In re Armfield

• Court: District of Columbia Court of Appeals
• Decided: August 14, 2025
• Docket: 24-BG-1135
• Status: Published

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 24-BG-1135

IN RE SONYA N. ARMFIELD, RESPONDENT.

A Suspended Member of the Bar of the District of Columbia Court of Appeals (Bar Registration No. 491717)

On Report and Recommendation of the Board on Professional Responsibility

(BDN: 22-BD-076; DDN No. 2016-D230)

(Decided August 14, 2025)

Before: MCLEESE, DEAHL, and SHANKER, Associate Judges.

PER CURIAM: The Board on Professional Responsibility recommends that

Sonya N. Armfield be disbarred from the practice of law for intentional or, at a

minimum, reckless misappropriation of client funds and serious interference with

the administration of justice, in violation of D.C. R. Pro. Conduct 1.15(a) and 8.4(d).

Although respondent filed a cursory notice of exceptions to the Board’s

Report and Recommendation, she did not file a brief, and our review is accordingly

deferential and limited. In re Dubow, 729 A.2d 886, 887 (D.C. 1999) (per curiam)

(“[R]eview of the Board’s report should be deferential where respondent has 2

bypassed the opportunity to identify and brief issues.”). Moreover, we observe that

respondent did not present any argument to the Board concerning the Hearing

Committee’s Report and Recommendation and thus has failed to preserve any

argument that she could have raised to the Board. In re Chapman, 284 A.3d 395,

400 (D.C. 2022) (“Our court has consistently held that an attorney who fails to

present a point to the Board waives that point and cannot be heard to raise it for the

first time here.” (internal quotation marks omitted)).

Upon review of the record, we find no reason to question the Board’s factual

findings and conclusions—including the determination that respondent engaged in

at least reckless misappropriation of client funds. Because disbarment is the usual

sanction for intentional or reckless misappropriation, see In re Johnson, 321 A.3d

642, 652 (D.C. 2024) (per curiam) (“In virtually all cases of misappropriation,

disbarment will be the only appropriate sanction unless it appears that the

misconduct resulted from nothing more than simple negligence.” (internal quotation

marks and brackets omitted)), we accept the Board’s recommendation that

respondent be disbarred. Accordingly, it is

ORDERED that respondent Sonya N. Armfield is hereby disbarred from the

practice of law in this jurisdiction. Respondent’s attention is directed to the 3

requirements of D.C. Bar R. XI, § 14 and their effect on eligibility for reinstatement.

See D.C. Bar R. XI, § 16(c).

So ordered.