## Facts

- M.A.R. applied for admission to The Florida Bar in 1995.
- After formal specifications and an evidentiary hearing, the Florida Board of Bar Examiners found multiple instances of misconduct and recommended denial of admission at that time for lack of character and fitness.
- The Board found M.A.R. willfully violated a child-support court order and was at least $17,000 in arrears; alleged lack of harm to the children and an asserted informal arrangement with his ex-wife did not excuse disobedience of the order.
- The Board found M.A.R. failed to timely file and pay federal income taxes for 1987–1990.
- The Board found M.A.R. wrote over forty bad checks since 1995, including one issued about a week before the formal hearing.
- The Board found M.A.R. made a false oath in submissions by signing documents that were notarized before being completed, and gave explanations the Board found not credible.
- The Board found M.A.R. omitted a DUI arrest and probation from his law-school application and found his explanation not credible.
- The Board found M.A.R. misrepresented to a creditor that he was an attorney despite not being admitted.
- M.A.R. presented mitigation evidence and character testimony, asserting partial remediation of some obligations.

## Issues

1. Whether M.A.R. proved the requisite character and fitness for admission to The Florida Bar in light of the Board’s findings of financial irresponsibility, disregard of legal obligations, and dishonesty.
2. What deference the Supreme Court should give the Board’s factual findings and credibility determinations in a bar-admission review.

## Decision

- The Supreme Court of Florida approved the Board’s recommendation and denied M.A.R. admission to The Florida Bar at that time.
- The Court held the Board’s factual findings were supported by competent, substantial evidence, including its credibility assessments.
- The Court concluded the cumulative pattern of misconduct—especially disobeying a court order, repeated financial delinquency, and false statements—showed M.A.R. had not met the character-and-fitness standard.
- The denial was not permanent; the disposition left open the possibility of a future application upon a sufficient showing of rehabilitation.

## Legal Principles

- Bar admission requires proof of present good character and fitness, including honesty, respect for the law, and financial responsibility.
- The Supreme Court retains ultimate authority over bar admissions but generally defers to the Board’s supported findings of fact and credibility after a formal hearing.
- Prolonged noncompliance with court orders and tax obligations, repeated issuance of bad checks, and misrepresentations in applications or sworn submissions are strong evidence of unfitness.
- Mitigation and rehabilitation must be substantial and convincingly demonstrated; recent or limited improvements may not overcome an ongoing or longstanding pattern of misconduct.

## Conclusion

The Florida Supreme Court denied admission because the Board’s supported findings showed a sustained pattern of legal noncompliance and dishonesty, and the evidence offered did not establish sufficient rehabilitation to meet the required character and fitness at the time of review.


Fla. Bd. of Bar Exam'rs re M.A.R., 755 So. 2d 89 (Fla. 2000)