Matter of Manchanda

2024 NY Slip Op 05833
CourtAppellate Division of the Supreme Court of the State of New York
DecidedNovember 21, 2024
DocketMotion No. 2024-03792, 2024-03805 Case No. 2023-05258
StatusPublished

This text of 2024 NY Slip Op 05833 (Matter of Manchanda) is published on Counsel Stack Legal Research, covering Appellate Division of the Supreme Court of the State of New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Matter of Manchanda, 2024 NY Slip Op 05833 (N.Y. Ct. App. 2024).

Opinion

Matter of Manchanda (2024 NY Slip Op 05833)
Matter of Manchanda
2024 NY Slip Op 05833
Decided on November 21, 2024
Appellate Division, First Department
Per Curiam
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
This opinion is uncorrected and subject to revision before publication in the Official Reports.


Decided and Entered: November 21, 2024 SUPREME COURT, APPELLATE DIVISION First Judicial Department
Present — Hon. Dianne T. Renwick
Presiding Justice
Peter H. Moulton Lizbeth González Tanya R. Kennedy Saliann Scarpulla
Justices.

Motion No. 2024-03792, 2024-03805 Case No. 2023-05258

[*1] In the Matter of Rahul Dev Manchanda an Attorney and Counselor-at-Law: Attorney Grievance Committee for the First Judicial Department, Petitioner, Rahul Dev Manchanda (OCA Atty. Reg. No. 4025714), Respondent.


Disciplinary proceedings instituted by the Attorney Grievance Committee for the First Judicial Department. Respondent, Rahul Dev Manchanda, was admitted to the Bar of the State of New York at a Term of the Appellate Division of the Supreme Court for the Second Judicial Department March 13, 2002.



Jorge Dopico, Chief Attorney, Attorney Grievance Committee, New York (Remi E. Shea, of counsel), for petitioner.

Respondent pro se.



Per Curiam

Respondent Rahul Dev Manchanda was admitted to the practice of law in the State of New York by the Second Judicial Department on March 13, 2002. At all times relevant to this proceeding, his registered business address on file with the Office of Court Administration was within the First Judicial Department.

Nature of Proceedings

The disciplinary charges stem from the Attorney Grievance Committee's (AGC) sua sponteinvestigation of respondent after he filed three complaints with the AGC and the Human Rights Council in 2021, each containing racist and anti-Semitic language. In response to the AGC's email asking that he respond to the allegations of misconduct, respondent replied again using racist and anti-Semitic rhetoric. The AGC then undertook a retrospective review of respondent's previous court filings and prior complaints filed with it, which revealed:

"[R]espondent's long-standing history of verbally attacking and disparaging members of the judiciary, the bar, and the public in the context of litigation, in complaints filed with the [AGC] and other agencies . . . and in reviews/complaints filed anonymously [online] . . . . Respondent has also disclosed confidential information about clients in response to negative Google reviews and repeatedly filed non-meritorious frivolous, vexatious, or clearly meritless appeals, motions, or other papers."

Pursuant to its investigations, the AGC served respondent with a petition that included the following charges. In the first charge, the AGC alleged that respondent violated Rules of Professional Conduct (22 NYCRR 1200.0) (RPC) rule 8.4 (d) (a lawyer shall not "engage in conduct that is prejudicial to the administration of justice") by repeatedly making unfounded allegations of corruption by members of the judiciary. This charge arose out of legal documents that respondent prepared and filed in state and federal courts attacking members of the judiciary, using "foul and vile language" to challenge their integrity, specifically:

a federal civil rights action (later dismissed as frivolous) that respondent filed in the District of Connecticut against, among others, New York, and Connecticut judges (stemming from a custody dispute in which respondent was engaged with his ex-wife), in which he accused the defendants of engaging in criminal and sexually abusive behavior;

a federal civil rights action that respondent filed in the Southern District [*2]of New York against federal immigration officials, during which respondent leveled racist and anti-Semitic attacks against the presiding judge and others); an action that respondent filed in Supreme Court, New York County, in which he launched ad hominem attacks against the New York City Human Resources Administration;

an action filed against respondent in Supreme Court, New York County (stemming from a harassment campaign that respondent allegedly waged), in which the plaintiff was awarded costs on a discovery motion against respondent; respondent made anti-Semitic attacks in his motion in this Court for a stay, then tried to remove the action to the Southern District of New York, where (and in the U.S. Court of Appeals for the Second Circuit on appeal) he again leveled anti-Semitic attacks; and,

a federal action that respondent filed in the Southern District of New York against a federal bankruptcy judge (also in the Southern District of New York), in which respondent again leveled anti-Semitic attacks.

In the second charge, the AGC alleged that respondent violated RPC rule 8.4 (h) (a lawyer shall not "engage in any other conduct that adversely reflects on the lawyer's fitness as a lawyer") by repeatedly making racist, anti-Semitic, homophobic, and misogynistic statements about members of the judiciary and the bar in complaints to the AGC and other agencies. This charge arose out of "offensive language" that respondent used not only to publicly criticize members of the judiciary within the context of litigation but also in complaints filed with the AGC and other agencies, specifically:

a general complaint that respondent filed with the Commission on Judicial Conduct (CJC) in which he made racist attacks;

complaints that respondent filed with the AGC against Attorneys A, B, and C, in which he made anti-Semitic attacks;

a general complaint that respondent filed with the AGC in which he made anti-Semitic attacks;

a complaint that respondent filed with the CJC against a Justice of this Court, in which he made anti-Semitic and racist attacks;

a complaint that respondent filed with the Office of the United Nations High Commissioner for Human Rights, in which he made anti-Semitic and racist attacks; and,

a complaint that respondent filed with the Administrative Office of the U.S. Courts, in which he made anti-Semitic attacks.

The third and fourth charges are related; the AGC alleged that respondent violated RPC rule 1.6(a) ("A lawyer shall not knowingly reveal confidential information . . . or use such information to the disadvantage of a client or for the advantage of the lawyer or a third person . . ."), by knowingly revealing confidential information about his clients in response to negative Google reviews, and RPC rule 8.4 (h) (a lawyer shall not "engage in any other conduct that adversely reflects on the lawyer's fitness as a lawyer") by using offensive language in those responses. These charges arose out of:

homophobic attacks, based on privileged [*3]information, launched by respondent against client A.S.;

racist attacks, based on privileged information, launched by respondent against client E.W.;

attacks, based on privileged information, launched by respondent against client

N.A.; and

attacks, based on privileged information, launched by respondent against client M.H.A.

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Bluebook (online)
2024 NY Slip Op 05833, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-manchanda-nyappdiv-2024.