Background
The Attorney Grievance Commission of Maryland filed a petition for disciplinary or remedial action against Louis Bernardo Antonacci, along with a request for immediate suspension, pursuant to Maryland Rules 19-721(a)(2) and 19-737. The Commission’s petition was premised on violations of Virginia Rules of Professional Conduct 1.9(c)(1), 1.9(c)(2), and 3.1 — rules governing duties to former clients and prohibitions on frivolous claims.
The Supreme Court of Maryland had already imposed a temporary suspension on Antonacci on May 27, 2026, while the disciplinary matter was pending. The Court subsequently issued an order to show cause, and both parties responded before the Court entered its final disciplinary order.
The Court’s Holding
The Supreme Court of Maryland suspended Louis Bernardo Antonacci from the practice of law in Maryland for one year and two days, effective nunc pro tunc to the date of his temporary suspension on May 27, 2026. The Court found that Antonacci had violated Virginia Rules of Professional Conduct 1.9(c)(1) and 1.9(c)(2), which prohibit an attorney from using or revealing confidential information relating to a former client’s representation, as well as Rule 3.1, which bars lawyers from bringing or asserting frivolous claims or defenses.
The Court further ordered that before the suspension may be lifted at the conclusion of the suspension period, Antonacci must affirmatively demonstrate his fitness to resume the practice of law to the Court’s satisfaction. The Clerk was directed to provide notice of the order in accordance with Maryland Rule 19-761.
Key Takeaways
- Antonacci was suspended for one year and two days for violating Virginia Rules of Professional Conduct 1.9(c)(1), 1.9(c)(2) (misuse of former-client confidences), and 3.1 (frivolous litigation).
- The suspension runs nunc pro tunc from May 27, 2026, the date of his earlier temporary suspension, meaning the time already served counts toward the disciplinary period.
- Reinstatement is not automatic — Antonacci must separately demonstrate fitness to practice before the suspension can be lifted.
Why It Matters
This case illustrates that Maryland will impose reciprocal or related discipline based on violations of another state’s professional conduct rules, and that misuse of former-client confidential information combined with frivolous litigation can result in a suspension with a fitness-to-practice reinstatement requirement. The nunc pro tunc effective date reflects the Court’s practice of crediting time served under a temporary suspension against the final disciplinary term.
The mandatory fitness showing before reinstatement adds a meaningful hurdle beyond simply waiting out the suspension period, signaling the Court’s concern about the underlying conduct and Antonacci’s readiness to return to ethical practice.