In re Ahmed M. Hamid-Ahmed, 2018 VT 113

Summary

The Vermont Supreme Court affirmed the Board of Bar Examiners’ denial of Ahmed M. Hamid-Ahmed’s application to take the Vermont bar examination. The court held that the Rule 8(c)(4) curing provision applies to applicants with qualifying foreign law degrees who satisfy the other Rule 8(b) requirements, and rejected the applicant’s due process argument as harmless.

Holdings

1. Rule 8(c)(4)'s curing provision applies only to applicants who satisfy the other requirements of Rule 8(b), including having a qualifying foreign law degree and having been admitted to and maintained good standing in another bar. An LLM alone does not make an applicant eligible to take the Vermont bar examination.
2. Any failure by the Board to provide express notice of the appellate procedure was harmless because the applicant timely appealed and received a merits judgment; the alleged error therefore did not warrant reversal.

Questions Presented

1. Whether an applicant who lacks a qualifying foreign law degree and admission to another bar may use Vermont Rule of Admission to the Bar 8(c)(4)'s curing provision solely by obtaining an LLM degree.
2. Whether the Board violated the applicant's due process rights by denying his application without expressly notifying him of the procedure for appealing to the Vermont Supreme Court.

Disposition

affirmed