Background
The Attorney Grievance Commission of Maryland filed a petition for disciplinary or remedial action against attorney Steve Larson-Jackson after he was temporarily suspended from the practice of law in the District of Columbia, where disciplinary proceedings against him remained pending before the D.C. Court of Appeals. Under Maryland’s reciprocal discipline framework, the Commission sought Larson-Jackson’s immediate suspension in Maryland as well.
The Supreme Court of Maryland issued an order to show cause directing Larson-Jackson to explain why he should not be immediately suspended in Maryland pending final resolution of the D.C. proceedings. Larson-Jackson filed a response to the show cause order, which the Court considered alongside the Commission’s petition.
The Court’s Holding
Finding no sufficient basis in Larson-Jackson’s response to forestall reciprocal action, the Supreme Court of Maryland ordered his immediate suspension from the practice of law in the State of Maryland pursuant to Maryland Rule 19-737(d). The suspension is effective pending the final disposition of the disciplinary proceedings in the District of Columbia.
The Court further directed the Clerk to provide notice of the order in accordance with Maryland Rule 19-761, which governs notification obligations when an attorney is suspended or disbarred.
Key Takeaways
- Maryland’s reciprocal discipline rule (Md. Rule 19-737(d)) authorizes the Supreme Court of Maryland to immediately suspend an attorney who has been temporarily suspended in another jurisdiction while disciplinary proceedings there remain pending.
- An attorney subject to an out-of-state temporary suspension bears the burden of showing cause why Maryland should not impose a corresponding suspension; Larson-Jackson’s response was insufficient to avoid that result.
- The suspension takes effect immediately and continues until the D.C. Court of Appeals issues a final disposition in its disciplinary matter.
Why It Matters
This order illustrates the reach of Maryland’s reciprocal discipline framework: a temporary, non-final suspension in a sister jurisdiction is sufficient to trigger an immediate suspension in Maryland, protecting the public even before the underlying disciplinary case is resolved. Attorneys who are suspended or face serious charges in any jurisdiction where they are licensed should anticipate prompt parallel action in every other state where they hold a bar license.
The case also underscores the limited scope of the show-cause process — respondents must present concrete grounds (such as a due-process infirmity in the foreign proceeding or proof the underlying conduct would not constitute misconduct in Maryland) to avoid automatic reciprocal suspension. A general response contesting the merits of the foreign proceeding is unlikely to suffice.