In re Sherryl V.R.S. Goffer a/k/a Sherryl Snodgrass Caffey, 121 A.3d 1252

In uncontested reciprocal discipline, identical discipline should be imposed with minimal review.
Alabama Disciplinary Board found Caffey engaged in serious misconduct and disbarred her on August 21, 2009.
Caffey failed to report her Alabama disbarment to the DC Bar and later claimed fraud in Alabama records.
On January 3, 2014 Bar Counsel filed a certified Alabama order; DC suspended Caffey and sought disbarment identical to Alabama.
The Board recommended a ninety-day suspension with a fitness requirement, but this was treated as contested rather than identical discipline.
Caffey had been administratively suspended in DC since 1987 for nonpayment of dues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Should identical discipline be automatic in uncontested reciprocal cases?	Identical discipline should be imposed with minimal review.	Board allowed contested-review elements, which was improper for uncontested cases.	Yes; impose identical discipline with limited review.
Did the Board's analysis treat the matter as contested, undermining automaticity?	Board erred by applying contest-like review in an uncontested case.	Board sought to balance considerations, but the matter remained uncontested.	The matter should have been treated as uncontested with automatic discipline.
Whether there was an obvious miscarriage of justice justifying non-identical discipline?	No rare miscarriage; automatic discipline appropriate.	Differences between Alabama and DC rules could justify non-identical sanction.	No miscarriage; identical discipline warranted.
Whether Caffey's notice and opportunity to be heard support identical discipline?	Notice and opportunity to be heard in Alabama support automatic discipline.	Nonparticipation could warrant departure under limited review.	Notwithstanding nonparticipation, identical discipline applies.

In re Childress, 811 A.2d 805 (D.C. 2002) (identical discipline with minimal review in uncontested cases)
In re Spann, 711 A.2d 1262 (D.C. 1998) (rarely present obvious miscarriage of justice in uncontested cases)
In re Drager, 846 A.2d 992 (D.C. 2004) (uncontested case where respondent did not contest reciprocal discipline)
In re Gruber, 889 A.2d 991 (D.C. 2005) (reciprocal disbarment in uncontested proceeding where notice and opportunity to be heard)
In re Berger (Awuah), 737 A.2d 1033 (D.C. 1999) (reciprocal discipline with fitness requirement; contest not required)
In re Jacoby, 945 A.2d 1193 (D.C. 2008) (limited review in reciprocal discipline)