In re Brian D. Geno

Summary

The District of Columbia Court of Appeals publicly censured attorney Brian D. Geno for violating D.C. Rules of Professional Conduct 1.3(c) and 1.4(a). Geno failed to adequately notify an immigration client of a hearing, appeared at the wrong courthouse, and took no effective remedial action after an in absentia deportation order was entered.

Holdings

1. Respondent violated Rules 1.3(c) and 1.4(a) by failing to notify his client adequately of the immigration hearing, failing to attend the correct hearing, and failing to take remedial action after the in absentia deportation order was entered.
2. Public censure was warranted because respondent failed to accept responsibility for conduct that caused an in absentia deportation order and created a serious risk of deportation, while the isolated nature of the misconduct made suspension unduly punitive.

Questions Presented

1. Whether respondent violated D.C. Rules of Professional Conduct 1.3(c) and 1.4(a) by failing to provide adequate diligence and communication in connection with his client's immigration hearing.
2. Whether public censure, rather than an informal admonition or suspension, was the appropriate sanction for respondent's misconduct.

Disposition

other