In Re Allen, 27 A.3d 1178

Claude A. Allen, a DC bar member since 1992, was charged in Maryland with misdemeanor theft by fraud for a three-event scheme at Target stores in 2005–2006.
He pled guilty in Maryland to misdemeanor theft of property under $500 and was sentenced to probation, community service, and fines totaling $625.
Bar Counsel initiated DC disciplinary proceedings; the Board found no moral turpitude and recommended a one-year suspension plus restitution as a reinstatement condition.
The Hearing Committee found the conduct violated Rules 8.4(b) and 8.4(c) but not moral turpitude, and recommended 90 days’ suspension; Bar Counsel sought disbarment, or at least more severe discipline.
The Board adopted the Committee’s facts, found moral turpitude not proven, but recommended a one-year suspension with restitution as a condition of reinstatement.
The DC Court of Appeals reviewed de novo whether the crime involved moral turpitude and ultimately imposed a one-year suspension with restitution as a reinstatement condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the theft convictions involved moral turpitude	Bar Counsel contends the acts were intentional dishonesty for personal gain.	Allen argues stress and exceptional circumstances negate intentional personal-gain dishonesty.	No moral turpitude found; discipline limited to one-year suspension.
Whether the record shows personal gain as the motive for the thefts	Bar Counsel asserts intentional personal gain from thefts.	Allen presents evidence of stress/mental condition undermining personal-gain motive.	Burden not met by clear and convincing evidence; motive found to be stress-related.
What sanction is appropriate given the conduct absent moral turpitude	Disbarment or at least longer suspension is warranted.	One-year suspension with restitution is appropriate.	One-year suspension with restitution required upon reinstatement.

In re Spiridon, 755 A.2d 463 (D.C. 2000) (stress and exceptional circumstances can preclude moral turpitude)
In re Sims, 844 A.2d 353 (D.C. 2004) (psychiatric evidence may negate intentional dishonesty for personal gain)
In re Sneed, 673 A.2d 591 (D.C. 1996) (disbarment for large-scale fraud scheme when proven)
In re McBride, 602 A.2d 626 (D.C. 1992) (misdemeanor not per se moral turpitude; context matters)
In re Colson, 412 A.2d 1160 (D.C. 1979) (distinction between inherent moral turpitude and case-specific test)
In re Kent, 467 A.2d 982 (D.C. 1983) (extreme distress can negate moral turpitude)
In re Cleaver-Bascombe, 986 A.2d 1191 (D.C. 2010) (board findings reviewed for substantial evidence; de novo ultimate conclusions)
In re Berryman, 764 A.2d 760 (D.C. 2000) (standard of review for Board recommendations; de novo on ultimate conclusions)
In re Anderson, 778 A.2d 330 (D.C. 2001) (clear and convincing standard governs disciplinary proofs)