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FLORIDA NEWS ARCHIVE - LAWYER ETHICS, Disciplinary Proceedings Florida Supreme Court suspends lawyer for 3 years rather than 90 days; confidentiality gives way to fiduciary obligations when holding money in trust for non-client. [Added 12/13/11] Lawyer represented developer Meyer in connection with a “financing device” referred to as a “standby letter of credit.” The underlying facts were complex and involved a number of parties. Investors were solicited and apparently informed that the funds they invested would be held in Lawyer’s trust account and then returned to them along with “exceptional interest.” At some point Lawyer prepared and signed 5 letters addressed to possible investors. The letters inaccurately suggested, however, that the 5 recipients had already provided their funds to Lawyer. The funds that were received were deposited in Lawyer’s trust account and later disbursed by him upon instructions from Meyer. None of the investors were notified or gave their permission before the disbursement occurred. The Bar charged Lawyer with violations of Rule 4-8.4(c) (conduct involving dishonesty, fraud, deceit, or misrepresentation) and Rule 5-1.1(b) (lawyer must hold property of others with care required of professional fiduciary). The referee before whom the case was tried recommended that Lawyer be found guilty of violating Rule 5-1.1(b). The referee recommended that Lawyer be found not guilty of violating Rule 4-8.4(c) because Lawyer “acted negligently and, thus, did not intend to engage in misrepresentation.” The recommended discipline was a 90-day suspension followed by a 3-year probation. The Bar sought Florida Supreme Court review. The Court approved the guilty recommendation regarding the trust accounting violations but disapproved the not-guilty recommendation regarding Rule 4-8.4(c). The Court also suspended Lawyer for 3 years instead of 90 days. The Court rejected the referee’s finding that Lawyer acted negligently rather than intentionally. Citing its precedent, the Court stated that “[t]he motive behind the attorney’s action is not the determinative factor. Rather, the issue is whether the attorney deliberately or knowingly engaged in the activity in question.” (Citations omitted.) The actions Lawyer took (e.g., writing and signing the letters, transferring money out of his trust account) were deliberately or knowingly engaged in, and so his conduct was intentional and violated Rule 4-8.4(c). The Court did not accept Lawyer’s contention that his conduct concerning the letters could not violate the rule unless it was proven that someone relied on them. “Deceitful conduct does not have to be successful in order to be found dishonest.” Lawyer also asserted that Meyer was his client and so he could not provide the investors with the information that they requested regarding the status of their funds. The Court disagreed, noting that Lawyer owed fiduciary duties to the investors. “[L]awyers often hold funds in escrow where their client is one principal and a non-client is another principal party. By undertaking to do so, the lawyer establishes a new legal relationship with the principal parties either by an expressed agreement or by an agreement implied in law. The relationship that is established is one of principal and agent, in which the lawyer is an agent of, and owes a fiduciary duty to, all of the principals. Absent a written agreement, the law implies that the attorney will know the conditions of the principals’ agreement and will exercise reasonable skill and ordinary diligence in the holding and delivering of the escrowed funds in accordance with that agreement.” In suspending Lawyer for 3 years, the Court stated: “[Lawyer] misused his status as an attorney to harm members of the public. He caused these individuals to believe that their funds would be safe in his attorney trust account, yet he intentionally disbursed their funds without their knowledge or consent. [Lawyer]’s flagrant misuse of his position as an attorney, by which he purposefully lulled members of the public into thinking their funds would be safe in his account, merits a severe sanction.” Florida Bar v. Watson, __ So.3d ___, 36 Fla.L.Weekly S713 (Fla., No. SC09-2022, 12/8/2011), 2011 WL 6090078.
Florida Supreme Court makes additional guilty finding and increases recommended suspension from 10 to 91 days in disciplinary case. [Added 11/4/11] Lawyer was accused by the Florida Bar of sending a fraudulent subpoena to a bank in order to obtain records of a client who had written checks to her. The fraudulent subpoena stated: "If you fail to produce these records and the above requested information as described, you may be held in contempt of court, punishable by a fine or incarceration or both." In reality, there was no pending case and the bogus subpoena was not authorized by law. The referee assigned to hear the disciplinary case recommended that Lawyer be found guilty of violating Rule 4-8.4(d) (conduct prejudicial to the administration of justice). The referee recommended that Lawyer be found not guilty of several other charged violations, including Rule 4-8.4(c) (conduct involving dishonesty, fraud, deceit, or misrepresentation). The referee recommended a 10-day suspension. The Bar sought Supreme Court review. The Supreme Court concluded that Lawyer did violate Rule 4-8.4(c). Despite Lawyer's assertion that the sending of the subpoena was a mistake, the referee found that she "knowingly and deliberately sent the purported subpoena with the offending language." Lawyer also argued that she did violate the rule because the Bar did not prove she had engaged in fraud. Neither of these contentions impressed the Court. "[T]here is no requirement that fraud must be proven to show that a respondent violated the rule. In fact, conduct involving any element, such as dishonesty, deceit, or misrepresentation, can result in a violation of rule 4-8.4(c)." The Court summarized: "[W]e disapprove the referee's recommendation that [Lawyer] be found not guilty of violating rule 4-8.4(c). Because the record and the referee's findings show that [Lawyer] 'knowingly and deliberately sent the purported subpoena with the offending language,' which was 'clearly designed to cause the bank to produce the records without legal authority,' and thus 'clearly misleading' (Report of Referee at 3), we find [Lawyer] guilty of violating rule 4-8.4(c)." (In a footnote the Court pointed out that "the motive behind the [Lawyer]'s action is not the determinative factor; rather, the issue is whether [Lawyer] deliberately or knowingly engaged in the activity in question.") The Court also rejected the recommended 10-day suspension and instead suspended Lawyer for 91 days. "In considering violations of rules 4-8.4(c) and 4-8.4(d), we have explicitly stated that 'basic, fundamental dishonesty . . . is a serious flaw, which cannot be tolerated [because] '[d]ishonesty and a lack of candor cannot be tolerated by a profession that relies on the truthfulness of its members.'' [Citations omitted.] [Lawyer] has engaged in serious misconduct – she abused the subpoena power, which is a power of the court, for her personal investigation. Such dishonest conduct demonstrates the utmost disrespect for the court and is destructive to the legal system as a whole." Florida Bar v. Berthiaume, __ So.3d ___, 36 Fla.L.Weekly S631 (Fla., No. SC08-1786, 11/3/2011), 2011 WL 5217514.
By 4-3 vote Florida Supreme Court rejects Bar's opposition and reinstates lawyer who failed to file delinquent tax returns until he petitioned for reinstatement. [Added 10/14/11] Lawyer had been voluntarily placed on the Florida Bar inactive list for incapacity unrelated to misconduct. At that time he was serving a 3-year probation for a prior disciplinary offense. Lawyer petitioned the Florida Supreme Court for reinstatement. The Bar opposes reinstatement. By a 4-3 vote the Court reinstated Lawyer. Three justices dissented on the ground that Lawyer failed prove that he had not been financially irresponsible during his inactive period. The dissent noted that Lawyer had willfully failed to file tax returns for 2007 and 2008, and did not file the returns until he filed them in conjunction with his petition for reinstatement. The dissenting opinion stated: "Willful failure to file a tax return is a misdemeanor offense, see 26 U.S.C.A. § 7203 (2011), and the comment to Rule Regulating the Florida Bar 4-8.4 expressly notes that the 'willful failure to file an income tax return' is 'illegal conduct [that] reflect[s] adversely on fitness to practice law.' Contrary to the referee's determination, [Lawyer]'s willful disregard of his obligation to file income tax returns is disqualifying conduct. This flouting of the federal income tax law is serious misconduct which should preclude [Lawyer]' reinstatement until he has demonstrated rehabilitation." Furthermore, in the view of the dissenting justices Lawyer's "disregard of his obligation to file his tax returns is part of a pattern of misconduct" that included the disciplinary probation and a criminal conviction for a "road rage" incident. The dissent concluded: "It does damage to the credibility of The Florida Bar to reinstate a lawyer who has so recently flouted the federal income tax law and has otherwise shown a disregard for the requirements of the law." Florida Bar v. Hudson, ___ So.3d ___, 36 Fla.L.Weekly S605 (Fla., No. SC10-329, 10/13/2011), 2011 WL 4835808.
Florida Supreme Court suspends lawyer who sent non-complying direct mail letter containing material false statements. [Added 9/7/11] Lawyer sent more than 900 direct mail solicitation letters regarding a "purported class action" to current and former part-time adult education teachers. The Bar charged Lawyer with various rules violations. The referee assigned to try the case found that the letters contained inaccurate and erroneous statements that were meant to induce the prospective clients to hire Lawyer. Additionally, the letters did not comply with the technical requirements governing direct mail advertisements. Accordingly, the referee recommended that Lawyer be found guilty of violating Rules Regulating The Florida Bar 3-4.2 (violation of rules of professional conduct is cause for discipline), 4-7.4(a) (solicitation), and 4-8.4(d) (conduct prejudicial to administration of justice). The referee recommended a not guilty finding as to other charges. The referee recommended a 90 day suspension. On review, the Florida Supreme Court found additional rules violation and increased the disciplinary sanction to a 1-year suspension followed by 3 years of probation. In addition to the rules cited above, the Court found Lawyer guilty of violating rules 4-4.1 (false statement of material fact to third person), 4-8.4(a) (violating or attempting to violate rules of professional conduct), and 4-8.4(c) (conduct involving dishonesty, fraud, deceit or misrepresentation). Lawyer's prior disciplinary history (Florida Bar v. Letwin, 14 So.3d 243 (Fla. 2009); Florida Bar v. Letwin, 652 So.2d 818 (Fla. 1995)) and "the seriousness of the misconduct" resulted in the stiffer sanction. A defense raised by Lawyer was that "she already viewed the recipients of the letter as her 'clients' and that because of the multiple lawsuits she had filed, there was a 'budding attorney-client relationship' between her and the putative class members." The Court stated that "nothing in the record showed that a true attorney-client relationship had been established." Florida Bar v. Letwin, 70 So.3d 578 (Fla. 2011).
Florida Supreme Court suspends lawyer for providing improper financial assistance to client. [Added 6/28/11] -- Florida Bar v. Patrick, 67 So.3d 1009 (Fla. 2011).
Disbarred lawyer is prohibited from further pro se filings in Florida Supreme Court. [Added 5/17/11] -- Florida Bar v. Kivisto, 62 So.3d 1137 (Fla. 2011).
Supreme Court suspends lawyer for 3 years for rule violations in representation of putative class. [Added 5/4/11] -- Florida Bar v. Adorno, 60 So.3d 1016 (Fla. 2011).
Lawyer publicly reprimanded for threatening to present criminal charges to gain advantage in civil matter. [Added 5/2/11] -- Florida Bar v. Knowles, 64 So.3d 1195 (Fla. 2011).
Florida Supreme Court disbars lawyer for multiple trust account violations. [Added 4/8/11] -- Florida Bar v. Mirk, 64 So.3d 1180 (Fla. 2011).
Florida Supreme Court suspends lawyer whose sexual relationships with clients violated conflict rule and other rules. [Added 3/7/11] -- Florida Bar v. Roberto, 59 So.3d 1101 (Fla. 2011).
Florida Supreme Court disbars rather than suspends lawyer who practiced while suspended, with 3 concurring justices criticizing conduct of Bar prosecutor. [Added 2/5/1] -- Florida Bar v. Lobasz, 64 So.3d 1167 (Fla. 2011).
Lawyer is disbarred, not suspended, for criminal convictions and misconduct relating to drug abuse. [Added 11/11/10] -- Florida Bar v. Irish, 48 So.3d 767 (Fla. 2010).
Florida Supreme Court denies rehearing for lawyer disciplined for using trade name "Legal Experts." [Added 8/31/10] -- Florida Bar v. Doane, 43 So.3d 640 (Fla. 2010).
Florida Supreme Court disbars rather than suspends lawyer for misusing law to hurt members of public for personal gain. [Added 8/27/10] -- Florida Bar v. Hall, 49 So.3d 1254 (Fla. 2010).
Florida Supreme Court rejects suspension recommendation and instead disbars lawyer convicted of drug trafficking. [Added 8/27/10] -- Florida Bar v. Liberman, 43 So.3d 36 (Fla. 2010).
Florida Supreme Court imposes stricter discipline than recommended by referee in case involving conflict, competence, and misrepresentation. [Added 7/14/10] -- Florida Bar v. Shankman, 41 So.3d 166 (Fla. 2010).
Lawyer permanently disbarred, rather than suspended, for uncharged income tax evasion. [Added 7/2/10] -- Florida Bar v. Behm, 41 So.3d 136 (Fla. 2010).
Conduct resulting in finding of no probable cause can be used as aggravating factor in disciplinary case, per Florida Supreme Court. [Added 6/30/10] -- Florida Bar v. Ratiner, 46 So.3d 35 (Fla. 2010) (revised opinion).
Florida Supreme Court disciplines lawyer who allowed non-lawyer to have signatory authority on escrow account. [Added 6/10/10] -- Florida Bar v. Hines, 39 So.3d 1196 (Fla. 2010).
In conflict of interest case, Florida Supreme Court imposes harsher disciplinary sanction than that recommended by referee. [Added 6/10/10] -- Florida Bar v. Scott, 39 So.3d 309 (Fla. 2010).
Florida Supreme Court disciplines lawyer for using firm name containing term "expert." [Added 5/21/10] -- Florida Bar v. Doane, 43 So.3d 640 (Fla. 2010).
Florida Supreme rejects referee's recommended sanction and disbars suspended lawyer found guilty of contempt. [Added 3/2/10] -- Florida Bar v. Bitterman, 33 So.3d 686 (Fla. 2010).
Florida Supreme Court rejects stipulation for reinstatement of suspended lawyer due to her failure to pay restitution and costs. [Added 2/19/10] -- 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] -- Florida Bar v. Head, 27 So.3d 1 (Fla. 2010).
Florida Supreme Court disbars lawyer for two instances of engaging in unlicensed practice of law. [Added 11/18/09] -- Florida Bar v. D'Ambrosio, 25 So.3d 1209 (Fla. 2009).
Florida Supreme Court sanctions disbarred lawyer who submitted numerous filings seeking readmission. [Added 9/2/09] -- 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] -- 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] -- 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). |
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