Attorney Grievance Commission v. Goodman
426 Md. 115
| Md. | 2012Background
- Spearman and Silver hired Goodman to pursue personal injury claims and authorized payment of medical bills from any recovery.
- Goodman reduced bills with UMPTWC by $400 each, but UMPTWC never received payment from Goodman.
- Spearman and Silver later learned bills remained unpaid; collection agency letters prompted AGC complaint in 2008.
- Goodman admitted not maintaining a client trust account and depositing settlement funds into his operating account; records were allegedly lost in a divorce.
- Hearing found clear and convincing evidence that Goodman violated multiple MRPC rules and related statutes.
- Court imposed disbarment and cost-shifting (including paying AGC costs).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Trust account violations | AGC | Goodman | Violation established; improper funds handling. |
| Delay and failure to pay client medical bills | AGC | Goodman | Violation established; duty to timely pay bills from recoveries. |
| Misuse and commingling of funds | AGC | Goodman | Violation established; misappropriation inferred from lack of records and unpaid bills. |
| Appropriate sanction | AGC | Goodman | Disbarment warranted. |
Key Cases Cited
- Att'y Griev. Comm'n v. Roberts, 394 Md. 137 (2006) (late payment to medical providers violated 1.3)
- Att'y Griev. Comm'n v. Zuckerman, 386 Md. 341 (2005) (late payment and trust issues violated MRPC 1.15 and related rules)
- Att'y Griev. Comm'n v. Nwadike, 416 Md. 180 (2010) (strict record-keeping required for escrow accounts; adverse inference possible)
- Att'y Griev. Comm'n v. Roberts, 394 Md. 137 (2006) (delay and misappropriation context informing discipline)