In re Rodriguez-Quesada, 122 A.3d 913

Juan Lorenzo Rodriguez-Quesada, D.C. Bar member since 2005, practiced immigration law (2003–2008) and handled ~400–500 cases; disciplinary proceeding concerned four client matters (Abarca, Koerner-Goodrich, Belhmira, Ramirez).
Board on Professional Responsibility and the Hearing Committee found repeated failures: incompetence, lack of diligence, poor communication, failure to return files/unearned fees, and in one matter a knowing false statement to a tribunal.
Specific client problems: missed or defective filings, failure to obtain or transmit notices, charging/retaining fees without performing work, false statement to immigration judge re: filing, and long periods of non‑communication.
Board concluded violations of multiple Rules of Professional Conduct (competence, diligence, communication, candor to tribunal, honesty, and return of files/fees) and recommended a two‑year suspension with restitution to three clients (not Abarca) as reinstatement condition.
This court accepted the Board’s factual findings and rule‑violation conclusions, but imposed a two‑year suspension conditioned on (1) a showing of fitness and (2) restitution to all four affected clients (including Abarca).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board’s factual findings are supported	Bar (Board) argued record supports findings of neglect, incompetence, dishonesty	Rodriguez asserted factual disputes and pointed to some successful filings and lack of prejudice	Court accepted Board/Hearing Committee factual findings as supported by substantial evidence
Whether specific Rule violations were proven (competence, diligence, communication, candor, return of files/fees)	Bar: clear and convincing evidence of multiple rule breaches across four matters	Rodriguez contended some work succeeded, prejudice absent, and volume/overload excused conduct	Court held each specified Rule violation proven and accepted Board’s conclusions
Appropriate sanction (suspension length; fitness condition)	Bar supported two‑year suspension and fitness + restitution to all clients	Rodriguez sought brief suspension, cited no prior discipline, no lasting client injury, and cessation of immigration practice	Court imposed two‑year suspension and added reinstatement conditions: showing of fitness and restitution to all four clients
Restitution to Abarca	Bar urged restitution to all harmed clients including Abarca	Board had declined restitution to Abarca (citing partial fee paid, some work done, small‑claims loss) ; Rodriguez opposed	Court required restitution to Abarca as condition of reinstatement, finding partial restitution appropriate and Board’s reasons insufficient to deny it

In re Brown, 112 A.3d 913 (D.C. 2015) (deference to Board/Hearing Committee factual findings)
In re Yelverton, 105 A.3d 413 (D.C. 2014) (court reviews Board legal conclusions de novo)
In re Shelnutt, 719 A.2d 96 (D.C. 1998) (prejudice not required element of neglect; sanction focus is malfeasance)
In re Vohra, 68 A.3d 766 (D.C. 2013) (standard of deference to Board sanction recommendations)
In re Kanu, 5 A.3d 1 (D.C. 2010) (court’s responsibility for sanctioning discipline)
In re Mintz, 626 A.2d 926 (D.C. 1993) (two‑year suspension with fitness requirement for gross/persistent negligence)
In re Cater, 887 A.2d 1 (D.C. 2005) (standard for conditioning reinstatement on proof of rehabilitation)
In re Ukwu, 926 A.2d 1106 (D.C. 2007) (two‑year suspension with fitness requirement for pervasive neglect and dishonesty)
In re Omwenga, 49 A.3d 1235 (D.C. 2012) (deferring precise restitution amounts until reinstatement stage)