In re Christopher H. Reed

Summary

The District of Columbia Court of Appeals imposed reciprocal discipline on Christopher H. Reed based on a three-year suspension ordered by the Supreme Court of Arizona. The court suspended Reed from practice in the District of Columbia for three years and required proof of rehabilitation for reinstatement. It declined to impose Arizona's additional restitution and post-reinstatement probation provisions as independent sanctions.

Holdings

1. The Court imposed reciprocal discipline consisting of a three-year suspension from practice in the District of Columbia and a requirement that Reed prove rehabilitation as a condition of reinstatement.
2. The Court declined to impose disbarment because the Arizona proceeding did not find that Reed's misappropriations were intentional or reckless, and the District of Columbia could not independently reevaluate the evidence to establish misconduct not found by the disciplining jurisdiction.
3. The Court did not impose Arizona's restitution and post-reinstatement probation provisions as independent District of Columbia sanctions, although Reed's compliance with those conditions could be considered in a future fitness or reinstatement proceeding.

Questions Presented

1. Whether the District of Columbia should impose reciprocal discipline identical in material respects to the three-year suspension imposed by the Supreme Court of Arizona.
2. Whether the record established an exception warranting substantially different discipline, specifically disbarment, based on intentional or reckless misappropriation.
3. Whether the District of Columbia should adopt the Arizona order's restitution and post-reinstatement probation provisions.

Disposition

other