upheld hearing in Maryland

2018See Attorney Grievance Comm'n v. Van Dusen , 443 Md. 413 , 430, 116 A.3d 1013 , 1023 (2015) (This Court concluded that a lawyer violated MLRPC 8.4(c) where, after being admitted to the Bar of Maryland, the lawyer "continued to conceal his criminal conduct from [the] SBLE, the [Attorney Grievance] Commission, and this Court." This Court stated that the lawyer's "deliberate and continued failure to disclose his misconduct in order to protect his Maryland [law] license [was] conduct involving dishonesty and misrepresentation."); Attorney Grievance Comm'n v. Hunt , 435 Md. 133 , 142-43, 76 A.3d 12

2018See Attorney Grievance Comm'n v. Van Dusen , 443 Md. 413 , 430, 116 A.3d 1013 , 1023 (2015) (This Court concluded that a lawyer violated MLRPC 8.4(c) where, after being admitted to the Bar of Maryland, the lawyer "continued to conceal his criminal conduct from [the] SBLE, the [Attorney Grievance] Commission, and this Court." This Court stated that the lawyer's "deliberate and continued failure to disclose his misconduct in order to protect his Maryland [law] license [was] conduct involving dishonesty and misrepresentation."); Attorney Grievance Comm'n v. Hunt , 435 Md. 133 , 142-43, 76 A.3d 12

2018See Attorney Grievance Comm'n v. Van Dusen , 443 Md. 413 , 430, 116 A.3d 1013 , 1023 (2015) (This Court concluded that a lawyer violated MLRPC 8.4(c) where, after being admitted to the Bar of Maryland, the lawyer "continued to conceal his criminal conduct from [the] SBLE, the [Attorney Grievance] Commission, and this Court." This Court stated that the lawyer's "deliberate and continued failure to disclose his misconduct in order to protect his Maryland [law] license [was] conduct involving dishonesty and misrepresentation."); Attorney Grievance Comm'n v. Hunt , 435 Md. 133 , 142-43, 76 A.3d 12

2018See Attorney Grievance Comm'n v. Van Dusen , 443 Md. 413 , 430, 116 A.3d 1013 , 1023 (2015) (This Court concluded that a lawyer violated MLRPC 8.4(c) where, after being admitted to the Bar of Maryland, the lawyer "continued to conceal his criminal conduct from [the] SBLE, the [Attorney Grievance] Commission, and this Court." This Court stated that the lawyer's "deliberate and continued failure to disclose his misconduct in order to protect his Maryland [law] license [was] conduct involving dishonesty and misrepresentation."); Attorney Grievance Comm'n v. Hunt , 435 Md. 133 , 142-43, 76 A.3d 12

2026See Attorney Grievance Comm’n v. Silbiger, 478 Md. 607, 629-30 , 276 A.3d 53, 66 (2022) (This Court upheld the hearing judge’s conclusion that an attorney engaged in dishonest conduct in violation of MARPC 8.4(c) by concealing from his client that he had misappropriated settlement funds, and we noted that the hearing judge stated that there was clear and convincing evidence that the attorney “exhibited a lack of straightforwardness[.]”).

2026See Attorney Grievance Comm’n v. Silbiger, 478 Md. 607, 629-30 , 276 A.3d 53, 66 (2022) (This Court upheld the hearing judge’s conclusion that an attorney engaged in dishonest conduct in violation of MARPC 8.4(c) by concealing from his client that he had misappropriated settlement funds, and we noted that the hearing judge stated that there was clear and convincing evidence that the attorney “exhibited a lack of straightforwardness[.]”).

2026See, e.g., Attorney Grievance Comm’n v. Rossbach, 485 Md. 563, 601-02 , 301 A.3d 176 , 198-99 (2023) (This Court upheld the hearing judge’s finding of indifference to making restitution where the attorney never refunded any portion of a client’s $1,600 fee, despite her claims that she would do so, and where the attorney refunded another client’s $1,000 fee approximately 18 months after the client terminated the representation and only after the client filed a complaint with Bar Counsel.).

2026See Attorney Grievance Comm’n v. Johnson, 450 Md. 621, 644 , 150 A.3d 338 , 352 (2016); see also Attorney Grievance Comm’n v. Taniform, 482 Md. 272, 307 , 286 A.3d 1072 , 1092 (2022) (This Court upheld the hearing judge’s conclusion that an attorney violated MARPC 1.4(b) by failing to advise his client “that he had not filed the motion to reopen” and making “repeated misrepresentations to the contrary that prevented [the client] from making informed decisions regarding his immigration matter.” (Citation modified)).

2026We have concluded that the aggravating factors of indifference to making restitution, refusal to acknowledge the misconduct’s wrongful nature, and a selfish motive were present where an attorney offered “a negligible refund” of $1,200 of the $6,200 that his client had paid and “falsely” blamed his client “for his own mistakes[.]” Attorney Grievance Comm’n v. Ucheomumu, 462 Md. 280, 326-27 , 200 A.3d 282, 309 (2018).

2026We have concluded that the aggravating factors of indifference to making restitution, refusal to acknowledge the misconduct’s wrongful nature, and a selfish motive were present where an attorney offered “a negligible refund” of $1,200 of the $6,200 that his client had paid and “falsely” blamed his client “for his own mistakes[.]” Attorney Grievance Comm’n v. Ucheomumu, 462 Md. 280, 326-27 , 200 A.3d 282, 309 (2018).

2026See Attorney Grievance Comm’n v. Johnson, 450 Md. 621, 644 , 150 A.3d 338 , 352 (2016); see also Attorney Grievance Comm’n v. Taniform, 482 Md. 272, 307 , 286 A.3d 1072 , 1092 (2022) (This Court upheld the hearing judge’s conclusion that an attorney violated MARPC 1.4(b) by failing to advise his client “that he had not filed the motion to reopen” and making “repeated misrepresentations to the contrary that prevented [the client] from making informed decisions regarding his immigration matter.” (Citation modified)).

2026See Attorney Grievance Comm’n v. Johnson, 450 Md. 621, 644 , 150 A.3d 338 , 352 (2016); see also Attorney Grievance Comm’n v. Taniform, 482 Md. 272, 307 , 286 A.3d 1072 , 1092 (2022) (This Court upheld the hearing judge’s conclusion that an attorney violated MARPC 1.4(b) by failing to advise his client “that he had not filed the motion to reopen” and making “repeated misrepresentations to the contrary that prevented [the client] from making informed decisions regarding his immigration matter.” (Citation modified)).

2022See id. at 244, 262-63 , 269 A.3d at 293, 304 .

2014In Attorney Grievance v. Link, 380 Md. 405, 428-29 , 844 A.2d 1197, 1211 (2004), this Court upheld the hearing judge’s finding that Link had engaged in “rude, boorish, insensitive, oppressive and certainly insulting” behavior, when he became involved in a heated argument with an MVA employee in circumstances where it was not apparent that he was representing a client.

2014In Attorney Grievance v. Link, 380 Md. 405, 428-29 , 844 A.2d 1197, 1211 (2004), this Court upheld the hearing judge’s finding that Link had engaged in “rude, boorish, insensitive, oppressive and certainly insulting” behavior, when he became involved in a heated argument with an MVA employee in circumstances where it was not apparent that he was representing a client.

1994Co. v. Tolson, 132 Md. 203, 206 , 103 A. 478, 479 (1918), this Court upheld an instruction which informed the jury of the existence of the State Industrial Accident Commission’s decision. 6 The instruction contained the following language: “ ‘But in Court proceedings, upon an appeal from a decision of the Commission, the decision is to be held prima facie correct, and the burden of proof is upon the party attacking it.’ ” Tolson, 132 Md. at 205 , 103 A. at 478-79 .

1994Co. v. Tolson, 132 Md. 203, 206 , 103 A. 478, 479 (1918), this Court upheld an instruction which informed the jury of the existence of the State Industrial Accident Commission’s decision. 6 The instruction contained the following language: “ ‘But in Court proceedings, upon an appeal from a decision of the Commission, the decision is to be held prima facie correct, and the burden of proof is upon the party attacking it.’ ” Tolson, 132 Md. at 205 , 103 A. at 478-79 .

1992In United States v. Jeffers, the Seventh Circuit stated: “The privilege may be recognized when so much of the actual communication has already been disclosed [not necessarily by the attorney, but by independent sources as well] that identification of the client [or of fees paid] amounts to disclosure of a confidential communication.” (Alteration in original). 532 F.2d 1101, 1115 (7th Cir.1976) (quoting NLRB v. Harvey, 349 F.2d 900, 905 (4th Cir.1965)), vacated in part on other grounds, 432 U.S. 137 , 97 S.Ct. 2207 , 53 L.Ed.2d 168 (1977).

1992In United States v. Jeffers , the Seventh Circuit stated: "The privilege may be recognized when so much of the actual communication has already been disclosed [not necessarily by the attorney, but by independent sources as well] that identification of the client [or of fees paid] amounts to disclosure of a confidential communication." (Alteration in original). 532 F.2d 1101, 1115 (7th Cir.1976) (quoting NLRB v. Harvey, 349 F.2d 900, 905 (4th Cir.1965)), vacated in part on other grounds, 432 U.S. 137 , 97 S.Ct. 2207 , 53 L.Ed.2d 168 (1977).

1992In United States v. Jeffers, the Seventh Circuit stated: “The privilege may be recognized when so much of the actual communication has already been disclosed [not necessarily by the attorney, but by independent sources as well] that identification of the client [or of fees paid] amounts to disclosure of a confidential communication.” (Alteration in original). 532 F.2d 1101, 1115 (7th Cir.1976) (quoting NLRB v. Harvey, 349 F.2d 900, 905 (4th Cir.1965)), vacated in part on other grounds, 432 U.S. 137 , 97 S.Ct. 2207 , 53 L.Ed.2d 168 (1977).

1992In United States v. Jeffers , the Seventh Circuit stated: "The privilege may be recognized when so much of the actual communication has already been disclosed [not necessarily by the attorney, but by independent sources as well] that identification of the client [or of fees paid] amounts to disclosure of a confidential communication." (Alteration in original). 532 F.2d 1101, 1115 (7th Cir.1976) (quoting NLRB v. Harvey, 349 F.2d 900, 905 (4th Cir.1965)), vacated in part on other grounds, 432 U.S. 137 , 97 S.Ct. 2207 , 53 L.Ed.2d 168 (1977).

1978In this regard, this case more nearly resembles Mills v. United States, 281 F. 2d 736, 741 (4th Cir. 1960), where the court upheld a claim of Fifth Amendment privilege, stating: “The-fact that [the subject witness had pleaded guilty but]... had not been sentenced distinguishes this case from United States v. Gernie, 2 Cir., 1958, 252 F. 2d 664, 670 , where the witness had been convicted of the crime with which charged and sentenced.