Background
Louis Bernardo Antonacci, an attorney licensed in Maryland, was suspended from the practice of law in Virginia for one year and two days after the Virginia State Bar found he violated Virginia Rules of Professional Conduct 1.9 (duties to former clients) and 3.1 (meritorious claims and contentions). Following that suspension, the District of Columbia Court of Appeals imposed corresponding reciprocal discipline on Antonacci.
The Attorney Grievance Commission of Maryland thereafter filed a petition for disciplinary or remedial action against Antonacci based on the out-of-state discipline, and requested that he be immediately suspended from the practice of law in Maryland pursuant to Maryland Rule 19-737(d), which governs reciprocal discipline proceedings. The Court issued an order to show cause, to which Antonacci responded.
The Court’s Holding
After considering the Commission’s petition, its request for immediate suspension, and Antonacci’s response to the show-cause order, the Supreme Court of Maryland ordered that Antonacci be immediately suspended from the practice of law in the State of Maryland pursuant to Rule 19-737(d).
The Court further ordered the Clerk to send notice of the suspension order in accordance with Maryland Rule 19-761, which governs notification procedures in attorney discipline matters. The order was signed by Chief Justice Matthew J. Fader.
Key Takeaways
- Maryland’s reciprocal discipline rule, Rule 19-737(d), authorizes immediate suspension of a Maryland attorney upon a showing that the attorney has been suspended in another jurisdiction.
- Antonacci’s underlying violations — conflict-of-interest duties to former clients (Rule 1.9) and filing non-meritorious claims (Rule 3.1) — resulted in a Virginia suspension that then triggered reciprocal discipline in both D.C. and Maryland.
- An attorney’s response to a show-cause order did not forestall immediate suspension where the predicate out-of-state discipline was established.
Why It Matters
This order illustrates how a single disciplinary finding in one jurisdiction can cascade rapidly across multiple bars. Attorneys practicing in several states face compounding consequences when discipline is imposed in any one of them, as reciprocal-discipline rules in Maryland — and many other states — allow for swift corresponding action without relitigating the underlying misconduct.
For Maryland practitioners, the case is a reminder that Rule 19-737(d) provides a fast-track mechanism for immediate suspension based solely on out-of-state discipline, underscoring the importance of complying with professional conduct rules in every jurisdiction where one holds a license.