In re Howes, 52 A.3d 1

respondent, a former AUSA, diverted over $42,000 in witness vouchers to ineligible recipients and to non-witness groups
respondent failed to disclose voucher payments to the court or opposing counsel, and misrepresented disclosures to the court
misconduct spanned 1993–1995 across Card/Moore, Newton Street Crew, and Jones investigations, influencing sentences
OPR found deliberate, extensive misuse of voucher funds and concealment; post-conviction relief proceedings led to sentence reductions for nine felons
Board recommended sanctions ranging from suspension to disbarment; this court ultimately disbars respondent for egregious prosecutorial misconduct
court states it has substantial discretion to fashion sanctions for novel prosecutorial misconduct and adopts disbarment as appropriate

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether disbarment is the appropriate sanction for respondent's misconduct	Bar Counsel: disbarment warranted given extent and deceit	Howes: mitigated factors justify suspension	Disbarment is warranted
Whether mitigating factors outweigh aggravating factors	Bar Counsel: aggravating factors dominate; disbarment appropriate	Howes: mitigating factors (delay, cooperation) lessen severity	Aggravating factors prevail; disbarment upheld
Whether respondent's misrepresentations regarding disclosures violated Brady/Giglio	Brady/Giglio violated; payments were exculpatory material (to jurors)	No substantive Brady/Giglio issue addressed; violations acknowledged in stipulation	Court recognizes Brady/Giglio violations as established by stipulation; supports severe sanction
Whether the public's interest and deterrence justify a harsh sanction for a prosecutor	Disbarment necessary to deter prosecutorial misconduct and protect public trust	Mitigating factors reduce need for extreme sanction	Public protection and deterrence favor disbarment
Whether delay in proceedings mitigates sanction	Delay weighs against severity	Delay sometimes mitigates punishment	delay not sufficient to mitigate to suspension; disbarment remains

In re Cleaver-Bascombe II, 986 A.2d 1191 (D.C. 2010) (disbarment warranted for flagrant dishonesty and misuse of public funds)
In re Cleaver-Bascombe I, 892 A.2d 396 (D.C. 2006) (disbarment for similar voucher misuse; framework for four-factor analysis)
In re Kanu, 5 A.3d 1 (D.C. 2010) (disbarment based on seriousness and public protection)
In re Pelkey, 962 A.2d 268 (D.C. 2008) (flagrant dishonesty; continuing misconduct justifies disbarment)
In re Corizzi, 803 A.2d 438 (D.C. 2002) (prior dishonesty and impact on public trust support disbarment)