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Attorney Grievance Commission of Maryland v. Framm

Maryland Court of Appeals
144 A. 3d 827 (2016)


Rhonda Framm (defendant) was admitted to the bar in the State of Maryland in 1981. In 2010, she began representing Robert Wilson as he sought to vacate his divorce judgment. Wilson had diminished mental capacity and sought help from his cousin, Kevin Griggs, to understand information and legal documents. Framm informed Wilson that his diminished mental capacity could be a basis for overturning his divorce judgement. Framm filed a motion to vacate the divorce judgement and a petition to have Grigg appointed as guardian for Wilson; however, the guardianship petition was rejected twice because Framm failed to comply with filing rules. Framm properly filed the petition on the third attempt, and the court appointed another attorney to represent Wilson in the guardianship proceedings. At Wilson’s direction, Framm filed a denial asserting that he was not disabled, but then Framm also filed an opposition to that answer on Grigg’s behalf, arguing that Wilson was in fact disabled. Grigg and Wilson later decided to withdraw the guardianship petition, and Framm’s motion to withdraw the petition was granted. In representing Wilson for his divorce case, Framm attested to the judge that Wilson had a diminished mental capacity. The judge ordered Wilson to be evaluated for competency. Upon a finding that Wilson was not competent, the judge granted Framm’s petition to vacate the divorce judgement. Over the course of representing Wilson, Framm had billed him attorney’s fees that were greater than the amount of the divorce judgment Wilson had sought to have vacated. Framm sued Wilson for those fees and, in that proceeding, Framm attested that Wilson was of sound mind. Framm won the suit for payment of the attorney’s fees and had Wilson’s accounts garnished to satisfy the judgment. The Attorney Grievance Commission of Maryland (the Commission) (plaintiff) filed a petition for disciplinary action. A hearing judge determined that Framm had violated some rules of professional conduct but not all that the Commission had charged. Both the Commission and Framm filed exceptions to the judge’s findings.

Rule of Law


Holding and Reasoning (Barbera, C.J.)

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