Supreme Court of Maryland
Attorney Grievance v. Tabe
February 27, 2023483 Md. 3
Summary
The Court sustained the hearing judge’s factual findings and concluded that the lawyer violated Maryland trust-account and professional-conduct rules, as well as federal immigration-practitioner rules, through incompetent, negligent, and inadequately communicative representation of two asylum-seeking clients. Applying the governing choice-of-law rule, the Court held that federal immigration professional-conduct rules governed misconduct connected with the federal immigration proceedings, while Maryland rules continued to govern trust-account misconduct and related violations. The Court imposed a 90-day suspension with a one-year attorney-monitor condition upon reinstatement.