On September 19, 2023, Angelique Layton Anderson, an attorney licensed to practice law in New Jersey, was suspended from the practice of law for a period of one year by the Supreme Court of New Jersey due to unethical conduct that violated various rules of professional conduct.
The case is entitled “In the Matter of Angelique Layton Anderson,” with case no. 088260.
The case began with a motion for reciprocal discipline filed by the Office of Attorney Ethics (OAE) against Anderson, who was admitted to practice law in New Jersey, the District of Columbia, and Colorado. The OAE alleged that Anderson had violated the equivalents of New Jersey RPC 1.1(a) (three instances), RPC 1.4(b), RPC 1.4(c), RPC 1.5(b), RPC 3.1, RPC 3.4(b), RPC 3.4(d), RPC 8.1(a), RPC 8.4(c), and RPC 8.4(d) (two instances).
Anderson was accused of engaging in gross neglect, failing to communicate with her client, failing to explain a matter to the extent reasonably necessary to permit the client to make informed decisions regarding the representation, falsifying evidence, failing to comply with pre-trial discovery requests, making a false statement of material fact to disciplinary authorities, engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation, and engaging in conduct prejudicial to the administration of justice.
The alleged misconduct occurred during Anderson’s representation of a client in a highly contentious matrimonial matter in Colorado. Anderson substituted as counsel for the client and filed a request for review of the district court’s order, which was construed as a request for an extension of time to file a petition for review.
Anderson filed the petition six days after the deadline, claiming that the district court’s order did not specify a deadline for filing the petition. The Supreme Court of New Jersey’s Disciplinary Review Board granted the OAE’s motion for reciprocal discipline and determined that a one-year suspension was the appropriate quantum of discipline for Anderson’s misconduct.
The Board noted that Anderson had previously been suspended for six months in Colorado for violating Colo. RPC 1.5(b) (failing to set forth in writing the basis or rate of the legal fee), Colo. RPC 1.7 (engaging in a concurrent conflict of interest), and Colo. RPC 1.8(e) (providing financial assistance to a client in connection with pending or contemplated litigation).
Anderson’s personal interest in obtaining the client’s tax refund created a significant risk of materially limiting her representation, in violation of Colo. RPC 1.7. The Board found that Anderson’s misconduct in Colorado, including her failure to pay her annual assessment to the New Jersey Lawyers’ Fund for Client Protection, warranted a harsher sanction than the six-month suspension imposed in Colorado.
The Supreme Court of New Jersey, in its decision dated September 19, 2023, adopted the Disciplinary Review Board’s recommendation and suspended Anderson from the practice of law for a period of one year, effective October 19, 2023. The Court also ordered Anderson to comply with Rule 1:20-20 dealing with suspended attorneys and to reimburse the Disciplinary Oversight Committee for appropriate administrative costs and actual expenses incurred in the prosecution of this matter, as provided in Rule 1:20-17.
The Court further ordered that the entire record of this matter be made a permanent part of Anderson’s file as an attorney at law of this State. Additionally, the Court found that Anderson’s failure to comply with the Affidavit of Compliance requirement of Rule 1:20-20(b)(15) may preclude the Disciplinary Review Board from considering Anderson’s petition for reinstatement for a period of up to six months from the date Anderson files proof of compliance, and may also be found to constitute a violation of RPC 8.1(b) and RPC 8.4(d) and provide a basis for an action for contempt pursuant to Rule 1:10-2.
According to Avvo, Ms. Anderson practices in Louisville, Colorado. She acquired her law license in New Jersey in 1989.
A copy of the original filing can be found here.
