In 2010, attorney John J. Zodrow pleaded guilty in federal court to the felony of knowingly making a false oath in a bankruptcy petition, in violation of 18 U.S.C. § 152(2). After receiving notice of the conviction, the D.C. Court of Appeals suspended Zodrow and directed the Board on Professional Responsibility to determine whether the offense involved moral turpitude under D.C. Code § 11-2503(a). The Board recommended disbarment, and the court agreed, holding that bankruptcy fraud inherently involves moral turpitude based on its elements, which triggers mandatory disbarment without examining the specific facts of the case. The court therefore ordered Zodrow disbarred from practicing law in the District of Columbia, effective immediately, with his name stricken from the roll of attorneys.
The case arose from a 2004 traffic collision in which Detective Rauf rear-ended Steven Tulin's car, leading to Tulin's arrest for reckless driving by Officer McKoy; Tulin was later acquitted at trial. Tulin then sued Rauf for false arrest, malicious prosecution, and intentional infliction of emotional distress, and sued the District of Columbia for negligent supervision of McKoy. The jury found Rauf liable for intentional infliction of emotional distress and the District liable for negligent supervision, awarding $450,000 in damages, while rejecting the other claims. On appeal, the District and Rauf argued that the evidence was insufficient to support negligent supervision and that the verdicts were inconsistent with the jury's other findings. The court affirmed, holding that the evidence was legally sufficient and that the verdicts could be reconciled under the trial court's instructions.
This case involves reciprocal attorney discipline proceedings in the District of Columbia. Edward M. Fink had been disbarred by consent from the practice of law in New Jersey by order of the Supreme Court of New Jersey. Following an earlier D.C. suspension and an order to show cause why identical discipline should not be imposed, the court considered Fink's response along with Bar Counsel's statement. The D.C. court ordered Fink disbarred from practicing law in the District of Columbia, applying D.C. Bar Rule XI, § 11(c) and precedent from In re Addams, with the disbarment effective as of the date of the prior suspension.
In Byrd v. Voca Corp. of Washington, DC, three former employees who were union members covered by a collective bargaining agreement (CBA) with their employer sued for wrongful termination after they complained internally and to D.C. officials about deficiencies in group homes for developmentally disabled residents. The trial court granted summary judgment to the employer, ruling that the claims were preempted by § 301 of the National Labor Relations Act because they were inextricably tied to the CBA's 'just cause' termination provision and also that the employees failed to exhaust arbitration remedies under the CBA. On appeal, the court affirmed dismissal of one employee's claim on preemption grounds, finding that resolving it would require interpreting the CBA, but remanded the other two employees' cases for further proceedings after determining their public-policy claims could potentially stand independently of the CBA. The decision rests on federal preemption principles from cases like Lingle v. Norge, which hold that state-law claims are preempted only if they necessitate construing the collective bargaining agreement.
The case involved MPD Sergeant Buddy Smallwood's appeal of an agency ruling that classified minor injuries he sustained while off-duty in Maryland—during an attempted robbery where he identified himself as an officer and exchanged gunfire—as not incurred in the performance of his duties, thereby denying him workers' compensation benefits under the Police and Firefighter’s Retirement and Disability Act. The Superior Court had affirmed the Metropolitan Police Department's determination, and this court reviewed the matter under the same standards, assessing whether the decision was supported by substantial evidence and in accordance with the law. The court affirmed the ruling, relying on precedent from Rife v. District of Columbia Police and Firefighters’ Retirement and Relief Board, which held that an off-duty officer killed in a similar out-of-state robbery attempt was not acting in the performance of duty. It rejected Smallwood's arguments that statutes or his status as a potential Special Deputy U.S. Marshal granted him authority to act in Maryland, finding no police powers applied there and that the agency's classification was rational and not arbitrary.
Mason pled guilty to possession with intent to distribute marijuana. Nine years later, facing deportation proceedings, he petitioned for a writ of coram nobis to withdraw the plea on the ground that the trial court had not given the immigration-consequences advisement required by D.C. Code § 16-713. The trial court denied the petition without a hearing, and the appellate court affirmed, holding that Mason’s sworn statement at the plea hearing that he was a U.S. citizen judicially estopped him from asserting non-citizenship or claiming entitlement to the statutory warning.
