257 A.3d 1061
Md.2021Background
- Christopher E. Vasiliades applied for admission to the Maryland bar in March 2016, answered “No” to questions about conditions (including substance abuse) that could affect his fitness, but later admitted in a sworn statement that he had been addicted to Percocet in 2016 and subsequently took prescribed Suboxone. He did not disclose this to the Character Committee investigator or the Lawyers Assistance Program evaluator.
- The Character Committee investigator met with Vasiliades multiple times, then recommended admission after an alcohol/substance evaluation that reported full disclosure; Vasiliades was admitted to the Maryland Bar on December 14, 2016.
- In January–June 2019 Vasiliades assaulted J.T. (squeezed yogurt on her head), was charged with second-degree assault, was subject to temporary and then final protective orders, and repeatedly contacted J.T. in violation of those orders.
- Vasiliades maintained public social media accounts linked to his law practice that contained racially, sexually, and homophobic derogatory posts and re-tweets; he used those accounts to advertise his firm.
- The hearing judge found, by clear and convincing evidence, violations of MARPC Rule 19-308.1(b) (Rule 8.1(b)) and Rules 19-308.4(a), (b), (c), (d), and (e) (Rule 8.4 series); the Court of Appeals imposed disbarment. The judge identified aggravating factors (dishonesty, pattern of misconduct, multiple offenses, refusal to acknowledge wrongdoing) and several mitigating factors (no prior discipline, personal/emotional problems, cooperation, interim therapy, positive community reputation).
Issues
| Issue | Petitioner (Attorney Grievance) | Respondent (Vasiliades) | Held |
|---|---|---|---|
| Did Vasiliades violate Rule 8.1(b) by failing to disclose substance addiction/treatment during admission and failing to supplement his application? | He knowingly omitted material facts (Percocet addiction, Suboxone treatment) and failed to correct misapprehensions. | He subjectively believed his condition did not affect his ability to practice and claims he was not specifically asked. | Yes — failure to disclose/supplement violated Rule 8.1(b). |
| Did his assault and subsequent contacts in violation of protective orders violate Rule 8.4(b)/(d)? | The assault and deliberate violations are criminal acts reflecting adversely on fitness and prejudicial to administration of justice. | He minimized the incidents and argued lack of requisite proof / consensual character. | Yes — clear and convincing evidence of second-degree assault and protective-order violations; Rule 8.4(b) and (d) violations. |
| Did his omissions and false statements during the admissions/investigative process amount to dishonesty in violation of Rule 8.4(c)? | Silence and failure to correct application answers during character investigation were deceitful and intentional. | He contends any inaccuracies were not intentional misrepresentations. | Yes — deliberate omissions and failures to disclose material information violated Rule 8.4(c). |
| Did publicly linked social media posts violate Rule 8.4(e) (manifesting bias while acting in professional capacity)? | Posts containing racial, sexist, and homophobic slurs on accounts linked to his law practice knowingly manifested bias prejudicial to administration of justice. | Posts were personal/social discourse within cultural context and not professional conduct. | Yes — accounts advertised his firm and posts occurred in that professional context; Rule 8.4(e) violated. |
Key Cases Cited
- Attorney Grievance Comm’n v. Van Dusen, 116 A.3d 1013 (Md. 2015) (failure to supplement bar application can warrant disbarment)
- Attorney Grievance Comm’n v. Slate, 180 A.3d 134 (Md. 2018) (silence on bar application constitutes deceit and supports disbarment)
- Attorney Grievance Comm’n v. Keating, 243 A.3d 520 (Md. 2020) (framework for weighing sanctions and deference to hearing judge)
- Attorney Grievance Comm’n v. Gracey, 136 A.3d 798 (Md. 2016) (misconduct violating multiple Rules supports severe sanction)
- Attorney Grievance Comm’n v. Markey, 230 A.3d 942 (Md. 2020) (elements for Rule 8.4(e) bias/prejudice violation when acting in professional capacity)
- Attorney Grievance Comm’n v. Yates, 225 A.3d 1 (Md. 2020) (conviction not required for Rule 8.4(b); clear and convincing evidence of criminal act suffices)
- Attorney Grievance Comm’n v. Woolery, 198 A.3d 835 (Md. 2018) (deference to hearing judge and approach to credibility findings)
- Attorney Grievance Comm’n v. Mahone, 150 A.3d 870 (Md. 2016) (intentional dishonest conduct ordinarily warrants disbarment)