In re Wojahn

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 25-BG-0486

IN RE PATRICK L. WOJAHN, RESPONDENT.

A Suspended Member of the Bar of the District of Columbia Court of Appeals (Bar Registration No. 483705)

On Report and Recommendation of the Board on Professional Responsibility

(BDN: 24-BD-069; DDN: 2024-D170)

(Decided February 5, 2026)

Before: EASTERLY and SHANKER, Associate Judges, and THOMPSON, Senior Judge.

PER CURIAM: The Board on Professional Responsibility recommends that

Patrick L. Wojahn be disbarred from the practice of law following his convictions

for knowing possession of child pornography with intent to distribute (100 counts),

in violation of Md. Code Ann., Crim. Law § 11-207, and knowing possession of

child pornography (40 counts), in violation of Md. Code Ann., Crim. Law § 11-208.

Although the Board found that Md. Code Ann., Crim. Law §§ 11-207, -208 were

not crimes of moral turpitude per se, it concluded that the undisputed facts 2

underlying the offenses involved moral turpitude. Respondent has not filed any

exceptions to the Board’s Report and Recommendation.

Under D.C. Bar R. XI, § 9(h)(2), “if no exceptions are filed to the Board’s

report, the [c]ourt will enter an order imposing the discipline recommended by the

Board upon the expiration of the time permitted for filing exceptions.” See also In

re Viehe, 762 A.2d 542, 543 (D.C. 2000) (per curiam) (“When . . . there are no

exceptions to the Board’s report and recommendation, our deferential standard of

review becomes even more deferential.”). Because no exceptions have been filed,

we accept the Board’s determination that the undisputed facts of this case constitute

offenses of moral turpitude. 1 Therefore, we impose the required sanction and disbar

respondent from the practice of law. See D.C. Code § 11-2503(a).

Accordingly, it is

1 See, e.g., In re Wolff, 490 A.2d 1118, 1119-20 (D.C. 1985), aff’d on reh’g en banc, 511 A.2d 1047 (D.C. 1986) (en banc) (concluding based on the facts that distribution of child pornography involved moral turpitude). We express no opinion regarding the Board’s determination that violations of Md. Code Ann., Crim. Law §§ 11-207, -208 are not crimes of moral turpitude per se. See, e.g., In re Moir, 258 A.3d 161, 162 (D.C. 2021) (per curiam) (“Because no exceptions have been filed, we need not . . . reach the issue of whether this offense constitutes a crime of moral turpitude per se or as applied to respondent’s actions, as both support the recommendation of disbarment.”). 3

ORDERED that respondent Patrick L. Wojahn is hereby disbarred from the

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

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

We observe that respondent has already filed two D.C. Bar R. XI, § 14(g) affidavits

in this matter, on February 19, 2025, and December 1, 2025, 2 but Disciplinary

Counsel has not yet taken a position on whether either or both of those affidavits

comply with Section 14. For reinstatement purposes, respondent’s disbarment will

run from the date of his first compliant D.C. Bar R. XI, § 14(g) affidavit. See D.C.

Bar R. XI, § 16(c). It is

FURTHER ORDERED that the underlying proceeding which resulted in

respondent’s suspension pursuant to D.C. Bar R. XI, § 10(c), In re Wojahn, No. 24-

BG-1113, is dismissed as moot.

So ordered.

2 Respondent’s affidavits were filed in case No. 24-BG-1113.