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Robert P. Meehan (Disbarred)

Robert P. Meehan of Philadelphia voluntarily tendered his unconditional resignation from the practice of law due to his involvement in one of the most disturbing factual scenarios to present itself in a Disciplinary Board matter in a number of years. Meehan was sentenced to a two- to four-year prison term last December, after he pleaded guilty to statutory sexual assault, promoting prostitution of a minor, and corrupting the morals of a minor.

Meehan engaged in sex in his office with a 14-year-old girl who was held hostage and prostituted by a couple Meehan had previously represented. The girl identified Meehan from his name on the office and described the layout of the office to the police. The girl told investigators Meehan offered her “Irish potatoes” Meehan's wife had made for the office. Meehan bragged of liking young girls and told the victim he had previously had sex with a 12-year-old. Meehan was fired from the firm that previously bore his name after he was indicted and turned himself into the police in 2014.

Meehan's voluntary resignation acknowledged his conviction constitutes a per se grounds for discipline under Pennsylvania Rule of Disciplinary Enforcement 203(b)(1). Pursuant to Pa. R.D.E. 203(b)(1), any conviction of a crime is grounds for discipline.

Jamie Ray-Leonetti (Suspended)

Ray-Leonetti of Philadelphia was suspended for a year and a day on consent. Ray-Leonetti accepted representation of a medical malpractice plaintiff. She filed the matter, but did not file a complaint. The matter was scheduled for an arbitration hearing. Ray-Leonetti rescheduled the arbitration twice, but did not appear at the second rescheduled arbitration date. Ray-Leonetti informed the client the arbitration was rescheduled, which was not true. A judgment of non-pros was entered when Ray-Leonetti and her clients did not appear for the arbitration. Following the entry of non-pros, Ray-Leonetti engaged in a lengthy course of deceptive conduct which included a number of false statements to her clients about an alleged settlement of the matter.

The Disciplinary Board found Ray-Leonetti violated Rules of Professional Conduct 1.3, 1.4(a)(3), 1.4(b), 4.1(a), and 8.4(c). Rule 1.3 requires an attorney to act with reasonable diligence and promptness in representing a client. Rule 1.4 requires an attorney to communicate the information necessary for the client to make informed decisions regarding the representation. Rule 4.1 prohibits lawyers from knowingly making false statements of material fact or law to a third person. Rule 8.4 states it is professional misconduct for a lawyer to engage in conduct involving dishonesty, fraud, deceit or misrepresentation.

The Disciplinary Board found Ray-Leonetti's conduct was mitigated due to complex post-traumatic stress disorder. She was able to establish a causal connection between her medical condition and the ethical violations. The Disciplinary Board also noted Ray-Leonetti admitted to her conduct, was remorseful, and cooperated with the board as evidenced by her admissions and consent to receiving a suspension of a year and a day.

Ray-Leonetti had a history of prior discipline which consisted of a private reprimand for failure to diligently pursue an employment discrimination case and failure to keep the client informed. In the previous matter, Ray-Leonetti had also made multiple misrepresentations regarding the status of her client's case.

The redacted psychiatric report filed with the opinion suggests Ray-Leonetti's psychological condition was at least in part due to a stressful work environment. Ray-Leonetti's described symptoms included auditory hallucinations of her former employer's voice.

Nichole A. Collins (Disbarred)

Collins was alleged to have engaged in a pattern of conduct which included writing checks from her firm's “costs account” to obtain cash for her personal use. The firm alleged Collins also overstated amounts received on commissions and double-billed for alleged client services. Collins acknowledged some of the allegations were correct but denied others. The temporary suspension was entered pursuant to Pa. R.D.E. 208(f)(1) which permits Disciplinary Counsel with the concurrence of a member of the board to enter emergency temporary suspension orders upon petition to the Supreme Court for injunctive relief. Collins subsequently voluntarily resigned from the Bar of the commonwealth of Pennsylvania.

Wayne D. Bozeman (Reinstated)

In 2011, Bozeman was suspended on consent for a period of five years, retroactive to a period of temporary suspension beginning in December 2009. Prior to becoming an attorney, Bozeman worked in business for nearly thirty years. While working for a company called Advanced Game Concepts, Inc. Bozeman filed false income tax returns prepared by disbarred attorney Bernard J. Bagdis. On June 17, 2008, Bagdis and 11 other defendants, including Bozeman, were charged with tax crimes. Bozeman entered a guilty plea to one count of conspiracy to defraud the United States of taxes and was sentenced to 22 months in prison and three years of supervised release.

After his release, Bozeman worked as a paralegal with an attorney with whom he was associated with prior to the suspension of his license. The work Bozeman performed was not for the attorney he was formerly associated with, but he worked with and was paid through the attorney he was formerly associated with. Bozeman also did not timely file notices of engagement with the Disciplinary Board for the work he was performing as a paralegal.

In September 2014, Bozeman filed an initial petition for reinstatement. Following a hearing, the hearing committee recommended the initial petition be denied. The board found Bozeman violated Pa. R.D.E. 217(j)(4). Pa. R.D.E. 217(j)(4)(i) specifically prohibits a formerly admitted attorney from performing any law-related activity for a law firm, organization or lawyer with which the formerly admitted attorney was associated on or after the date on which the acts which resulted in the disbarment or suspension occurred.

Shortly after the hearing committee filed its report recommending the initial petition be denied, Bozeman ceased working as a paralegal with the attorney he had previously been associated with. Bozeman also started working for an animal rescue charity and a nonprofit associated with his church.

Bozeman testified credibly that he accepted responsibility for his criminal acts. Bozeman accepted his original petition for reinstatement was appropriately denied, and testified about the steps he took to correct the reasons for the denial. The Disciplinary Board noted the tax offence was unrelated to Bozeman's practice of law. While in prison, Bozeman used his free time to teach other inmates how to conduct legal research. Bozeman presented the testimony of four witnesses. Bozeman's former law professor who hired Bozeman to assist in cases testified as to the quality of his legal work. Bozeman's wife of 48 years testified regarding his repentance and the change in his priorities brought about by his conviction and incarceration. A neighbor testified about Bozeman's changed priorities since his conviction and incarceration. Another neighbor, and parish services director for his church, testified Bozeman had become caring and had a passion to help people. The Office of Disciplinary Counsel did not oppose the reinstatement.

The Disciplinary Board found Bozeman demonstrated by clear and convincing evidence that he had the moral qualifications, competency and learning in the law required for admission to the bar, and that the resumption of the practice of law will not be detrimental to the integrity of the bar or the administration of justice, nor subvert the public interest. The Disciplinary Board recommended reinstatement, and reinstatement was granted on March 19, 2018.

The Bozeman matter is a good roadmap to reinstatement following a suspension for serious crimes. Bozeman accepted responsibility for his actions and took concrete steps to address each of the issues raised by the Disciplinary Board and Office of Disciplinary Counsel. Bozeman was able to establish a significant change in outlook and priorities from the person he was when his unlawful acts occurred.

Josh J.T. Byrne, a partner in Swartz Campbell's professional liability group in the firm's Philadelphia office, is also co-chair of the Philadelphia Bar Association's professional guidance committee and the incoming chair of the Pennsylvania Bar Association's professional liability committee.