Application of Brown to the Bar, 144 A.3d 1188

Deirdre P. Brown applied for admission to the Maryland Bar in May 2012; her file was investigated by the Seventh Appellate Character Committee and the State Board of Law Examiners.
Brown failed to disclose a 1992 felony theft charge on her Bar application (she disclosed only a false-statement-to-a-police-officer charge); the charges were stetted and did not result in convictions.
While in her final semester of law school (2012), Brown intentionally falsified her law-school resume by inflating her GPA from 2.71 to 3.71 to qualify for an employer; the law school issued an academic reprimand.
Brown admitted the resume falsification and expressed remorse; she later said she did not recall the theft charge (her testimony about recollection was inconsistent).
Brown had multiple delinquent credit accounts but provided documentation showing she later paid them and thereafter maintained responsible financial management.

Issue	Plaintiff's Argument (Brown)	Defendant's Argument (Board/Opponents)	Held
Failure to disclose prior felony theft charge on Bar application	She was unaware of the separate theft charge and therefore did not intentionally omit it	Omission was of a known charge; she signed an affirmation of full disclosure; inconsistent testimony undermines credibility	Denied — omission and inconsistent statements show lack of candor required for admission
Intentional falsification of GPA on law-school resume	A lapse in judgment in law school, followed by remorse and subsequent good conduct, shows rehabilitation	Deliberate, calculated deception to obtain employment, not excused by remorse; occurred while preparing for legal career	Denied — falsification evidences lack of truthfulness and integrity
Financial irresponsibility (delinquent debts)	Past poor planning; debts have been paid and current accounts are in good standing, showing rehabilitation	Prior delinquencies were concerning for fitness to practice	Not dispositive — record showed debts were resolved and financial management improved
Overall present moral character and fitness for Bar admission	Recent professional conduct (settlement agent, notary) and mitigation letters show rehabilitation and fitness	Pattern of dishonesty, failure of candor, and inconsistent explanations undermine present moral fitness	Denied — cumulative lack of candor and honesty means applicant failed to carry burden of proving present moral character

In re Application of T. Z.-A.O., 441 Md. 65, 105 A.3d 492 (court conducts independent review of applicant's present moral character)
In re Application of Cramer, 427 Md. 612, 50 A.3d 1066 (defines good moral character to include truthfulness and candor)
In re Application of Stern, 403 Md. 615, 943 A.2d 1247 (Board determinations entitled to great weight; Court independently evaluates record)
In re Application of Brown, 392 Md. 44, 895 A.2d 1050 (failure to disclose serious adverse facts supports denial of admission)
In re Application of Hyland, 339 Md. 521, 663 A.2d 1309 (inconsistent or evasive testimony can warrant denial for lack of candor)
In re Application of Strzempek, 407 Md. 102, 962 A.2d 988 (duty of full disclosure on Bar application is mandatory, not optional)