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Attorney Grievance Commission v. Hamilton - Attorney Misconduct

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Filed January 27th, 2026
Detected March 2nd, 2026
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Summary

The Maryland Court of Appeals has disbarred attorney Judith Marie Hamilton for multiple violations of professional conduct rules, including incompetence, lack of diligence, communication failures, and misconduct during an investigation. The disciplinary action stems from her representation in a divorce case and her failure to cooperate with Bar Counsel.

What changed

The Supreme Court of Maryland has ordered the disbarment of attorney Judith Marie Hamilton. The disciplinary action, initiated by the Attorney Grievance Commission of Maryland, found that Hamilton violated numerous Maryland Attorneys' Rules of Professional Conduct. These violations encompassed issues of competence, diligence, communication, fees, safekeeping of property, declining representation, and general misconduct, including a failure to cooperate with the Bar Counsel's investigation into her conduct during a client's divorce proceedings.

This disbarment represents a final and severe disciplinary measure. For legal professionals, this case underscores the critical importance of adhering strictly to ethical rules and cooperating fully with disciplinary investigations. Failure to do so can result in the loss of one's license to practice law. While no specific compliance deadline is mentioned for other entities, the outcome serves as a stark warning regarding the consequences of professional misconduct and non-cooperation with regulatory bodies.

What to do next

  1. Review Maryland Attorneys' Rules of Professional Conduct for adherence
  2. Ensure full cooperation with any Bar Counsel investigations

Penalties

Disbarment

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Jan. 27, 2026 Get Citation Alerts Download PDF Add Note

Attorney Grievance Comm'n v. Hamilton

Court of Appeals of Maryland

Combined Opinion

Attorney Grievance Commission of Maryland v. Judith Marie Hamilton, AG No. 32,
September Term, 2024. Opinion by Killough, J.

ATTORNEY MISCONDUCT – DISCIPLINE – DISBARMENT – Respondent Judith
Marie Hamilton violated Maryland Attorneys’ Rules of Professional Conduct 19-301.1
(Competence), 19-301.3 (Diligence), 19-301.4 (Communication), 19-301.5(a) (Fees), 19-
301.15(c) (Safekeeping of property), 19-301.16(d) (Declining or terminating
representation), 19-308.1(b) (Bar admission and disciplinary matters), and 19-308.4(a) and
(d) (Misconduct). These violations arose from Respondent’s representation of a client in
his divorce proceedings and from Respondent’s lack of cooperation in Bar Counsel’s
subsequent investigation into her conduct.

The Supreme Court of Maryland ordered that Respondent be disbarred.
Circuit Court for Baltimore County
Case No.: C-03-CV-25-000067
Argued: Oral Argument waived

IN THE SUPREME COURT

OF MARYLAND

AG No. 32

September Term, 2024


ATTORNEY GRIEVANCE COMMISSION
OF MARYLAND

v.

JUDITH MARIE HAMILTON


Fader, C.J.,
Watts,
Booth,
Biran,
Gould,
Eaves,
Killough,

JJ.


Opinion by Killough, J.
Pursuant to the Maryland Uniform Electronic Legal


Materials Act (§§ 10-1601 et seq. of the State
Government Article) this document is authentic.
Filed: January 27, 2026
2026.01.27
'00'05- 16:15:12
Gregory Hilton, Clerk
This matter arises from Respondent Judith Marie Hamilton’s misconduct in her

representation of Brian Foster during his divorce proceedings and from her lack of

cooperation with Bar Counsel’s resulting investigation. On December 17, 2024, the

Attorney Grievance Commission of Maryland (“Commission”), acting through Bar

Counsel (hereinafter referred to as “Petitioner”), filed a Petition for Disciplinary or

Remedial Action against Respondent in the Supreme Court of Maryland. Petitioner alleged

that Respondent violated Maryland Attorneys’ Rules of Professional Conduct (“MARPC”)

19-301.1 (Competence), 19-301.3 (Diligence), 19-301.4 (Communication), 19-301.5(a)

(Fees), 19-301.15(c) (Safekeeping of property), 19-301.16(d) (Declining or terminating

representation), 19-308.1(b) (Bar admission and disciplinary matters), and 19-308.4(a) and

(d) (Misconduct).1 On January 3, 2025, the Supreme Court of Maryland referred this

matter to the Honorable Garret P. Glennon, Jr. (“Hearing Judge”) of the Circuit Court for

Baltimore County to make findings of fact and conclusions of law.

Pursuant to the Order for Alternative Service dated February 25, 2025, and the Order

dated April 1, 2025, Petitioner served the Petition on Respondent via mail, certified mail,

and email on April 2, 2025. Respondent failed to answer within the required time. On

April 28, 2025, the circuit court entered an Order of Default. Respondent did not move to

vacate the Order of Default. On June 25, 2025, Petitioner moved for default judgment and

sanctions. On June 30, 2025, the circuit court held a hearing in this matter at which

1
In this opinion, for ease of reference, we use the numbering format of the American
Bar Association Model Rules – e.g., Rule 1.1, in lieu of Rule 19-301.1. See Md. Rule 19-
300.1(22).
Respondent did not appear. On July 3, 2025, the court granted the default judgment against

Respondent. On July 14, 2025, a hearing was held in this matter before the Hearing Judge

at which Respondent did not appear. During the hearing, the court granted Petitioner’s

motion to admit the averments in the Petition for Disciplinary or Remedial Action. On

August 28, 2025, the Hearing Judge issued findings of fact and conclusions of law.

The Hearing Judge found, by clear and convincing evidence, that Respondent

violated the following Maryland Attorneys’ Rules of Professional Conduct: 1.1, 1.3, 1.4,

1.5(a), 1.15(c), 1.16(d), 8.1(b), and 8.4(a) and (d). The Hearing Judge also found the

presence of six aggravating factors and no mitigating factors. No exceptions were filed,

and Petitioner recommends that Respondent be disbarred.

On October 15, 2025, the Clerk’s Office of the Supreme Court of Maryland sent to

Respondent and Petitioner a notice advising the parties that oral argument in this matter

was scheduled for November 3, 2025, that Respondent was to notify the Clerk’s Office no

later than October 20, 2025, whether she intended to appear for oral argument, and that, if

Respondent did not send in a notice of intention to appear, she would be deemed to have

waived oral argument. The notice further provided that, in the event Respondent

affirmatively waived oral argument or was deemed to have waived oral argument, Bar

Counsel was to notify the Clerk’s Office by October 21, 2025, whether Petitioner also

waived oral argument. Respondent did not send in a notice of intention to appear, and on

October 21, 2025, Petitioner sent a letter to the Clerk’s Office advising that its position was

that Respondent waived oral argument by not providing notice and that Bar Counsel would

appear for oral argument unless otherwise directed by this Court. On October 24, 2025,

2
the Clerk’s Office sent a letter to the parties advising that Respondent was deemed to have

waived oral argument and that the matter was removed from the November 3, 2025, oral

argument schedule. As such, no oral argument was held in this matter.

In this case, Respondent wholly failed to participate in the disciplinary process. She

did not respond to the Petition, did not file exceptions to the Hearing Judge’s findings and

conclusions, did not submit opposition memoranda to this Court, and waived oral

argument. Where, as here, no exceptions are filed, this Court may accept the hearing

judge’s factual findings as established. Md. Rule 19-740(b)(2)(A). We exercise that

discretion in this case. Accordingly, we treat as established the following facts, which the

Hearing Judge found to have been proved by clear and convincing evidence.

I.

HEARING JUDGE’S FINDINGS OF FACT

We summarize below the Hearing Judge’s findings of fact.

Respondent was admitted to the Maryland Bar on December 12, 1995. During the

period relevant to this matter, Respondent maintained an office for the practice of law in

Baltimore County, Maryland.

3
A.

Brian Foster Divorce Proceedings

In April 2023, Brian Foster retained Respondent to represent him in divorce

proceedings. On April 26, Respondent endorsed and deposited a $3,000 check from Mr.

Foster into an account that was not her Interest on Lawyers’ Trust Account (“IOLTA”).2

On May 1, Respondent entered an appearance in Mr. Foster’s case and filed an

Answer to the Counter-Complaint for Absolute Divorce on his behalf in the Circuit Court

for Baltimore County. The court rejected Respondent’s entry of appearance for failure to

comply with Maryland Rule 20-203(c) but accepted the Answer. On June 5, Respondent

spoke with opposing counsel both before and after the initial scheduling conference.

However, from July 2023 until September 2023, Respondent never responded to opposing

counsel’s many attempts to contact her via telephone, email, and U.S. mail.

On August 29, opposing counsel filed a Motion to Extend the Deadline for

Discovery and to Compel Discovery from Mr. Foster. In her Motion, opposing counsel

mentioned how her attempts to secure Respondent’s consent to the Motion to Extend

Discovery had gone unanswered. On September 5, Mr. Foster informed opposing counsel

that Respondent had not communicated with him since June 5, 2023. On September 20,

the court granted opposing counsel’s motion.

2
An IOLTA is a type of client trust account “payable to the Maryland Legal
Services Corporation Fund under Code, Business Occupations and Professions Article, §
10-303.” Md. Rule 19-402(h).
4
Also in September 2023, Mr. Foster terminated Respondent’s services via email and

requested a refund of the fee he had previously paid her. On September 7, Respondent

responded to Mr. Foster’s email from a new email account. In her email, she asked Mr.

Foster to send her additional documents and provided no explanation regarding her long

absence from his case. Four days later, David Mahood, Esq., entered an appearance on

behalf of Mr. Foster. Respondent did not complete further work on Mr. Foster’s divorce

proceedings, and as of the hearing in this matter, she had not refunded him any portion of

his $3,000 payment.

B.

Commission’s Investigation

On September 1, 2023, opposing counsel filed a complaint against Respondent with

Petitioner. Mr. Foster did the same roughly two weeks later. On October 2, Bar Counsel

wrote Respondent with a copy of both complaints enclosed and requested a written

response via email. On October 31, Bar Counsel once again requested a response to the

October 2 letter. Bar Counsel sent this request via email and certified mail to the respective

addresses Respondent maintained with the Client Protection Fund. On December 11, Bar

Counsel received a response from the United States Postal Service (“USPS”) stating that

the letter was undeliverable.

On February 28, 2024, Bar Counsel docketed the case for investigation. Bar

Counsel sent this docket notice to Respondent via email and certified mail. Bar Counsel

once again received notice from USPS that the mailing was undeliverable. However, Bar

Counsel did not receive a notification that the email correspondence was undelivered.

5
On April 2, Bar Counsel’s investigator attempted to contact Respondent through

multiple avenues. Bar Counsel sent six messages to email accounts listed for Respondent,

attempted to call Respondent on nine different phone numbers associated with

Respondent’s TransUnion Locator Services profile, and reached out to Respondent’s

previous employer, who provided the investigator with an email address he had already

messaged. Respondent’s previous employer explained that Respondent was hired in the

late fall or early winter of 2023 and was “let go” at the end of February 2024. Bar Counsel’s

investigator also visited Respondent’s personal residence, which the investigator

discovered had been vacant for six months. As of the hearing on this matter, Respondent

has failed to respond to any of Bar Counsel’s attempts to contact her.

II.

HEARING JUDGE’S CONCLUSIONS OF LAW

The Hearing Judge concluded that Respondent violated MARPC 1.1, 1.3, 1.4,

1.5(a), 1.15(c), 1.16(d), 8.1(b), and 8.4(a) and (d). As noted above, neither Petitioner nor

Respondent filed any exceptions. We review the Hearing Judge’s conclusions of law de

novo and independently determine whether Bar Counsel established by clear and

convincing evidence the alleged rules violations. Md. Rule 19-740(b)(1)–(2); Attorney

Grievance Comm’n v. Trezevant, 484 Md. 34, 47 (2023). Based on our independent review

of the record, we agree with the Hearing Judge’s legal conclusions that Respondent

violated MARPC 1.1, 1.3, 1.4, 1.5(a), 1.15(c), 1.16(d), 8.1(b), and 8.4(a) and (d).

6
III.

RULE VIOLATIONS

Rule 1.1 –Competence

Rule 1.1 provides:

An attorney shall provide competent representation to a client.
Competent representation requires the legal knowledge, skill,
thoroughness and preparation reasonably necessary for the
representation.

“Incompetent representation occurs when an attorney fails to take necessary,

fundamental steps in a client’s case.” Attorney Grievance Comm’n v. Ambe, 466 Md. 270,

288 (2019) (citation omitted). Here, Respondent filed a deficient Notice of Representation

and never rectified it. After attending an initial scheduling conference and corresponding

a few times with opposing counsel, Respondent was unresponsive from July 2023 until

September 2023. During that time, Respondent never responded to Mr. Foster’s and

opposing counsel’s attempts to contact her. Respondent failed to adequately represent Mr.

Foster during the discovery process and abandoned her client with no notice. And, when

Respondent finally responded to Mr. Foster’s email terminating her services and requesting

a refund, she neither acknowledged the termination nor provided any explanation for her

four-month long absence, nor refunded him any of the payment he made to her.

Respondent’s conduct in Mr. Foster’s divorce proceedings constitutes a violation of Rule

1.1 (Competence).

Rule 1.3 – Diligence

Rule 1.3 provides:

7
An attorney shall act with reasonable diligence and promptness
in representing a client.

This Court has noted that “an attorney’s failure to take fundamental steps in

furthering a client’s matter qualifies as neglect and inattentiveness to a client’s interest”

and is a violation of Rule 1.3. Attorney Grievance Comm’n v. Garrett, 427 Md. 209, 223

(2012) (citation omitted). By failing to amend her deficient Notice of Representation,

respond to inquiries from her client and opposing counsel, fulfill her discovery obligations,

and provide notice and explanation of her inability to represent Mr. Foster in his divorce

case, Respondent violated Rule 1.3 (Diligence).

Rule 1.4 – Communication

Rule 1.4 provides:

(a) An attorney shall:
(1) promptly inform the client of any decision or
circumstance with respect to which the client’s
informed consent, as defined in Rule 19-301.0(g) (1.0),
is required by these Rules;
(2) keep the client reasonably informed about the status of
the matter;
(3) promptly comply with reasonable requests for
information; and
(4) consult with the client about any relevant limitation on
the attorney’s conduct when the attorney knows that the
client expects assistance not permitted by the Maryland
Attorneys’ Rules of Professional Conduct or other law.
(b) An attorney shall explain a matter to the extent reasonably
necessary to permit the client to make informed decisions
regarding the representation.

Respondent’s absence during a substantial portion of Mr. Foster’s divorce

proceedings constitutes a violation of Rule 1.4. After attending an initial scheduling

8
hearing on June 5, 2023, Respondent was totally unresponsive for four months. She failed

to respond to both her client’s and opposing counsel’s attempts to contact her during this

time. When she responded to Mr. Foster’s email terminating her services and requesting a

refund in September 2023, she provided no explanation as to her four-month absence from

the case and gave no account of how she intended to rectify the consequences of this

absence. Respondent’s actions do not meet the standards of communication required by

Rule 1.4.

Rule 1.5 – Fees

Rule 1.5(a) provides:

(a) An attorney shall not make an agreement for, charge, or
collect an unreasonable fee or an unreasonable amount for
expenses. The factors to be considered in determining the
reasonableness of a fee include the following:
(1) the time and labor required, the novelty and
difficulty of the questions involved, and the skill
requisite to perform the legal service properly;
(2) the likelihood, if apparent to the client, that the
acceptance of the particular employment will preclude
other employment of the attorney;
(3) the fee customarily charged in the locality for similar
legal services;
(4) the amount involved and the results obtained;
(5) the time limitations imposed by the client or by the
circumstances;
(6) the nature and length of the professional relationship
with the client;
(7) the experience, reputation, and ability of the attorney
or attorneys performing the services; and
(8) whether the fee is fixed or contingent.

This Court has recognized that, “[w]hen an attorney charges a fee but does no work,

the fee is per se unreasonable. It is irrelevant that the fee is ‘initially reasonable’ if the

9
attorney fails to perform any of the services for which the attorney was paid.” Attorney

Grievance Comm’n v. Gage-Cohen, 440 Md. 191, 198–99 (2014) (internal citations

omitted). Here, Respondent did not represent Mr. Foster in any substantial capacity during

his divorce proceedings. Besides filling out a “boilerplate” Answer, corresponding a few

times with opposing counsel, and attending an initial scheduling conference, Respondent

made little effort to complete the work for which she was retained. She failed to respond

to both her client’s and opposing counsel’s multiple attempts to reach her during the

discovery process. As of the date of the hearing on this matter, she has yet to refund any

portion of the $3,000 retainer Mr. Foster paid. Respondent’s conduct violates Rule 1.5(a)

(Fees).

Rule 1.15 – Safekeeping Property

Rule 1.15(c) provides:

(c) An attorney shall deposit into a client trust account legal
fees and expenses that have been paid in advance, to be
withdrawn by the attorney only as fees are earned or expenses
incurred.

Respondent violated Rule 1.15(c) (Safekeeping Property) when she deposited the

$3,000 retainer Mr. Foster paid her to represent him in his divorce proceedings in an

account other than her IOLTA. See Attorney Grievance Comm’n v. King, 491 Md. 485,

505 (2025) (finding a violation of Rule 1.15(c) for failing to maintain unearned portions of

retainer fee in an attorney trust account).

Rule 1.16 – Declining or Terminating Representation

Rule 1.16(d) provides:

10
(d) Upon termination of representation, an attorney shall take
steps to the extent reasonably practicable to protect a
client’s interests, such as giving reasonable notice to the
client, allowing time for employment of another attorney,
surrendering papers and property to which the client is
entitled and refunding any advance payment of fee or
expense that has not been earned or incurred. The attorney
may retain papers relating to the client to the extent
permitted by other law.

Respondent violated Rule 1.16(d) when she failed to acknowledge Mr. Foster’s

termination of her services and take the appropriate steps following the termination. Upon

termination, she also made no attempts to provide Mr. Foster and his new lawyer, David

Mahood, the records to which her former client was entitled and to facilitate a smooth

transition from herself to Mr. Mahood. Finally, despite making only minimal progress on

Mr. Foster’s case, Respondent never refunded any portion of the $3,000 retainer he paid

her. See Attorney Grievance Comm’n v. Davis, 486 Md. 116, 138 (2023) (concluding that

an attorney violated Rule 1.16(d) when he abandoned his client and failed to return

unearned portion of retainer fee).

Rule 8.1 – Bar Admission and Disciplinary Matters

Rule 8.1 provides:

An applicant for admission or reinstatement to the bar, or an
attorney in connection with a bar admission application or in
connection with a disciplinary matter, shall not:

(b) fail to disclose a fact necessary to correct a
misapprehension known by the person to have arisen in

11
the matter, or knowingly fail to respond to a lawful
demand for information from an admissions or
disciplinary authority, except that this Rule does not
require disclosure of information otherwise protected
by Rule 19-301.6 (1.6).

Respondent violated Rule 8.1(b) when she failed to cooperate with or respond to the

Commission’s investigation into her representation of Mr. Foster. Despite being properly

served and Bar Counsel’s numerous attempts to contact her at her known physical

addresses, phone numbers, and email addresses, Respondent did not acknowledge or

answer the Commission’s request for information. As a result of Respondent’s failure to

respond, the Hearing Judge entered a default judgment and conducted an ex parte hearing.

Respondent’s actions constitute a knowing failure “to respond to a lawful demand for

information from an admissions or disciplinary authority,” thereby violating Rule 8.1(b).

See Attorney Grievance Comm’n v. De La Paz, 418 Md. 534, 555–56 (2011) (finding a

violation of Rule 8.1(b) for failing to respond or cooperate with Bar Counsel after receiving

adequate notice); Attorney Grievance Comm’n v. Briscoe, 357 Md. 554, 564–65 (2000)

(same).

Rule 8.4 – Misconduct

Rule 8.4 (a) and (d) provide:

It is professional misconduct for an attorney to:

(a) violate or attempt to violate the Maryland Attorneys’ Rules
of Professional Conduct, knowingly assist or induce another to
do so, or do so through the acts of another;


12
(e) engage in conduct that is prejudicial to the administration
of justice[.]

By violating Rules 1.1, 1.3, 1.4, 1.5(a), 1.15(c), 1.16(d) and 8.1(b), Respondent

violated Rule 8.4(a). See Attorney Grievance Comm’n v. Framm, 449 Md. 620, 664 (2016)

(citation modified) (“We have held that, when an attorney violates a rule of professional

conduct, the attorney also violates M[A]RPC 8.4(a).”).

Moreover, Respondent’s consistent unresponsiveness during Mr. Foster’s divorce

proceedings and the Commission’s investigation, her choice to deposit the retainer her

client paid her in an account other than her IOLTA, her failure to meet her discovery

obligations, her unwillingness to refund the unearned retainer fee, and her ultimate

abandonment of her client are “prejudicial to the administration of justice” and thus violate

Rule 8.4(d). See Attorney Grievance Comm’n v. Agbaje, 438 Md. 695, 717 (2014) (citation

omitted) (“Conduct which is likely to impair public confidence in the profession, impact

the image of the legal profession and engender disrespect for the court is conduct

prejudicial to the administration of justice.”).

IV.

SANCTION

The primary purpose of attorney discipline in Maryland is to “protect the public,

to deter other lawyers from engaging in violations of the [MARPC], and to maintain the

integrity of the legal profession.” Attorney Grievance Comm’n v. Shryock, 408 Md. 105,

126 (2009) (citation omitted). In line with this principle, this Court imposes sanctions that

13
are “commensurate with the nature and gravity of the violations and the intent with which

they were committed.” Attorney Grievance Comm’n v. Awuah, 374 Md. 505, 526 (2003)

(citation omitted).

In the course of an attorney grievance matter, the circuit court may consider the

existence of aggravating and mitigating factors. The following aggravating factors

should be considered in an attorney disciplinary proceeding:

(1) prior attorney discipline; (2) a dishonest or selfish motive; (3) a pattern
of misconduct; (4) multiple violations of the M[A]RPC; (5) bad faith
obstruction of the attorney discipline proceeding by intentionally failing to
comply with the Maryland Rules or orders of this Court []; (6) submission
of false evidence, false statements, or other deceptive practices during the
attorney discipline proceeding; (7) a refusal to acknowledge the
misconduct’s wrongful nature; (8) the victim’s vulnerability; (9) substantial
experience in the practice of law; (10) indifference to making restitution or
rectifying the misconduct’s consequences; (11) illegal conduct, including
that involving the use of controlled substances; and (12) likelihood of
repetition of the misconduct.

Attorney Grievance Commission v. Shuler, 443 Md. 494, 506–07 (2015) (alterations in

original omitted). Petitioner has the burden of proving aggravating factors by clear and

convincing evidence. Md. Rule 19-727(c).

Petitioner alleged the following aggravating factors: dishonest or selfish motive,

multiple violations of the rules of professional conduct, bad faith obstruction of the

discipline proceeding, substantial experience in the practice of law, indifference to making

restitution or rectifying the misconduct’s consequences, and likelihood of repetition of

misconduct.

We agree with the Hearing Judge’s determination that Petitioner established the

existence of these aggravating factors through clear and convincing evidence. Respondent

14
displayed dishonest and selfish behavior when she deposited the retainer payment in an

account other than her IOLTA, abandoned her client for months, failed to acknowledge the

termination of her services, and failed to refund the retainer he paid her. And, as detailed

above, her conduct during Mr. Foster’s divorce proceedings and the subsequent

investigation into her actions constituted multiple violations of the rules of professional

conduct. Relatedly, her lack of cooperation and forthcomingness during the grievance

process amounts to a bad-faith obstruction of the disciplinary process. Moreover, given

that Respondent has been a licensed attorney for over 30 years, she has substantial

experience in the practice of law. In addition, the fact that she did not acknowledge Mr.

Foster’s termination of her services or refund him any portion of his $3,000 retainer fee

evinces an indifference to making restitution or rectifying the misconduct’s consequences.

Finally, her continued absence for the duration of this grievance process indicates a

likelihood of repetition of such misconduct.

This Court also considers certain mitigating factors when determining the

appropriate sanctions to impose in a grievance case. The following is a list of possible

mitigating factors:

[A]bsence of a prior disciplinary record; absence of a dishonest or selfish
motive; personal or emotional problems; timely good faith efforts to make
restitution or to rectify consequences of misconduct; full and free disclosure
to disciplinary board or cooperative attitude toward proceedings;
inexperience in the practice of law; character or reputation; physical or
mental disability or impairment; delay in disciplinary proceedings; interim
rehabilitation; imposition of other penalties or sanctions; remorse; and
finally, remoteness of prior offenses.

Attorney Grievance Commission v. Hodes, 441 Md. 136, 209 (2014) (citation omitted).

15
The Hearing Judge did not find the presence of any mitigating factors. Bar Counsel

notes that Respondent does not have any prior disciplinary history.

Considering Respondent’s conduct during Mr. Foster’s divorce proceedings and Bar

Counsel’s investigation, the appropriate sanction here is disbarment. As Petitioner

observes, “[t]his Court has disbarred attorneys who have engaged in similar conduct” as

Respondent. In De La Paz, we disbarred an attorney who never made an appearance in the

litigation for which he was retained, failed to adequately represent and communicate with

his client during the litigation, and failed to return the unearned portion of the fee his client

paid him. De La Paz, 418 Md. at 558. Similarly, in Attorney Grievance Commission v.

Fox, 417 Md. 504 (2010), we disbarred an attorney who abandoned his clients, made a

misrepresentation, and did not cooperate with Bar Counsel in the grievance process. Id. at

544–45. In Attorney Grievance Commission v. Yeatman, 489 Md. 211 (2024), we disbarred

an attorney who abandoned his clients, failed to respond to Bar Counsel’s request for

information, and had several aggravating factors found against him. Id. at 241.

Here, Respondent’s lack of communication with her client, her complete

abandonment of his case for four months, her lack of acknowledgment of his termination

of services, her unwillingness to refund the unearned portion of the fee she was paid, and

her total absence during Petitioner’s investigation merits disbarment.

V.

CONCLUSION

For the reasons discussed above, we conclude that Respondent violated Rules 1.1

(Competence), 1.3 (Diligence), 1.4 (Communication), 1.5(a) (Fees), 1.15(c) (Safekeeping

16
Property), 1.16(d) (Declining or Terminating Representation), 8.1(b) (Bar Admission and

Disciplinary Matters), and 8.4(a) and (d) (Misconduct), and order that Respondent be

disbarred.

IT IS SO ORDERED; RESPONDENT
SHALL PAY ALL COSTS AS TAXED BY
THE CLERK OF THIS COURT,
INCLUDING COSTS OF ALL
TRANSCRIPTS, PURSUANT TO
MARYLAND RULE 19-709 FOR WHICH
SUM JUDGMENT IS ENTERED IN FAVOR
OF THE ATTORNEY GRIEVANCE
COMMISSION AGAINST JUDITH MARIE
HAMILTON.

17

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Federal and State Courts
Filed
January 27th, 2026
Instrument
Enforcement
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Legal professionals
Geographic scope
National (US)

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Attorney Ethics Professional Conduct

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