Office of Chief Disciplinary Counsel v. Vena

Citations

• 236 Conn. App. 39

Syllabus

The respondent attorney appealed from the trial court's judgment sus- pending him from the practice of law in Connecticut for five years as reciprocal discipline to his suspension from the practice of law in Virginia for five years for engaging in the unauthorized practice of law. He claimed, inter alia, that the court lacked authority to suspend him for five years pursuant to the rule of practice (§ 2-39) because he was not a member of the Virginia bar and, thus, the discipline was not reciprocal. Held: The trial court had subject matter jurisdiction over the attorney discipline brought pursuant to Practice Book § 2-39, as that rule plainly outlines the court's authority to hear and determine whether discipline is appropriate for attorneys admitted in Connecticut and disciplined in another jurisdiction, and the respondent provided no analysis to support his claim that the court lacked authority because he was not admitted to practice in Virginia. The respondent's unpreserved claim that the trial court's imposition of reciprocal discipline against him violated his right to due process failed under the third prong of State v. Golding (213 Conn. 233), as he failed to establish a constitutional violation that deprived him of a fair trial. The trial court's finding that the respondent failed to demonstrate by clear and convincing evidence that the Virginia proceedings against him were so lacking in notice or opportunity to be heard that it would constitute a grave injustice to impose commensurate discipline in Connecticut was not clearly erroneous. The trial court did not abuse its discretion by suspending the respondent from the practice of law in Connecticut for a period of five years, as it fell within the discipline warranted under Practice Book § 2-39. Argued May 20—officially released October 28, 2025