Attorney Grievance v. Bonner


Attorney Grievance Commission of Maryland v. Keith M. Bonner, Miscellaneous Docket AG No. 51, September Term, 2020, Opinion by Booth, J. ATTORNEY DISCIPLINE – SANCTIONS – DISBARMENT Respondent Keith M. Bonner violated the District of Columbia Rules of Professional Conduct (“D.C. Rules”) 8.4 (a), (b), and (c) by misappropriating funds from his law firm over a period of several years and making numerous knowing and intentional misrepresentations to principals and employees at his law firm to conceal the misconduct. Considering the nature of Mr. Bonner’s misconduct and the various mitigating and aggravating factors present here, the Court of Appeals concluded that disbarment is the appropriate sanction. Circuit Court for Montgomery County Case No.: 484242-V Argued: November 8, 2021 IN THE COURT OF APPEALS OF MARYLAND Misc. Docket AG No. 51 September Term, 2020 ATTORNEY GRIEVANCE COMMISSION OF MARYLAND v. KEITH M. BONNER Getty, C.J. *McDonald Watts Hotten Booth Biran Gould, JJ. Opinion by Booth, J. Filed: March 3, 2022 *McDonald, J. now retired, participated in the hearing and conference of this case while an active member of this Court; after being recalled Pursuant to Maryland Uniform Electronic Legal Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic. Pursuant to MD Constitution, Article IV, Section 3A, he also participated in the decision and 2022-03-03 14:27-05:00 adoption of this opinion. Suzanne C. Johnson, Clerk “How much more grievous are the consequences of anger than the causes of it.” Aurelius, Marcus. 2014. Meditations. Translated by Martin Hammond. Penguin Pocket Hardbacks. London, England: Penguin Classics. In this attorney grievance proceeding, we must determine the sanction to impose for an attorney’s misconduct involving misappropriation of funds from his law firm in which he was a founding partner and member for decades. Respondent Keith Bonner freely admits to the facts of the misconduct and resulting violations of the professional ethical rules applicable to his misconduct. The case he presents to this Court in his defense relates almost exclusively to the mitigating factors that this Court should consider when imposing a sanction (in addition to one aggravating factor to which he excepts). Specifically, he asserts that he has shown sufficient mitigating circumstances to justify a deviation from our case law, which generally imposes the sanction of disbarment where an attorney’s misconduct involves theft or intentional misappropriation of funds. Prior to our consideration of the sanction, as we always do, we shall describe the procedural history, as well as the hearing judge’s findings of fact and conclusions of law. We shall then discuss our case law concerning sanctions where intentional misconduct involves theft or misappropriation, as well as Mr. Bonner’s argument that we should consider the emotional problems that he experienced during the period of his misconduct—anger, frustration, and feelings of entitlement and self-righteousness—as a mitigating factor in this case, along with the other mitigating factors that are present here, which he asserts warrant the imposition of a sanction less than disbarment. On November 30, 2020, the Attorney Grievance Commission of Maryland …

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