In re Stuart

CourtDistrict of Columbia Court of Appeals
DecidedMarch 2, 2023
Docket21-BG-0656
StatusPublished

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In re Stuart, (D.C. 2023).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 21-BG-0656

IN RE PAMELA BRUCE STUART.

A Suspended Member of the Bar of the District of Columbia Court of Appeals (Bar Registration No. 220236)

On Report and Recommendation of the Board on Professional Responsibility

(19-BD-007; DDN 2019-D016)

(Argued October 5, 2022 Decided March 2, 2023)

Pamela Bruce Stuart, pro se.

Ebtehaj Kalantar, Assistant Disciplinary Counsel, with whom Julia L. Porter, Deputy Disciplinary Counsel, Myles V. Lynk, Senior Assistant Disciplinary Counsel, and Sean P. O’Brien, Assistant Disciplinary Counsel, were on the brief, for the Office of Disciplinary Counsel.

Before BECKWITH and MCLEESE, Associate Judges, and THOMPSON, Senior Judge.

PER CURIAM: Pamela Bruce Stuart was suspended from the Bar of this court

for one year, with a requirement that she demonstrate fitness to practice law before

being reinstated. In re Stuart, 172 A.3d 393, 394 (D.C. 2017) (per curiam). Ms.

Stuart has filed a petition for reinstatement. After holding an evidentiary hearing, a 2

Hearing Committee of the Board on Professional Responsibility recommended that

the court deny the petition. We agree with the Hearing Committee’s

recommendation and deny the petition.

I. Procedural and Factual Background

A. Proceedings in Florida

Ms. Stuart was made a trustee of her father’s trust. A dispute arose about her

performance of that responsibility. Ms. Stuart’s sisters, who are beneficiaries of the

trust along with Ms. Stuart, filed a civil lawsuit against Ms. Stuart in Florida. The

trial court in that case found that Ms. Stuart had breached her fiduciary duties by

loaning herself a substantial amount of money from the trust and by failing to

provide requisite annual accountings. More specifically, the trial court found,

among other things, that Ms. Stuart: (1) failed to appoint an independent co-trustee

as required; (2) instead appointed her brother-in-law, Edward Ryan, as co-trustee

even though she knew he was ineligible to be a trustee; (3) effectively operated

thereafter as a sole trustee; (4) abused her authority as trustee to the detriment of her

sisters; (5) loaned herself over $1.7 million from the trust, without providing

collateral or paying interest as required by the terms of the trust; (6) initially failed 3

to inform her sisters of the loans; (7) created a backdated loan agreement between

herself and the trust with respect to the loans; (8) once her sisters and Mr. Ryan

discovered the extent of the loans and expressed concerns, pointed out that Mr. Ryan

was not eligible to be a trustee and caused him to be removed as co-trustee;

(9) threatened to sue Mr. Ryan; (10) claimed that her obligation to repay the loans

she took out should be reduced by trust expenses she had paid, trustee fees, and legal

fees for her services as trustee at a rate of $675 per hour; (11) largely failed to

demonstrate that the loan amount should properly be reduced to reflect trustee fees

or expenses; (12) promised to repay the loans but repeatedly failed to carry through

on those promises, despite having received income that she could have used to at

least partially repay the loans; (13) took steps to shelter income and assets from

creditors, including falsely claiming to be a legal resident of Florida; and

(14) forfeited any right to compensation as a trustee due to her “multiple and flagrant

abuses” of her authority as trustee. The trial court therefore denied Ms. Stuart’s

request for compensation and expenses relating to her service as trustee and awarded

Ms. Stuart’s interests in certain Florida real properties to her co-beneficiaries. The

trial court also entered a deficiency judgment of over $1.7 million against Ms. Stuart.

Ms. Stuart challenged the trial court’s judgment in both state and federal court, but

the judgment was ultimately affirmed. 4

Ms. Stuart, who is also a member of the Florida Bar, was charged with

violating the Florida Bar rules. In that disciplinary proceeding, Ms. Stuart pleaded

guilty to “engag[ing] in a pattern of misconduct” in violation of Fla. R. Prof. Conduct

3-4.3 (acts that are “unlawful or contrary to honesty and justice”), 4-8.4(a) (violating

Rules of Professional Conduct), and 4-8.4(b) (acts that “reflect[] adversely on the

attorney’s honesty, trustworthiness, or fitness as a lawyer in other respects”). Ms.

Stuart acknowledged the trial court’s finding that she had breached her fiduciary

duties. The Supreme Court of Florida suspended Ms. Stuart from the practice of law

in Florida for one year.

B. Petition for Reinstatement in the District of Columbia

As previously noted, this court imposed reciprocal discipline, and Ms. Stuart

has now filed a petition for reinstatement. Disciplinary Counsel opposes

reinstatement. Ms. Stuart therefore was required to show by clear and convincing

evidence that she “has the moral qualifications, competency, and learning in law

required for readmission,” and that her “resumption of the practice of law . . . will

not be detrimental to the integrity and standing of the Bar, or to the administration

of justice, or subversive to the public interest.” D.C. Bar. R. XI, § 16(d)(1). When

evaluating a reinstatement petition, we consider the following factors: 5

(1) the nature and circumstances of the misconduct for which the attorney was disciplined; (2) whether the attorney recognizes the seriousness of the misconduct; (3) the attorney’s conduct since discipline was imposed, including the steps taken to remedy past wrongs and prevent future ones; (4) the attorney’s present character; and (5) the attorney’s present qualifications and competence to practice law.

In re Roundtree, 503 A.2d 1215, 1217 (D.C. 1985).

Ms. Stuart’s petition for reinstatement characterized her suspension as the

result of a “family dispute.” Ms. Stuart claimed that she borrowed from the trust as

a result of financial problems caused by a real-estate transaction in which she was

defrauded. She claimed that she had informed her family of her intent to borrow

from the trust to address the situation. She stated that her failure to prepare annual

accountings as required was “reasonable,” based on her many other responsibilities

and her family’s access to information about the trust accounts. She claimed to have

repaid over $700,000 of the money she borrowed from her father’s trust. She

disputed the findings and conclusions of the trial court in the Florida case.

In its answer to the petition, Disciplinary Counsel notified Ms. Stuart that

Disciplinary Counsel intended to rely on the “record of the reciprocal discipline 6

matter in this jurisdiction and the underlying civil and disciplinary matters.” Ms.

Stuart filed a pre-hearing motion objecting to, among other things, the consideration

of evidence and exhibits relating to the Florida civil proceedings. The Hearing

Committee denied that motion in relevant part.

C. Evidentiary Hearing

At the evidentiary hearing, Ms. Stuart’s testimony included the following.

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Related

In Re Roundtree
503 A.2d 1215 (District of Columbia Court of Appeals, 1985)
In Re Ditton
954 A.2d 986 (District of Columbia Court of Appeals, 2008)
In Re Maxwell
798 A.2d 525 (District of Columbia Court of Appeals, 2002)
In Re Stanton
757 A.2d 87 (District of Columbia Court of Appeals, 2000)
Harrison v. United States
526 A.2d 1377 (District of Columbia Court of Appeals, 1987)
In re Sabo
49 A.3d 1219 (District of Columbia Court of Appeals, 2012)

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