People v. Snyder

Summary

The Colorado Presiding Disciplinary Judge found that Albert R. Snyder neglected an immigration representation, failed to communicate with his clients, failed to provide fee and financial records, and practiced law while administratively suspended. The court concluded that Snyder violated eight Colorado Rules of Professional Conduct and imposed a three-year suspension, along with related winding-up, affidavit, and cost obligations.

Holdings

1. Snyder violated Colo. RPC 1.3 by failing to act with reasonable diligence and promptness, including allowing the clients' I-130 petition to expire.
2. Snyder violated Colo. RPC 1.4(b) and 1.4(a)(4) by failing to explain his change in immigration strategy and by failing to respond promptly to reasonable requests for information and an accounting.
3. Snyder violated Colo. RPC 1.5(b), 1.15A(b), and 1.15D by failing to communicate the basis of his fees in writing, failing to provide an accounting or deliver client funds or property upon request, and failing to maintain required financial records.
4. Snyder violated Colo. RPC 3.4(c) and 5.5(a)(1) by failing to notify the clients of his administrative suspension, failing to withdraw, and practicing law without authorization while suspended.
5. A three-year suspension was warranted for Snyder's knowing and repeated misconduct, considering the duties violated, actual and potential injury, four aggravating factors, absence of mitigation, and comparable Colorado disciplinary decisions.

Questions Presented

1. Whether Snyder violated the Colorado Rules of Professional Conduct by neglecting the clients' immigration matter and failing to communicate material information.
2. Whether Snyder violated the rules governing fees, client funds, and financial records by failing to provide a written fee agreement, accounting, and required records.
3. Whether Snyder violated disciplinary rules by continuing to represent the clients and practicing law while administratively suspended.
4. What sanction was appropriate in light of the misconduct, mental state, injury or potential injury, aggravating factors, mitigating factors, and comparable Colorado disciplinary cases.

Disposition

other