About the Author

Shirley M. Watts

Shirley M. Watts

Judge, Court of Appeals of Maryland


Issue: What sanction, if any, should the Court impose upon an attorney who claimed to have exercised his right to free speech when he called his female client a "C*NT" in a letter that contained other inappropriate insults?

Holding: Finding no First Amendment protection for a lawyer who verbally assaulted his client in letters containing egregiously unprofessional language, the Court reprimanded him for violating the Maryland Lawyers' Rules of Professional Conduct through conduct that tends to bring the legal profession into disrepute.

Alleged Violations: Maryland Lawyers' Rules of Professional Conduct 8.4(d) (Conduct That is Prejudicial to the Administration of Justice).

Citation:441 Md. 703 (2015)