Background
The Attorney Grievance Commission of Maryland brought disciplinary proceedings against Christopher Michael Finke, a Maryland attorney, for violations of multiple Rules of Professional Conduct. The parties reached agreement and filed a joint petition proposing a six-month suspension stayed in favor of one year of probation, subject to the terms and conditions of a negotiated probation agreement.
The violations at issue spanned several core professional obligations. Finke was found to have violated Rules 19-301.1 (competence), 19-301.3 (diligence), 19-301.4(a) and (b) (communication with clients), 19-303.2 (expediting litigation), and 19-308.4(a), (c), and (d) (misconduct, including dishonest or fraudulent conduct and conduct prejudicial to the administration of justice).
The Court’s Holding
A majority of the Supreme Court of Maryland accepted the joint petition and ordered that Finke be suspended from the practice of law in Maryland for six months. The court stayed that suspension for one year, placing Finke on probation under the terms and conditions set forth in the parties’ probation agreement.
The court further ordered Finke to pay $1,196.40 to the Attorney Grievance Commission within 90 days of the order as reimbursement for costs associated with the disciplinary proceedings. The order was signed by Chief Justice Matthew J. Fader.
Key Takeaways
- Finke received a six-month suspension stayed for one year of probation, meaning he may continue practicing law provided he complies with all probation conditions.
- The violations included failures of competence, diligence, and client communication, as well as misconduct involving dishonesty and conduct prejudicial to the administration of justice.
- Finke must reimburse the Attorney Grievance Commission $1,196.40 in costs within 90 days.
- The outcome resulted from a joint petition — a negotiated resolution between the Commission and the respondent attorney.
Why It Matters
This case illustrates the Maryland Supreme Court’s willingness to accept negotiated, stayed suspensions in attorney discipline matters when the parties jointly propose structured probation as an alternative to active suspension. The stayed suspension preserves the respondent’s ability to practice while imposing accountability through probation conditions, balancing public protection with rehabilitation.
The breadth of rule violations — spanning competence, diligence, communication, and misconduct including dishonesty — signals that even in negotiated resolutions, the court scrutinizes the full scope of an attorney’s conduct. Maryland practitioners should note that Rule 19-308.4(c) and (d) violations, involving dishonest conduct and conduct prejudicial to the administration of justice, carry particular weight in disciplinary proceedings.