In re Brown

Summary

The South Carolina Supreme Court imposed a two-year definite suspension and disbarment on an attorney in two disciplinary matters, with the sanctions running concurrently. The misconduct involved unauthorized real estate closings, improper signing, witnessing, and notarization of documents, fraudulent HUD-1 settlement statements, undisclosed property flips, false occupancy representations, and conflicts of interest. The court held that it had authority to discipline the attorney for serious professional-related misconduct occurring before his admission to the South Carolina Bar.

Holdings

1. The Supreme Court of South Carolina has authority to discipline an attorney for misconduct occurring before the attorney's admission to practice law when the misconduct is related to the legal profession and implicates protection of the public and public trust in the legal system.
2. The Court accepted both Agreements for Discipline by Consent and imposed a definite two-year suspension and disbarment, with the sanctions running concurrently.

Questions Presented

1. Whether the Supreme Court of South Carolina may discipline an attorney for misconduct that occurred before the attorney's admission to practice law in South Carolina.
2. Whether the two Agreements for Discipline by Consent should be accepted and the agreed misconduct sanctioned by a two-year definite suspension and disbarment running concurrently.

Disposition

other