In the Matter of a Member of the Bar of the Supreme Court of Delaware
CourtSupreme Court of Delaware
Date FiledAugust 18, 2026
Docket97, 2026
StatusPublished
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Full Opinion
IN THE SUPREME COURT OF THE STATE OF DELAWARE
IN THE MATTER OF A MEMBER §
OF THE BAR OF THE SUPREME § No. 97, 2026
COURT OF DELAWARE:
Board Case No. 117282-B
GABRIEL A. DILEONARDO, SR.,
CO? Or Or Kr Or
Respondent.
Submitted: August 11, 2026
Decided: August 18, 2026
Before SEITZ, Chief Justice; TRAYNOR and GRIFFITHS, Justices.
ORDER
A panel of the Board on Professional Responsibility (“the Board”) filed
a Report and Approval of Conditional Admission and Order of Discipline by
Consent pursuant to Rules 9(d) and 17(c) of the Lawyers’ Rules of
Disciplinary Procedure (“Report”). Having reviewed the matter under Rule
9(e), the Court approves the Report.
NOW, THEREFORE, IT IS ORDERED that the Board’s Report (copy
attached) is APPROVED. This matter is CLOSED.
BY THE COURT:
/s/ Collins J. Seitz, Jr.
Chief Justice
BOARD ON PROFESSIONAL RESPONSIBILITY
OF THE SUPREME COURT OF THE STATE OF DELAWARE
In the Matter of a
Member of the Bar of
the Supreme Court of
Delaware:
CONFIDENTIAL
GABRIELA. DILEONARDO, SR., Board Case No. 117282-B
Name Nee Nee ee ee ee” eee” eee”
Respondent.
REPORT AND APPROVAL OF CONDITIONAL ADMISSION
AND ORDER OF DISCIPLINE BY CONSENT
1. Pending before a panel of the Board on Professional Responsibility (the
“Board”) is a Petition for Discipline in Board Case No. 117282-B (the
“Petition”) involving Gabriel A. DiLeonardo, Sr., Esquire (the
“Respondent”), a member of the Bar of the Supreme Court of the State of
Delaware at all times relevant hereto, having been admitted to practice in
Delaware on September 6, 2018 (Bar ID No. 6524).
2. The Petition, which charges the Respondent with violations of Rules 1.15, 5 3,
8.1, and 8.4 of the Delaware Lawyers’ Rules of Professional Conduct (the
“DLRPC”) arising out of his handling of the books, records, and the attorney
trust account of DiLeonardo Law LLC, is hereby incorporated by reference
into the Board’s record in this matter.
3. The Office of Disciplinary Counsel (the “ODC”) has submitted to the Board
a Conditional Admission notarized by the Respondent and signed by
Respondent’s counsel, and an accompanying Affidavit of Gabriel A.
DiLeonardo, Sr. (“Affidavit”), pursuant to Rule 17 of the Delaware Lawyers’
Rules of Disciplinary Procedure (the “Procedural Rules”). The Respondent
conditionally admits the following Counts of the Petition:
a. Count I: On at least eight (8) occasions, the Respondent failed to
safeguard client funds when he disbursed funds from his lawyer trust
account on behalf of one client that relied, in part, on another clients’
trust funds, in violation of DLRPC 1.15(a) (Conditional Admission § 1;
Aff. 7 1);
. Count If: The Respondent failed to properly maintain the books and
records of DiLeonardo Law LLC from September 2023 until March
2026, in violation of DLRPC 1.15(d) (Conditional Admission 2; Aff.
12);
. Count IV: On at least four (4) occasions, the Respondent disbursed
funds from his trust account in excess of those received for a particular
client, in violation of DLRPC 1.15(d)(12)(C) (Conditional Admission
q 3; Aff. ¥ 3);
. Count V: The Respondent failed to properly supervise nonlawyer
assistants related to properly maintaining the books and records of
DiLeonardo Law LLC, in violation of DLRPC 5.3 (Conditional
Admission § 4; Aff. ¥ 4);
. Count VIII: The Respondent made negligent misrepresentations
regarding the status of DiLeonardo Law LLC’s books and records on
his 2024 Certificate of Compliance, which was submitted to the
Delaware Supreme Court, in violation of DLRPC 8.4(c) (Conditional
Admission 4 5; Aff. J 5);
. Count IX: The Respondent negligently made misrepresentations
regarding the status of DiLeonardo Law LLC’s books and records on
his 2025 Certificate of Compliance, which was submitted to the
Delaware Supreme Court, in violation of DLRPC 8.4(c) (Conditional
Admission { 6; Aff. 6);
. Count XI: The Respondent negligently made misrepresentations
regarding the status of DiLeonardo Law LLC’s books and records on
his 2024 Certificate of Compliance submitted to the Delaware Supreme
Court, in violation of DLRPC 8.4(d) (Conditional Admission { 7; Aff.
q 7); and
. Count XII: The Respondent negligently made misrepresentations
regarding the status of DiLeonardo Law LLC’s books and records on
his 2025 Certificate of Compliance submitted to the Delaware Supreme
Court, in violation of DLRPC 8.4(d) (Conditional Admission { 8; Aff.
7 8).
. A description of the specific factual allegations and the Counts of the Petition
being conditionally admitted is set forth in the Respondent’s attached
Affidavit, which constitutes an affidavit of consent under Procedural Rule
17(b).
. The ODC has agreed to the Conditional Admission, including the proposed
disciplinary sanction and the enumerated conditions and procedures described
in paragraphs 7-9 below. (Conditional Admission { 14.)
. In exchange for the Conditional Admission, and subject to approval by both
the Board and the Delaware Supreme Court, the ODC has agreed to dismiss,
with prejudice, Counts II, VI, VII, and X of the Petition. (Conditional
Admission § 10.)
. In light of the foregoing admitted violations, pursuant to Procedural Rule
8(a)(2), the Respondent agrees to a sanction of suspension for a period of six
(6) months and one (1) day. (Conditional Admission { 11; Aff. ¥ 9.)
. Following the period of suspension, the Respondent may petition for
reinstatement pursuant to Procedural Rule 22. (Conditional Admission § 12.)
. The Respondent has further agreed to accept, pursuant to Procedural Rules
8(a)(10) and 8(b), the following additional conditions:
a. Pursuant to Procedural Rule 27, the Respondent shall pay all costs
associated with these proceedings, promptly upon presentation of a
statement by the ODC;
b. The Respondent shall fully cooperate in good faith with a receiver,
appointed pursuant to Procedural Rule 24, for the winddown of his
current Delaware law practice(s);
c. The Respondent may not serve as the managing partner of a Delaware
law firm nor be the Delaware lawyer in charge of books and records for
a period of one (1) year after reinstatement;
d. The Respondent shall notify the ODC within thirty (30) days if, at any
point after one (1) year from reinstatement, he begins serving as the
managing partner of a Delaware law firm and/or he becomes the
Delaware lawyer in charge of books and records; and
e. The Respondent shall, for the two (2) years following his becoming the
Delaware lawyer in charge of books and records, have completed a pre-
certification by a licensed certified public accountant approved by the
Lawyers’ Fund for Client Protection and shall promptly provide the
pre-certification report to the ODC.
(Conditional Admission § 13; see also Aff. § 9 (agreeing to accept “the
conditions as set forth in the Conditional Admission’’).)
10.The undersigned Panel convened on July 29, 2026 to consider whether to
approve the Conditional Admission and proposed sanction pursuant to
Procedural Rule 17(c). The Panel deemed admitted into the record solely for
the purposes of the Procedural Rule 17(c) hearing, and subject to the terms
articulated on the record during the hearing, the following documents:
a. The Petition and ODC’s Exhibits A-JJ;
b. The Respondent’s Answer to the Petition and Respondent’s Exhibits
A-T;
c. the Conditional Admission; and
d. the Affidavit.
11.At the hearing, the Panel heard argument from ODC and counsel for the
Respondent, as well as a statement from the Respondent, concerning the
admissions and the proposed disciplinary sanction, and questioned ODC
concerning the circumstances giving rise to the Petition and the Conditional
Admission. The Panel also confirmed with Respondent under oath his
agreement to the terms of the Conditional Admission and the proposed
sanction, including that his agreement to both was made knowingly, freely
and voluntarily, after discussing the terms and potential consequences with
his Delaware counsel.
12.Under Standard 4.12 of the ABA’s Standards for Imposing Lawyer Sanctions
(the “ABA Standards”), “[s]uspension is generally appropriate where a lawyer
knows or should know that he is dealing with client property and causes injury
or potential injury to a client.” Based on the Conditional Admission, the Panel
is satisfied that suspension is appropriate here, in the absence of any
ageravating or mitigating factors.
13.In reaching its conclusion as to the disciplinary sanction described herein, and
pursuant to Procedural Rule 8(c) and Standard 9.22 of the ABA Standards,
the Board considered as aggravating factors (which both the Respondent and
ODC agreed applied in this matter): (a) a pattern of misconduct; (b) multiple
offenses; and (c) the Respondent’s refusal to acknowledge the wrongful
nature of the conduct. (Conditional Admission § 15.) The Board also
considered other potential aggravating factors identified in Standard 9.22, but
determined that none applied.
14.In reaching the foregoing conclusion as to the disciplinary sanction described
herein, and pursuant to Procedural Rule 8(c) and Standard 9.32 of the ABA
Standards, the Board considered as a mitigating factor (which both the
Respondent and ODC agreed applied to this matter) the absence of a prior
disciplinary record. (Conditional Admission § 16.) The Board also
considered other potential mitigating factors identified in Standard 9.22, but
determined that none applied. The Panel determined that the aggravating
factors and the mitigating factor did not compel a sanction more or less severe
than the sanction agreed upon by the parties.
15.In considering the proposed sanction, the Board noted that the agreed upon
suspension was consistent with precedent from the Delaware Supreme Court
for similar violations. See In re Beauregard, 189 A.3d 1236, 1252-53 (Del.
2018); In re Bailey, 821 A.2d 851, 867 (Del. 2003).
16.Having carefully and duly considered all of the issues related to this matter,
the Board is satisfied that the disciplinary sanction provided for in the tendered
Conditional Admission, as described above, is adequate and appropriate in
light of the admissions in, and terms of, the Conditional Admission.
WHEREFORE, IT IS HEREBY ORDERED THAT:
1. The tendered Conditional Admission is hereby approved and accepted,
pursuant to Procedural Rule 17, and the Conditional Admission and the
attached Affidavit are hereby incorporated by reference.
2. In resolution of Counts I, I, IV, V, VI, [X, XI, and XII of the Petition,
the Board hereby imposes the sanction of a suspension for a period of six (6)
months and one (1) day, pursuant to Procedural Rule 8(a)(2), together with
the additional conditions set forth in Paragraph 9 above, grounded upon the
Respondent’s admissions that he violated the DLRPC corresponding to each
of these Counts. Following the period of suspension, the Respondent may
petition for reinstatement pursuant to Procedural Rule 22.
3. In resolution of Counts II, VI, VU, and X of the Petition, the Board hereby
dismisses such Counts with prejudice as part of its acceptance and approval
of the Conditional Admission and this Order of Discipline by Consent.
4. The Board’s imposition of such sanction is subject to the conditions set
forth herein, which, if not complied with, shall be grounds under Procedural
Rule 7 for further disciplinary action against the Respondent.
5. Pursuant to Procedural Rule 27 and as described in Paragraph 9(a) above,
the Respondent shall pay all costs associated with these proceedings.
6. The Board considers all issues surrounding this disciplinary matter to be
resolved by this Report and Order of Discipline by Consent, subject to review
by the Delaware Supreme Court pursuant to Procedural Rule 9(e).
BOARD ON PROFESSIONAL RESPONSIBILITY
Arthur R. Bookout, Esquire (Chair)
ban Ads
Michael L. Vild, Esquire
Kristen Voris Kulpers
Dated: “6 /_!\ /e2rL