## Facts

- Bonnie C. Cord, a 1975 law school graduate, was admitted by examination to the District of Columbia Bar in 1975 and worked as an attorney-adviser for a federal agency.
- Cord sought a statutory “certificate of honest demeanor or good moral character” under Va. Code § 54-60 as a prerequisite to taking the Virginia bar examination.
- The circuit court appointed three local attorneys to investigate Cord’s moral character and fitness.
- The investigators interviewed Cord and contacted former employers, and confirmed that Cord jointly purchased a home in Warren County with Jeffery Blue and that they lived together.
- Two investigators recommended issuing the certificate, finding Cord qualified as to moral character and fitness; one opposed issuance based solely on the unmarried cohabitation.
- At an ore tenus hearing, Cord presented testimony from four neighbors who knew of the cohabitation and attested to her integrity, acceptance in the community, and good moral character.
- The circuit court denied the certificate, reasoning that the “unorthodox” living arrangement would diminish public confidence in the bar.

## Issues

1. Whether the circuit court erred, on the evidentiary record, in denying a certificate of honest demeanor or good moral character based solely on the applicant’s unmarried cohabitation.

## Decision

- The Supreme Court of Virginia reversed.
- The court held the circuit court erred in denying the certificate where the evidence otherwise supported Cord’s honesty, integrity, and fitness, and cohabitation “standing alone” was insufficient.
- The case was remanded with directions to issue the certificate, allowing Cord to sit for the Virginia bar examination.

## Legal Principles

- Under Va. Code § 54-60, denial of a moral-character certificate must rest on evidence meaningfully related to fitness to practice law, not generalized moral disapproval.
- A private, consensual living arrangement, without more, is not probative of dishonesty, lack of integrity, or professional unfitness.
- Predictions about adverse “public perception of the bar,” untethered to evidence of unfitness, are not an adequate basis to deny a moral-character certificate.

## Conclusion

The Supreme Court of Virginia ruled that an applicant’s unmarried cohabitation, by itself and against an otherwise favorable record, does not justify denial of the statutory certificate of honest demeanor or good moral character required to take the Virginia bar examination.


Cord v. Gibb, 254 S.E.2d 71 (Va. 1979)