In re Nalls, 145 So. 3d 1011

Respondent Clarence T. Nalls, Jr. is a Louisiana attorney who was previously suspended for one year and one day in a fully deferred disposition (2006) and began a two-year probation; the court later revoked probation and made the suspension executory in 2009.
Respondent has not sought reinstatement and remains suspended as of the current proceedings.
In the present disciplinary matter, formal charges were filed in 2012 alleging unauthorized practice after suspension and misappropriation/mishandling of funds belonging to a client, Wade Garner, and a separate client, Linder Shields.
Respondent allegedly continued to represent Garner post-suspension, engaged in correspondence and court activity, and failed to provide Garner a file or an accounting of funds.
Respondent accepted a $2,500 advance fee from Shields after suspension and did not inform her of his suspension, instead indicating other attorneys would appear for her.
The Hearing Committee found multiple rule violations (1.15, 1.16, 5.5, 8.4(c), and related Supreme Court Rule XIX) and negligently violated duties to clients; the Board recommended disbarment with restitution and an accounting.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Nalls engage in unauthorized practice after suspension?	ODC argues Yes; continued practice after suspension.	Nalls contends the evidence does not prove clear, convincing unauthorized practice.	Disbarment warranted; respondent knowingly practiced after suspension.
Did Nalls mishandle and fail to account for client funds?	ODC asserts substantial mismanagement and conversion of funds.	Nalls disputes accounting conclusions and scope of mismanagement.	Respondent violated 1.15(d), 1.16(d), and 8.4(c); ordered accounting and restitution; sanctions support disbarment.
Did respondent fail to inform clients of his suspension and mislead them about representation?	ODC contends did not notify Garner/Shields and improperly accepted fees post-suspension.	Nalls argues conduct was not intentionally deceptive to a degree establishing disbarment.	Knowingly disregarded suspension; deceitful conduct supports disbarment.
Is disbarment the appropriate sanction given the misconduct?	ODC seeks disbarment; board recognized serious misconduct with aggravating factors.	Nalls urged lesser discipline or no discipline; arguments rejected by board and court.	Disbarment affirmed as baseline sanction given egregious misconduct and aggravating factors.

In re: Jackson, 843 So.2d 1079 (La. 2003) (unauthorized practice after suspension; consequences depend on state of mind)
In re: Lindsay, 976 So.2d 1261 (La. 2008) (conscious flouting of court authority leads to disbarment)
In re: Jones, 747 So.2d 1081 (La. 1999) (disbarment for repeated unauthorized practice after suspension)
In re: Banks, 18 So.3d 57 (La. 2009) (original-jurisdiction review; manifest-error standard applies to findings)
Louisiana State Bar Ass'n v. Reis, 513 So.2d 1173 (La. 1987) (discipline aims to protect public, integrity; baseline considerations)
Louisiana State Bar Ass'n v. Whittington, 459 So.2d 520 (La. 1984) (factors for aggravation/mitigation in imposing discipline)