In re Fitzpatrick
CourtDistrict of Columbia Court of Appeals
Date FiledOctober 8, 2026
Docket26-BG-0632
StatusPublished
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DISTRICT OF COLUMBIA COURT OF APPEALS
No. 26-BG-0632
IN RE ROBERT B. FITZPATRICK, RESPONDENT.
A Retired Member of the Bar
of the District of Columbia Court of Appeals
(Bar Registration No. 40410)
On Report and Recommendation
of the Board on Professional Responsibility
(BDN No. 23-BD-035; DDN No. 2019-D201)
(Decided October 8, 2026)
Before BECKWITH and SHANKER, Associate Judges, and THOMPSON, Senior
Judge.
PER CURIAM: The Board on Professional Responsibility recommends that
Robert B. Fitzpatrick be suspended from the practice of law for sixty days with
reinstatement conditioned upon a showing of fitness based on its finding that he
violated D.C. R. Pro. Conduct 1.15(a) & (c), 1.16(d), and 8.4(d).1 Respondent has
not filed any exceptions to the Board’s Report and Recommendation.
1
We grant the Board’s consent motion for leave to supplement the record with
the video recording of the Board oral argument, and the Clerk is directed to file the
recording as a supplemental record.
2
Under D.C. Bar R. XI, § 9(h)(2), “if no exceptions are filed to the Board’s
report, the [c]ourt will enter an order imposing the discipline recommended by the
Board upon the expiration of the time permitted for filing exceptions.” See In re
Viehe, 762 A.2d 542, 543 (D.C. 2000) (per curiam) (“When . . . there are no
exceptions to the Board’s report and recommendation, our deferential standard of
review becomes even more deferential.”). Because no exceptions have been filed
and we agree that the Board’s recommended sanction is reasonable and appropriate
for the violations presented here,2 we accept the recommendation that respondent be
suspended for sixty days with reinstatement conditioned on demonstrating fitness to
practice law. Accordingly, it is
ORDERED that respondent Robert B. Fitzpatrick is hereby suspended from
the practice of law in this jurisdiction for sixty days, with reinstatement conditioned
on demonstrating fitness to practice law. Respondent’s attention is directed to the
requirements of D.C. Bar R. XI, § 14, and their effect on eligibility for reinstatement.
See D.C. Bar R. XI, § 16(c).
2
See, e.g., In re Toppelberg, 906 A.2d 881, 881-82 (D.C. 2006) (per curiam)
(imposing sixty-day suspension, with thirty days held in abeyance in favor of one
year of supervised probation, for violations of multiple disciplinary rules including
D.C. R. Pro. Conduct 1.15(a) and 8.4(d)); In re Burnett, 878 A.2d 1291, 1292 (D.C.
2005) (per curiam) (imposing thirty-day suspension with fitness requirement for
misconduct including violation of D.C. R. Pro. Conduct 8.4(d)).
3
So ordered.