grievance committee meetings confidential; respondents may be barred from attending.  [Added 10/18/05]  --  The Florida Bar v. Committe, 916 So.2d 741 (Fla. 2005).

Florida Supreme Court declines to revoke lawyer's board certification as disciplinary sanction.  [Added 9/21/05]  --  The Florida Bar v. Kavanaugh, 915 So.2d 89 (Fla. 2005).

Misconduct dealing with his law firm nets lawyer 90-day suspension.  [Added 7/12/05]  --  The Florida Bar v. Shankman, 908 So.2d 379 (Fla. 2005).

Lawyer's moonlighting and subsequent denial results in loss of job and 30 day suspension from practice.  [Added 6/2/05]  --  The Florida Bar v. Kossow, 912 So.2d 544 (Fla. 2005).

ADA does not preclude Supreme Court from disbarring lawyer with serious drug and alcohol addiction.  [Added 3/3/05]  --  The Florida Bar v. Gross, 896 So.2d 742 (Fla. 2005).

Lawyer's cessation of conduct that resulted in emergency suspension not valid basis for lifting suspension.  [Added 2/4/05]  --  The Florida Bar v. Guerra, 896 So.2d 705 (Fla. 2005).

3-year suspension, not disbarment, appropriate for cases of client neglect short of "abandonment."  [Added 8/23/04]  --  The Florida Bar v. Shoureas, 892 So.2d 1002 (Fla. 2004).

Supreme Court rules that writing single $100 worthless check does not violate disciplinary rules, and declines to order restitution absent improper fees or misappropriation.  [Added 1/22/04]  --  The Florida Bar v. Smith, 866 So.2d 41 (Fla. 2004).