In re Demos

Attorney Paul Demos (defendant) was licensed to practice law in the District of Columbia (D.C.) but lived in Arizona. Demos applied to the bar of the United States District Court for the District of Arizona (Arizona federal court). Because he did not have an Arizona state law license, Demos could be admitted to practice before the Arizona federal court only if he was not a resident of Arizona. To get admitted, Demos intentionally misrepresented his residence on his admission application. The Arizona federal court discovered the misrepresentation, determined that it was intentional, and struck Demos from the Arizona federal court’s roll of attorneys. Being stricken from the roll of attorneys meant that Demos was suspended from practicing in that court but could reapply for admission at any time. Although the rules required Demos to immediately report this discipline to the D.C. bar (plaintiff), Demos never reported it. Five years later, the D.C. bar learned about the discipline and began reciprocal disciplinary proceedings in D.C. for the Arizona misconduct. The only sanction given in D.C. for intentional misrepresentations in a bar application was disbarment, and the Board on Professional Responsibility (the board) recommended disbarring Demos in D.C. The disbarment recommendation was reviewed by the District of Columbia Court of Appeals. During this review, Demos argued that the evidence showed that his misrepresentations in the federal-court application were not intentional.