289 A.3d 703
Md.2023Background:
- Keith Anthony Parris, admitted 1987, represented Chaddsford Community Association in litigation with its former law firm over attorney fees.
- Parris repeatedly failed to timely respond to discovery, ignored court orders compelling discovery, and did not oppose the firm’s motions for sanctions and default.
- The circuit court entered sanctions ($1,225) and a $75,000 default judgment against Chaddsford; Parris delayed notifying the client and misrepresented the timing/status of the judgment.
- Parris billed and collected $8,830 in fees while performing little or no meaningful work and created knowingly false time entries.
- Parris made knowing misrepresentations to the trial court, omitted material facts from communications with his client, and failed to respond to multiple Bar Counsel inquiries; he defaulted in the disciplinary proceeding.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competence / Diligence / Communication (Rules 1.1, 1.3, 1.4, 3.2, 3.4) | Parris abandoned the case, failed discovery and court orders, did not inform client, causing $75,000 loss. | No substantive defense (failed to respond; defaulted). | Clear-and-convincing evidence supported violations; client harmed by default and sanctions. |
| Fee Reasonableness (Rule 1.5) | Fees became unreasonable because Parris billed for services not performed and fabricated time entries. | No defense presented. | Court found $8,830 in unreasonable fees charged and collected. |
| Candor to Tribunal (Rule 3.3) | Parris knowingly misrepresented that he was hindered in obtaining discovery and was gathering materials when he had received them. | No response; no contest to findings. | Court held Parris made knowing, intentional false statements to the trial court. |
| Response to Disciplinary Inquiry (Rule 8.1) | Parris failed to respond to repeated Bar Counsel letters and investigator contact. | Claimed to have not received letters (later contradicted by investigator delivery). | Violated duty to respond to disciplinary authority. |
| Misconduct / Prejudicial Conduct (Rule 8.4) | Pattern of dishonesty, multiple MARPC violations, billing fraud, and obstruction warrant serious sanction. | No mitigation or restitution offered. | Violations of 8.4(a), (c), (d) found; conduct prejudicial to administration of justice. |
| Appropriate Sanction | Disbarment recommended to protect the public and deter future misconduct. | No argument opposing sanction (no filings/exceptions). | Court ordered disbarment and assessed costs. |
Key Cases Cited
- Silbiger v. Att’y Grievance Comm’n, 478 Md. 607 (disbarment ordinarily warranted for intentional dishonesty)
- Edwards v. Att’y Grievance Comm’n, 462 Md. 642 (overlap of competence and diligence; sanction principles)
- Brown v. Att’y Grievance Comm’n, 426 Md. 298 (failure to comply with discovery and resulting sanctions support discipline)
- Hoerauf v. Att’y Grievance Comm’n, 469 Md. 179 (failure to respond to Bar Counsel; Rule 8.1; misconduct analysis)
- Leatherman v. Att’y Grievance Comm’n, 475 Md. 80 (failure to communicate with client supports Rule 1.4 violation)
- Hamilton v. Att’y Grievance Comm’n, 444 Md. 163 (failure to respond to discovery leading to sanctions supports discipline)
- Collins v. Att’y Grievance Comm’n, 477 Md. 482 (Rule 3.3 violations where attorney misrepresents receipt or status of communications)
- Powell v. Att’y Grievance Comm’n, 461 Md. 189 (competence and diligence violations for failing to comply with court orders)
- White v. Att’y Grievance Comm’n, 480 Md. 319 (sanctioning objectives: protect public and deter misconduct)