In Re Rigas, 9 A.3d 494

Rigas pled guilty in SDNY to one count of 47 U.S.C. § 220(e) for willfully making a false entry or neglecting to make full entries.
Rigas reported the conviction to Bar Counsel on March 10, 2006; the court suspended him on August 3, 2006 and directed a Board proceeding to assess moral turpitude.
The Board initially found no moral turpitude per se and referred the matter to a Hearing Committee to determine if facts showed moral turpitude.
Bar Counsel filed a Specification of Charges in November 2008 alleging violations of DC Bar Rule XI and Rules 8.4(b) and 8.4(c); no allegation of moral turpitude was made.
In November 2008, the parties filed a petition for negotiated discipline admitting ethical rule violations and proposing a one-year suspension nunc pro tunc to January 25, 2007.
The Board adopted guidelines in March 2009 to govern negotiated discipline for criminal convictions potentially involving moral turpitude.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether negotiated discipline may resolve a criminal conviction potentially involving moral turpitude.	Rigas and Bar Counsel supported negotiated discipline.	N/A	Yes; negotiated discipline is permissible where no moral turpitude is proven.
Whether the sanction of one-year suspension is appropriate.	One-year suspension is warranted given the conduct.	N/A	Yes; one-year suspension nunc pro tunc to filing date.

In re Delaney, 697 A.2d 1212 (D.C.1997) (deferential review of Board recommendations in discipline)
In re Brown, 851 A.2d 1278 (D.C.2004) (per curiam; applicable one-year suspension contexts)
In re Belardi, 891 A.2d 224 (D.C.2006) (one-year suspension for false statements to a government agency)
In re Cerroni, 683 A.2d 150 (D.C.1996) (one-year suspension for false statements to government agencies)
In re Susman, 876 A.2d 637 (D.C.2005) (moral turpitude based on deliberate falsification in ERISA context)
In re Johnson, 984 A.2d 176 (D.C.2009) (note on departure from norm in novelty of issue)