Background
Gregory Krasovsky, a suspended member of the District of Columbia Bar, faced disciplinary proceedings arising from violations of D.C. Rules of Professional Conduct 3.4(c), 8.1(b), and 8.4(d), as well as D.C. Bar Rule XI, § 2(b)(3).
The Board on Professional Responsibility recommended suspending Krasovsky for thirty days and conditioning his reinstatement on proof that he is fit to practice law. Krasovsky filed no exceptions to the Board’s report and recommendation.
The Court’s Holding
The District of Columbia Court of Appeals accepted the Board’s recommendation, concluding that the proposed sanction was reasonable and appropriate for the violations. The court noted that, under D.C. Bar Rule XI, § 9(h)(2), it will impose the Board’s recommended discipline when no exceptions are filed after the time for doing so expires.
The court suspended Krasovsky for thirty days and held that he may be reinstated after serving that period only if he demonstrates fitness to practice law. Without such a showing, his suspension will remain in effect indefinitely.
Key Takeaways
- A lawyer’s failure to file exceptions to a disciplinary recommendation triggers an especially deferential review by the court.
- Krasovsky received a thirty-day suspension for violations involving noncompliance with professional and disciplinary obligations.
- Completion of the thirty-day period does not automatically restore Krasovsky’s license; reinstatement requires proof of fitness.
Why It Matters
The decision underscores that a nominally short disciplinary suspension can continue indefinitely when reinstatement is conditioned on fitness. It also illustrates the practical consequence of failing to challenge the Board’s recommendation: the court ordinarily will impose the recommended discipline if it finds the sanction reasonable and appropriate.