In re: Lillian Annette Ramos Bahamundi
2025 TSPR 43
Supreme Court of Puerto Rico2025Background
- Lillian Annette Ramos Bahamundi, an attorney and notary, was admitted to practice law in Puerto Rico in 1990 and as a notary in 1991.
- Two separate clients (Luz C. Ramos Santos and Abigail Rodríguez Torres) filed professional conduct complaints against her, citing failures in legal representation, lack of communication, dishonesty, and mishandling of client funds and documents.
- Ramos Bahamundi failed to file a client's damage lawsuit after accepting fees, misled the client about case status, and retained client files and funds longer than appropriate.
- In a separate matter, she delayed actions in another client’s case, failed to comply with court orders, and was not diligent in her notarial duties.
- The Supreme Court of Puerto Rico consolidated both disciplinary matters, conducted investigations, and both the Special Commissioner and the Office of the Solicitor General found clear violations of various Canons of Professional Ethics.
- Ramos Bahamundi had a prior two-year suspension for similar ethical breaches.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to act diligently and competently | Lawyer took fees, didn't file case, misled client | Claimed case lacked merit, tried to contact client | Violated Canons 18, 35, 38; sanction warranted |
| Failure to communicate and inform client | Defendant didn't respond to inquiries, hid case status | Claimed communication existed, but acknowledged delays | Violated Canon 19 |
| Mishandling client funds and documents | Delayed return of funds, failed to return documents | Eventually returned fees, but not timely or completely | Violated Canons 20, 23 |
| Failure to comply with court orders and notarial duties | Failed to act on orders, delayed notarial process | No substantive defense presented, missed deadlines | Violated Canons 9, 12, 18, 19 |
Key Cases Cited
- In re Navedo Dávila, 203 DPR 300 (Puerto Rico 2019) (on the importance of ethical legal practice)
- In re Cruz Liciaga, 198 DPR 828 (Puerto Rico 2017) (affirming the mandatory nature of professional standards)
- In re Franco Rivera, 197 DPR 628 (Puerto Rico 2017) (disciplinary measures for attorney misconduct)
- In re Cay Espinosa, 213 DPR 813 (Puerto Rico 2024) (attorney duties of respect toward tribunals)
- In re Sánchez Rivoleda, 213 DPR 765 (Puerto Rico 2024) (compliance with court orders as part of ethical duty)