A Boston-area lawyer, Maude Laroche-St. Fleur was fined $100 a day and subjected to a lengthier suspension after being held in contempt for falsely holding herself out as eligible to practice law on her website and voicemail. Justice David A. Lowy of the Massachusetts Supreme Judicial Court wrote in an opinion imposing sanctions that Laroche-St. Fleur stated in open court that she would not take the steps needed to comply with court orders in her ethics case, which Lowy said constitutes textbook contempt.
Lowy said there is no evidence that Laroche-St. Fleur was actively practicing law during the 18-month suspension she received in March 2022 for ignoring court orders and filing false financial statements in her divorce case, according to prior coverage of the October 2022 opinion upholding the 2022 suspension. But there appears to be no reference to Laroche-St. Fleur’s suspension on her law office website, her law firm’s voicemail message, her LinkedIn pages, and her law office “contact us” form, Lowy said.
In addition, Laroche-St. Fleur did not comply with an order to supply documents showing the extent to which she complied with the suspension order.
“By continuing to hold herself out as a practicing attorney or as entitled to practice law while she has been suspended,” Lowy said, Laroche-St. Fleur “has engaged in the unauthorized practice of law.”
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Lowy added that this blatant defiance of the clear and unequivocal commands of the court constitutes textbook contempt, and as a result, Laroche-St. Fleur must continue paying the $100 daily fine until she is no longer in contempt. Lowy also tacked extra time onto Laroche-St. Fleur’s initial 18-month suspension, making her ineligible to apply for reinstatement for five years after whatever date she substantially complies with orders in the ethics case. And Lowy said he would appoint a commissioner to “take appropriate action.”
According to the discipline summary, Laroche-St. Fleur has the right to appeal to the full Massachusetts Supreme Judicial Court. She has filed a cert petition with the U.S. Supreme Court but could not comment further.
This case highlights the importance of adhering to ethical obligations as a lawyer. It is essential for lawyers to comply with court orders and avoid engaging in the unauthorized practice of law. Failure to do so can result in severe consequences such as fines, suspensions, and potential disbarment. Lawyers should ensure that their websites and other public-facing materials accurately reflect their current status as licensed and eligible practicing attorneys. Additionally, lawyers should promptly comply with court orders and provide the necessary documentation to avoid further disciplinary action.
Overall, Laroche-St. Fleur’s case reminds all lawyers that adherence to ethical obligations is essential to maintain their status as licensed attorneys and avoid disciplinary action. The consequences of failing to comply with court orders or engaging in the unauthorized practice of law can be severe, and lawyers must take these obligations seriously.