In re Churnet

District of Columbia Court of Appeals·Decided August 21, 2025·No. 25-BG-0395·Published

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 25-BG-0395

IN RE WORKNEH CHURNET, RESPONDENT.

A Member of the Bar of the District of Columbia Court of Appeals (Bar Registration No. 974538)

On Report and Recommendation of the Board on Professional Responsibility Ad Hoc Hearing Committee Approving Second Amended Petition for Negotiated Discipline (BDN: 24-ND-006; DDN: 2022-D063)

(Decided August 21, 2025)

Before MCLEESE, DEAHL, and SHANKER, Associate Judges.

PER CURIAM: This decision is nonprecedential. Please refer to D.C. Bar R. XI,

§ 12.1(d), governing the appropriate citation of this opinion.

In this disciplinary matter, the Hearing Committee recommends approval of

the parties’ second amended petition for negotiated attorney discipline. Respondent

Workneh Churnet voluntarily acknowledged that he (1) commingled and failed to

maintain complete records of entrusted funds and (2) failed to deposit entrusted

funds into an IOLTA. As a result, respondent admits that he violated D.C. R. Pro.

Conduct 1.15(a) and (b). The proposed discipline consists of a ninety-day 2

suspension, with all but thirty days stayed, in favor of one year of supervised

probation with conditions.

Having reviewed the Committee’s recommendation in accordance with our

procedures in these cases, see D.C. Bar R. XI, § 12.1(d), we agree that this case is

appropriate for negotiated discipline and “the agreed-upon sanction is justified,” In

re Mensah, 262 A.3d 1100, 1104 (D.C. 2021) (per curiam) (internal quotation marks

omitted), in light of analogous precedents. See, e.g., In re Iglehart, 759 A.2d 203,

204 (D.C. 2000) (per curiam) (thirty-day suspension for failure to maintain

trust-account records and commingling funds); In re Ukwu, 712 A.2d 502, 502-03

(D.C. 1998) (per curiam) (stayed thirty-day suspension for same); see also In re

Teitelbaum, 303 A.3d 52, 57-58 (D.C. 2023) (providing that a negotiated discipline

petition “may generally omit to charge a violation if, after reasonable factual

investigation, there is a substantial risk that [the Office of Disciplinary Counsel]

would not be able to establish the violation by clear and convincing evidence”).

Accordingly, it is

ORDERED that respondent Workneh Churnet is hereby suspended from the

practice of law in the District of Columbia for 90 days with all but 30 days stayed,

in favor of one year of supervised probation with the following conditions: 3

(a) Respondent shall meet with and obtain an assessment from the District

of Columbia’s Practice Management Advisory Service (PMAS) and

comply with and implement any recommendations of PMAS, including

the supervision of his practice by a monitor for the period of at least

one year.

(b) Respondent will execute a waiver allowing the assigned practice

monitor to communicate directly with the Office of Disciplinary

Counsel regarding his compliance. The assigned practice monitor will

conduct a full assessment of respondent’s practices, including but not

limited to reviewing financial records, client files, engagement letters,

and respondent’s supervision and training of staff. The assigned

practice monitor shall take steps to ensure respondent is aware of and

has taken steps to comply with his obligations under Rule 1.15,

including maintaining complete records relating to client funds,

depositing entrusted funds into an IOLTA, and treatment of flat or

advance fees in compliance with this court’s precedents, see, e.g., In re

Mance, 980 A.2d 1196 (D.C. 2009). The practice monitor shall ensure

respondent complies with all the practice monitor’s recommendations.

(c) Respondent must be in full compliance with the practice monitor’s

requirements for a period of twelve consecutive months. After the 4

practice monitor determines that respondent has been in full

compliance for twelve consecutive months, respondent must sign an

acknowledgement that he is in compliance with the practice monitor’s

requirements and file the signed acknowledgement with the Office of

Disciplinary Counsel. 1 This must be accomplished no later than two

years after the date of this opinion.

(d) Respondent shall not be found to have engaged in any unethical conduct

before the probationary period expires.

(e) During the probationary period, respondent shall inform all clients, in

writing, that he is serving a term of probation.

Additionally, respondent is reminded that he must file with the Court an

affidavit pursuant to D.C. Bar R. XI, § 14(g), for, inter alia, purposes of

reinstatement in accordance with D.C. Bar R. XI, § 16, and Bd. Pro. Resp. R. 9.

So ordered.

1 The record reflects the parties’ understanding that respondent’s probation may last longer than one year in order for him to demonstrate twelve months of consecutive compliance with the practice monitor’s requirements.

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Related

In Re Ukwu
712 A.2d 502 (District of Columbia Court of Appeals, 1998)
In Re Mance
980 A.2d 1196 (District of Columbia Court of Appeals, 2009)
In re Iglehart
759 A.2d 203 (District of Columbia Court of Appeals, 2000)