Background
Spencer Michael Hecht, a Maryland attorney admitted to the bar in 2002 whose practice had shifted primarily to family law, faced disciplinary proceedings arising from complaints by three separate clients. Bar Counsel filed a Petition for Disciplinary or Remedial Action in January 2025, later amended, charging violations of numerous Maryland Attorneys’ Rules of Professional Conduct. A hearing judge in the Circuit Court for Montgomery County conducted a multi-day evidentiary hearing in June and July 2025, found Hecht to be a “less than credible witness” whose testimony was “marked by inconsistencies, evasion, deflection, and deception,” and issued findings of fact and conclusions of law in September 2025.
The misconduct spanned three client matters. In the Juarez matter, Hecht lost a signed post-nuptial agreement a client had delivered to his unattended front desk, concealed that loss from the client for months while the client repeatedly asked for a copy, dismissed the underlying divorce action despite knowing the client’s willingness to dismiss was contingent on the agreement being in place, and refused to refund the $2,400 drafting fee for over a year. In the Greiner matter, Hecht repeatedly told his divorce client he was preparing a motion to compel discovery he never intended to file, filed an expert witness designation with the trial court falsely representing that the expert was preparing a report when he knew the expert was not, failed to communicate adequately despite persistent client requests, and—after withdrawing on the eve of trial—signed an affidavit for opposing counsel that was harmful to his former client and helped defeat her successor counsel’s motion for relief. In the Bonnell matter, Hecht charged $7,500 to a former client’s credit card without authorization after the client terminated the representation.
The hearing judge concluded that Hecht had violated MARPC 1.1 (Competence), 1.3 (Diligence), 1.4(a) and (b) (Communication), 1.5(a) (Fees), 1.9(c) (Duties to Former Clients), 1.15(a) (Safekeeping Property), 8.1(b) (Bar Admission and Disciplinary Matters), and 8.4(a) and (c), but did not find violations of MARPC 1.16(d), 8.4(d), or Maryland Rule 19-407. The Supreme Court heard oral argument on December 5, 2025.
The Court’s Holding
The Supreme Court of Maryland disbarred Hecht from the practice of law in Maryland. The Court applied the standard established in Attorney Grievance Comm’n v. Vanderlinde, 364 Md. 376, 773 A.2d 463 (2001), under which an attorney must demonstrate compelling extenuating circumstances to warrant any sanction less than disbarment when the misconduct involves intentional dishonesty. The Court reaffirmed its prior holding in Attorney Grievance Comm’n v. Collins, 477 Md. 482, 530, 533–34, 270 A.3d 917, 946, 948 (2022), that the Vanderlinde standard may be invoked based on the nature, circumstances, and consequences of the intentionally dishonest conduct at issue.
Finding that the Vanderlinde standard applied to Hecht’s conduct and that no compelling extenuating circumstances were present, the Court concluded that disbarment was the appropriate sanction. The pattern of intentional dishonesty—concealing the loss of a critical legal document, making false representations to a tribunal about expert witness preparation, executing an affidavit adverse to a former client for the benefit of that client’s opponent, and making an unauthorized credit card charge—left no room for a lesser sanction.
Key Takeaways
- Under Maryland’s Vanderlinde standard, intentional dishonesty creates a strong presumption of disbarment; the burden falls on the attorney to demonstrate compelling extenuating circumstances, and the absence of such circumstances makes disbarment mandatory.
- Signing an affidavit for opposing counsel that harms a former client violates MARPC 1.9(c) governing duties to former clients and weighs heavily toward disbarment when combined with other dishonest conduct.
- Filing a court document—such as an expert witness designation—that the attorney knows contains a material falsehood constitutes the kind of intentional dishonesty that triggers the Vanderlinde framework regardless of other, separately sanctionable misconduct in the same proceeding.
- An unauthorized credit card charge against a former client, even when rationalized as covering a claimed outstanding balance, constitutes a theft-like act of intentional dishonesty that compounds the overall disciplinary calculus.
Why It Matters
This decision reinforces Maryland’s firm line on intentional dishonesty in attorney discipline. By reaffirming Collins and Vanderlinde together, the Supreme Court of Maryland signals that courts need not wait for a single egregious act; a pattern of deliberate deceptions across multiple client matters—each individually serious—will be assessed holistically, and the combined picture of intentional dishonesty will trigger the disbarment presumption just as forcefully as a single act of fraud.
For practitioners, the case is a cautionary illustration of how misconduct that might seem compartmentalized—a lost document here, a false court filing there, an unauthorized charge elsewhere—can aggregate into a disbarment record. The Court’s emphasis on Hecht’s shifting, incredible testimony also underscores that a respondent-attorney’s credibility before the hearing judge is itself a significant factor: an attorney who attempts to deflect, minimize, or recast misconduct throughout disciplinary proceedings only deepens the court’s concern about character and fitness.