In re Flower

• Court: District of Columbia Court of Appeals
• Decided: December 26, 2024
• Docket: 24-BG-0991
• Status: Published

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 24-BG-0991

IN RE CLAUDIA FLOWER, RESPONDENT.

A Member of the Bar of the District of Columbia Court of Appeals (Bar Registration No. 489682)

On Report and Recommendation of the Board on Professional Responsibility Ad Hoc Hearing Committee Approving Petition for Negotiated Discipline (BDN: 23-ND-006; DDN: 2022-D014)

(Decided December 26, 2024)

Before: MCLEESE and DEAHL, Associate Judges, and THOMPSON, Senior Judge.

PER CURIAM: This decision is nonprecedential.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 a

petition for negotiated attorney discipline. Respondent Claudia Flower voluntarily

acknowledged that, during the pendency of an immigration appeal, she failed to both

provide competent representation and protect the client’s interests in connection with

terminating the representation by withdrawing the appeal without the client’s 2

consent rather than simply moving to withdraw as counsel. As a result, Ms. Flower

admits that she violated D.C. R. Pro. Conduct 1.1(a) and 1.16(d) and 8 C.F.R.

§ 1003.102(o) (2022) (a substantially similar obligation to Rule 1.1(a) for

practitioners before the Board of Immigration Appeals). The proposed discipline

consists of a public censure with no conditions as Ms. Flower has already completed

three hours of continuing legal education in the area of client communications.

Having reviewed the Committee’s recommendation in accordance with our

procedures in uncontested disciplinary cases, see D.C. Bar R. XI, § 12.1(d), we agree

that this case is appropriate for negotiated discipline and that “the agreed-upon

sanction is ‘justified,’” In re Mensah, 262 A.3d 1100, 1104 (D.C. 2021) (per curiam)

(quoting D.C. Bar R. XI, § 12.1(c)(3)); see, e.g., In re Avery, 926 A.2d 719 (D.C.

2007) (per curiam) (public censure for violating requirements to provide competent

representation and properly terminate representation, among other violations). We

further agree with the Committee that, in these circumstances, there is no need to

decide whether our Rule 1.1(a) or 8 C.F.R. § 1003.102(o) applies to Ms. Flower’s

misconduct. See In re Jenkins, 298 A.3d 293, 293 (D.C. 2023) (per curiam).

Accordingly, it is ordered that Claudia Flower is publicly censured.

So ordered.