slip.op
Md.
2026
Read the full case

Background

  • The Attorney Grievance Commission filed a disciplinary petition alleging Sara Mohamed Samy El-Shall violated diligence, communication, termination, disciplinary-cooperation, and misconduct rules based on three client matters and her noncooperation with Bar Counsel. 1
  • After El-Shall failed to answer, the hearing judge entered default, later granted default judgment and discovery sanctions, and El-Shall did not appear at the evidentiary hearing. 2
  • The hearing judge found El-Shall had effectively abandoned Stacey Wisniewski, repeatedly failed to communicate with her, and ignored Bar Counsel’s requests and subpoena in that complaint investigation. 3
  • The hearing judge found El-Shall ceased communicating with De’Errick’A Hawks after the retainer, failed to help schedule required care, and did not cooperate with Bar Counsel or appear for a subpoenaed statement. 4
  • The hearing judge found El-Shall ignored Marquisha Jackson’s repeated requests for settlement paperwork and withdrawal, and likewise failed to cooperate with Bar Counsel or appear under subpoena. 5
  • The Court held El-Shall violated Rules 1.3, 1.4(a) and (b), 1.16(d), 8.1(b), and 8.4(a) and (d), found multiple aggravating factors, and imposed indefinite suspension with reinstatement conditions. 6

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Did El-Shall violate diligence and communication rules? 7 Commission said she repeatedly ignored clients and failed to advance their matters. El-Shall relied on later explanations and mental-health issues. Yes; repeated nonresponse and inaction violated Rules 1.3 and 1.4. 8
Did El-Shall terminate representation properly? 9 Commission said she abandoned clients without protecting their interests. El-Shall argued she eventually withdrew in Jackson’s matter. Yes; she effectively abandoned all three clients and delayed withdrawal. 10
Did El-Shall violate disciplinary-cooperation rules? 11 Commission said she ignored Bar Counsel’s requests and subpoenaed statement. El-Shall disputed the identity-denial theory and cited health issues. Yes; repeated nonresponse to Bar Counsel violated Rule 8.1(b). 12
What aggravating and mitigating factors applied? 13 Commission sought pattern, multiple violations, obstruction, refusal to acknowledge, and indifference; also likelihood of repetition. El-Shall invoked mental-health mitigation and lack of prior discipline. Five aggravators and one mitigator applied; no likelihood-of-repetition finding. 14
What sanction was appropriate? 15 Commission sought disbarment. El-Shall sought indefinite suspension with six-month reinstatement right. Indefinite suspension; reinstatement requires medical proof and, if solo, a practice monitor. 16

Key Cases Cited

  • Attorney Grievance Comm'n v. Bonner, 477 Md. 576 (Md. 2022) (original and complete jurisdiction in attorney discipline proceedings 17)
  • Attorney Grievance Comm'n v. Hoerauf, 469 Md. 179 (Md. 2020) (factual findings reviewed for clear error; legal conclusions de novo 18)
  • Attorney Grievance Comm'n v. O'Neill, 477 Md. 632 (Md. 2022) (a factual finding is not clearly erroneous if supported by competent evidence 19)
  • Attorney Grievance Comm'n v. Dailey, 474 Md. 679 (Md. 2021) (diligence and Bar Counsel noncooperation violations can arise from repeated nonresponse and abandonment 20)
  • Attorney Grievance Comm'n v. Rossbach, 485 Md. 563 (Md. 2023) (Rule 1.4 requires keeping clients reasonably informed; misconduct may be prejudicial to justice 21)
  • Attorney Grievance Comm'n v. Kotlarsky, 453 Md. 469 (Md. 2017) (repeated failure to respond to Bar Counsel can violate Rule 8.1(b) 22)
  • Attorney Grievance Comm'n v. Yeatman, 489 Md. 211 (Md. 2024) (violating another professional rule also violates Rule 8.4(a) 23)
  • Attorney Grievance Comm'n v. Lee, 393 Md. 546 (Md. 2006) (indefinite suspension is appropriate for abandonment and noncooperation when disbarment is unnecessary 24)
  • Attorney Grievance Comm'n v. Kovacic, 389 Md. 233 (Md. 2005) (indefinite suspension imposed for failure to communicate and cooperate despite no prior discipline 25)
  • Attorney Grievance Comm'n v. King, 491 Md. 485 (Md. 2025) (describes aggravating and mitigating factors and sanction principles 26)
  • Attorney Grievance Comm'n v. Hamilton, 493 Md. 42 (Md. 2026) (disbarment appropriate for more egregious abandonment, obstruction, and repeated misconduct 27)
  • Attorney Grievance Comm'n v. Taniform, 482 Md. 272 (Md. 2022) (lists mitigating factors and reinstatement-related considerations 28)
  • Attorney Grievance Comm'n v. Lee, 387 Md. 89 (Md. 2005) (court may remand for newly proffered material evidence in disciplinary cases 29)
Read the full case