IN RE Paul J. MANAFORT, Jr., Respondent. An Inactive Member of the Bar of the District of Columbia Court of Appeals (Bar Registration No. 247486)
Report and Recommendation Of the Board on Professional
Responsibility, (DDN 288-18)
Fisher and Glickman, Associate Judges, and Steadman, Senior
case, the Board on Professional Responsibility has
recommended that respondent Paul J. Manafort, Jr., be
disbarred from the practice of law in the District of
Columbia after he pled guilty to conspiracy to obstruct
justice by tampering with witnesses while on pre-trial
release and conspiracy against the United
States. Neither respondent nor Disciplinary
Counsel filed exceptions to the Boards report. In response
to this courts January 10, 2019, order imposing an interim
suspension, respondent filed his D.C. Bar R. XI, § 14(g)
affidavit on February 28, 2019.
D.C. Bar R. XI, § 9(h)(2), "if no exceptions are filed
to the Boards report, the [c]ourt will enter an order
imposing the discipline recommended by the Board upon the
expiration of the time permitted for filing exceptions."
See also In re Viehe, 762 A.2d 542, 543
(D.C. 2000) ("When ... there are no exceptions to the
Boards report and recommendation, our deferential standard
of review becomes even more deferential."). Although we
have not previously held that a violation of 18 U.S.C. §
1512(b)(1) is a crime of moral turpitude per
se, we have found that convictions of
other subsections of this statute addressing witness and
evidence tampering constitute crimes of moral turpitude
per se. See, e.g., In re Johnson,
48 A.3d 170, 173 (D.C. 2012) (18 U.S.C. § 1512(b)(2));
In re Blair, 40 A.3d 883, 884 (D.C. 2012) (18 U.S.C.
§ 1512(b)(3)). Each of these subsections prohibits an
attempt to obstruct justice by attempting to induce an
individual to withhold evidence and we see no reason to treat
convictions from the three subsections differently. We have
held that a conviction for conspiracy to commit a crime of
moral turpitude is a crime of moral turpitude. See,
e.g., In re Lickstein, 972 A.2d 314, 316 (D.C.
2009). Because respondent has been convicted of a crime of
moral turpitude, the mandatory sanction imposed by statute is
to disbar him from the practice of law. See In
re Colson, 412 A.2d 1160, 1165 (D.C. 1979) (en banc).
Accordingly, it is
ORDERED that Paul J. Manafort, Jr. is hereby disbarred from
the practice of law in the District of Columbia, nunc pro
tunc to February 28, 2019.