## Facts

- Frederick Francis DeBartolo graduated from law school, passed the Illinois bar examination, and submitted a sworn character-and-fitness questionnaire required for admission.
- The Committee on Character and Fitness for the First Judicial District investigated and notified DeBartolo it would refuse to certify him as having the required good moral character and general fitness.
- After DeBartolo requested a hearing, the Committee again voted not to certify him and issued a written report detailing its findings.
- The Committee found inaccuracies in DeBartolo’s sworn application regarding his high school education and omissions of multiple residences.
- DeBartolo reported incurring approximately 200 to 400 parking tickets during law school, which he claimed were paid or successfully contested; the Committee viewed the volume as concerning.
- The Committee found DeBartolo twice falsely represented himself as a police officer.
- DeBartolo presented favorable testimony from relatives, lawyers, and friends supporting his integrity and stability.
- DeBartolo petitioned the Supreme Court of Illinois under Rule 708(d) for relief from the Committee’s refusal and sought an order admitting him to the bar.

## Issues

1. Whether the Committee’s refusal to certify DeBartolo’s character and fitness was justified based on application inaccuracies and omissions, extensive parking violations, and impersonation of a police officer.
2. Whether the Supreme Court of Illinois should order DeBartolo’s admission to the bar notwithstanding the Committee’s adverse determination.

## Decision

- The Supreme Court of Illinois denied the petition and refused to order DeBartolo’s admission.
- The court agreed the record raised serious questions about DeBartolo’s stability, integrity, and character.
- The court treated the application’s inaccuracies and omissions as significant because candor in sworn submissions to bar authorities is essential.
- The court viewed the large number of parking tickets and the police-impersonation incidents as part of an overall pattern reflecting poor judgment and disregard for legal obligations.
- The court credited the Committee’s evaluation based on its investigation and hearing record and found the favorable testimony insufficient to overcome the adverse evidence.
- The court indicated the denial was not necessarily permanent and left open the possibility of a future application after improved conduct.

## Legal Principles

- An applicant bears the burden to demonstrate good moral character and general fitness for admission to the bar.
- Candor and completeness in sworn bar application materials are central to character and fitness; misstatements and omissions may justify denial even if not independently criminal.
- A pattern of repeated legal violations, even minor ones, may support a finding of insufficient fitness when it reflects poor judgment or disrespect for the law.
- Misrepresentation of official status (such as falsely claiming to be a police officer) weighs heavily against a finding of moral character.
- Courts give substantial weight to character-and-fitness committees’ investigative and hearing-based determinations when the applicant receives notice of concerns and an opportunity to respond.

## Conclusion

The Supreme Court of Illinois denied admission because DeBartolo’s lack of candor on a sworn application and his pattern of misconduct, including repeated parking violations and falsely posing as a police officer, supported the Committee’s refusal to certify his character and fitness at that time.


In re DeBartolo, 111 Ill. 2d 1, 488 N.E.2d 947 (Ill. 1986)