## Facts

- Paul T. Demos, II was admitted to the District of Columbia Bar in 1993.
- He applied for admission to a federal district court in Texas and represented that he lived and practiced in Arizona.
- He then applied for admission to a federal district court in Arizona, where local rules required Arizona state bar membership for applicants who resided in Arizona or principally practiced there.
- In the Arizona application, he gave different information about his residence and law office location, which the Arizona federal court later found was intended to avoid the Arizona state bar requirement.
- The Arizona federal court issued a show-cause order, held a hearing, found intentional misrepresentations and inconsistencies in his applications, and ordered him stricken from its roll of attorneys (functionally an indefinite suspension subject to potential readmission).
- D.C. disciplinary rules required prompt notice to Bar Counsel of discipline imposed elsewhere; Demos did not report the Arizona action.
- D.C. Bar Counsel later learned of the Arizona (and related Texas) matters during an unrelated investigation and initiated reciprocal discipline proceedings.
- The Board on Professional Responsibility recommended disbarment in D.C. as reciprocal, but non-identical, discipline; Demos did not meaningfully participate before the Board and filed an untimely objection.

## Issues

1. Whether D.C. should impose reciprocal discipline based on the Arizona federal court’s order and, if so, whether the sanction should be identical to Arizona’s or greater under D.C. standards.
2. Whether the Arizona court’s finding of intentional misrepresentation was binding in D.C. reciprocal discipline proceedings.
3. Whether any exception to reciprocal discipline applied (lack of due process, infirmity of proof, grave injustice, or substantially different discipline warranted in D.C.).

## Decision

- The court imposed reciprocal discipline and disbarred Demos from the practice of law in the District of Columbia.
- The court treated the Arizona adjudication as conclusively establishing misconduct, including intentional misrepresentation.
- The court rejected challenges to the fairness and evidentiary basis of the Arizona proceedings.
- The court imposed a harsher sanction than Arizona because D.C. discipline for intentional misrepresentations in bar admission matters is typically disbarment.

## Legal Principles

- In reciprocal discipline matters, D.C. presumes the foreign sanction is appropriate but may depart if an enumerated exception applies, including when the misconduct warrants substantially different discipline in D.C.
- A final disciplinary adjudication in another jurisdiction conclusively establishes the misconduct for D.C. disciplinary purposes.
- Intentional misrepresentations made in connection with attorney admission processes are treated as among the most serious forms of dishonesty and, under D.C. precedent, ordinarily result in disbarment.
- Failure to report discipline imposed in another jurisdiction violates D.C. reporting obligations and may be considered in assessing discipline.

## Conclusion

The court disbarred Demos as reciprocal discipline, holding that the Arizona federal court’s findings of intentional misrepresentation were conclusive in D.C. and that D.C. sanctioning norms for intentional admission-related deceit warranted disbarment rather than an Arizona-style indefinite suspension.


In re Demos, 875 A.2d 636 (D.C. 2005)