The Court of Appeals has denied bar admission to an applicant who failed to disclose a prior criminal charge of felony theft on her bar application and intentionally falsified her grade point average on a law school resume.
Despite narrow votes in favor of Deirdre Paulette Brown’s admission to the bar by both the State Board of Law Examiners and a character committee that conducted hearings on her fitness to practice law, the state’s top court found that Brown had failed to meet the burden of proving she possessed the character and moral fitness required for admission.
“Given that only four years have passed since Ms. Brown falsified her resume and subsequently failed to disclose the felony theft charge on her Bar application without a credible explanation for the omission during the Committee’s investigatory review, it is questionable whether Ms. Brown fully ‘understand[s] the high standard of integrity expected of an attorney,’” Judge Michele D. Hotten wrote for a unanimous Court of Appeals. “Collectively, Ms. Brown’s actions … are indicative of a cumulative pattern of a lack of honesty and candor, which is contrary to the fundamental characteristics of an attorney.”
A telephone number listed for Brown, who represented herself before the Court of Appeals, was not in service Friday, and she could not be reached for comment on the ruling.
Brown filed an application for admission to the bar soon after graduating from law school in 2012, the opinion states. She later supplemented the application to address questions about the status of outstanding debts and criminal and civil matters noted in her application but did not supplement it further when she did not pass the July 2012 bar exam.
After passing the bar in February 2013, Brown contacted Stuart Herschfeld, a member of the Character Committee for the 7th Appellate Circuit who had been assigned to review her application, to inquire about its status.
Several months later, Herschfeld recommended that she be denied bar admission based on her failure to disclose an incident in which she was sanctioned by her law school for misrepresenting her GPA on her resume, as well as her failure to provide an explanation for her financial irresponsibility.
Brown represented herself at two hearings before the full character committee, which voted 3 to 2 in August 2015 in favor of her application to the bar, a recommendation the State Board of Law Examiners upheld 4 to 3.
In overturning that decision, the Court of Appeals ruled that Brown’s failure to disclose a 1992 felony theft charge on her bar application and her inconsistent testimony before the committee, in which she first acknowledged the charge but later claimed she had no recollection of it, reflected negatively on her character. Neither the felony theft charge nor a charge of making a false statement to a police officer, which stemmed from the same 1992 incident and which Brown did disclose on her application, resulted in convictions, according to the opinion.
The court found Brown’s deliberate falsification of information on her resume, on which she claimed to have a 3.71, rather than 2.71, GPA, “even more troubling.”
“Ms. Brown deliberately altered her GPA on her resume to advance employment prospects which she would not have qualified for, had her true GPA had been disclosed,” Hotten wrote. “Ms. Brown was cognizant that her actions were misleading. Ms. Brown also candidly admitted that the motivation behind her actions were calculated and purely designed for her own personal gain.”
Brown admitted that she did not correct the misrepresentation when a law school career adviser congratulated her on the high GPA, and she testified that she only withdrew her application from consideration by a potential employer because she was afraid of getting caught.
While Brown showed remorse for her actions, her conduct throughout the disciplinary process did not outweigh the lack of honesty she displayed in the past, the court ruled in denying her application.
The case is In the Matter of the Application of Deirdre Paulette Brown, Misc. No. 33, September Term, 2015.