Each September, the Attorney Grievance Commission publishes an annual report detailing the activities of the Commission and Bar Counsel. Last month, the Commission published its 50th Annual Report covering Fiscal Year 2025. Among the information provided, the report summarizes pertinent events within the AGC and the Office of Bar Counsel, identifies key personnel, and provides data regarding complaints made and discipline imposed by the Commission and the Supreme Court of Maryland.
The annual report also contains a financial summary and audited financial statements detailing the use of the Commission’s approximately $5,000,000 budget. Finally, the annual report also discusses other AGC and Bar Counsel activities such as conservatorships and targeted mail solicitations. The annual report is comprehensive and a worthwhile read for any member of the bar.
From my perspective, the most significant information is the data on attorney discipline. The annual report identifies the number of complaints, the number of matters docketed for further investigation, the number of attorneys disciplined and the primary reason for discipline and complaints. The Commission also summarizes the discipline imposed by the Commission and the Maryland Supreme Court during the year.
Regarding the number of complaints and matters docketed for further investigation, the number of files opened by the Office of Bar Counsel increased slightly, from 1,696 in FY 2024 to 1,760 in FY 2025. Of these, 210 (which is 12%, or approximately 1 in 8) matters were docketed for further investigation.
As a reminder, docketing a matter for further investigation is generally the next step in an investigation after the attorney responds to the initial complaint. While complaint numbers increased, the overall number of lawyers sanctioned remains fairly low. In FY 2025, 40 attorneys were sanctioned.
By comparison, the 10-year average for the number of attorneys disciplined is 69. Of the 40 lawyers disciplined in FY 2025, 12 were disbarred.
As for the reasons why lawyers were being investigated, the annual report separates matters by primary rule violation alleged, type of law and the primary reason for discipline. Of the 210 cases docketed in FY 2025, the primary rules alleged to have been violated are safekeeping property (Rule 1.15) with 35 matters and communication (Rule 1.4) with 26. Another 18 matters were docketed for diligence (Rule 1.3) and 17 more for competence (Rule 1.1).
Regarding the number of cases by law practice, family law and trust account issues led the way with 26 and 23, respectively. Personal injury and civil litigation were next, with 23 and 20 docketed matters. As for the reasons for discipline, criminal misconduct and “competence, diligence, communication and failure to abide by client decisions” led the way with 10 docketed matters each.
My takeaway from these numbers is that many complaints appear preventable. Indeed, there were 55 trust account overdraft notices which led to 18 docketed complaints. That should be basic accounting. Further, while no lawyer can guarantee a positive outcome, the annual report figures demonstrate that lawyers are far more likely to face a complaint for failing to follow fee and escrow rules or failing to talk to their clients than simply because of a bad outcome. My experience with discipline cases is consistent: There is likely something more than a bad outcome that leads to the filing of a complaint.
The Commission also reports on conservatorships. Md. Rule 19-734 authorizes Bar Counsel to file a Petition for Conservatorship when an attorney dies, disappears, has been disbarred, suspended, or transferred to disability inactive status, or is incapacitated or has abandoned the practice of law; there are open client matters; and there is no personal representative, partner, or other individual who is willing to conduct and capable of conducting the attorney’s client affairs. In these situations, Bar Counsel must file the Petition so someone else can manage the practice and wind it down. Last year, seven new conservatorships were established. All told, there were 37 pending conservatorships as of the end of the fiscal year.
I found the number of conservatorships to be surprising. Succession planning is an important part of a law practice, especially as one ages. As we age, we should consider enlisting a friend or colleague who can be available to step in, should the need arise.
Reading the report may also help remind lawyers that targeted mail solicitations should be filed with Bar Counsel. The good news is that none of the 409 targeted mail submissions required revisions to remedy violations of the Rules of Professional Conduct.
I suggest, therefore, that all Maryland lawyers take the time to visit the AGC’s website and read the Annual Report. It’s worth looking in the window.
This article originally appeared in The Daily Record on October 8, 2026.
Goodell DeVries defends various professionals in Maryland, the District of Columbia, and Virginia, including lawyers and law firms. Many of these cases are ethics matters involving Bar Counsel. If you have questions about the above or are a Maryland lawyer facing discipline, please contact us at EthicsHelp@gdldlaw.com.