About the Author

Shirley M. Watts

Shirley M. Watts

Judge, Court of Appeals of Maryland


Issue:  What is the proper sanction to impose upon (1) an attorney who "robo-signed" a large number of foreclosure-related documents, and upon (2) a managing attorney who took no effort to ensure that lawyers did not robo-sign documents and that notaries public did not falsely notarize documents?

Holding:  The Court reprimanded an attorney who "robo-signed" a large number of documents for engaging in conduct which is prejudicial to the administration of justice, together with his managing partner for failing to fulfill his responsibilities in supervising his attorneys and staff.

Alleged Violations: Maryland Lawyers’ Rules of Professional Conduct 5.1 (Responsibilities of Partners, Managers, and Supervisory Lawyers) and 5.3 (Responsibilities Regarding Nonlawyer Assistants); charging McDowell with violating MLRPC 5.2(a) (Responsibilities of a Subordinate Lawyer); and charging Burson and McDowell with violating MLRPC 1.1 (Competence) and 8.4 (Misconduct).

Citation:   439 Md. 26 (2014)