In Re: Quiana Marie Hunt

Supreme Court of Louisiana
March 14, 2023
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
IN RE: QUIANA MARIE HUNT
No. 2022-B-01792
_ _
_ _ _ _
I
N RE: Disciplinary Counsel - Applicant Other; Findings and Recommendations
(Formal Charges);
_ _ _ _ _ _
March 14, 2023
Suspension imposed. See per curiam.
Crichton, J., dissents and assigns reasons.
JBM
JLW
JDH
JTG
WJC
PDG
03/14/2023 "See News Release 013 for any Concurrences and/or Dissents."

S
UPREME COURT OF LOUISIANA
NO. 2022
-B-1792
I
N RE: QUIANA MARIE HUNT
AT
TORNEY DISCIPLINARY PROCEEDING
P
ER CURIAM
This disciplinary matter arises from formal charges filed by the Office of
Disciplinary Counsel (“ODC”) against respondent, Quiana Marie Hunt, an attorney
licensed to practice law in Louisiana but currently ineligible.
FO
RMAL CHARGES
The Probation Violation Matter
In November 2019, respondent was suspended from the practice of law for
one year and one day, fully deferred, subject to two years of supervised probation
with conditions, for mishandling her trust account and failing to cooperate with the
ODC in its investigation. In re: Hunt, 19 -1412 (La. 11/12/19), 282 So. 3d 213
(“Hunt I”). On January 2, 2020, respondent executed a probation contract, which
required her to: (1) comply with her annual professional obligations; (2) promptly
notify the ODC of any change of address during the probationary period; and (3)
respond to all requests by, and make herself reasonably available for conference
with, the ODC.
On June 18, 2021, during her probationary period, respondent was certified
ineligible to practice law for failing to comply with mandatory continuing legal
education requirements. On June 25, 2021, also during her probationary period,
respondent was certified ineligible to practice law for failing to pay the costs
associated with her discipline in Hunt I . On October 1, 2021, again during her
03/14/23

2

probationary period, respondent was certified ineligible to practice law for failing to
file her annual trust account disclosure form.
The ODC made several attempts to contact respondent via telephone, email,
regular mail, and personal service regarding her ineligibility. However, the ODC’s
attempts were unsuccessful.

The Morgan Matter
On February 11, 2022, the ODC received a disciplinary complaint against
respondent from her client, Patricia Morgan. Ms. Morgan alleged that she had been
trying to contact respondent via telephone, text messages, and social media with no
success. Between February 23, 2022 and April 28, 2022, the ODC made several
attempts to notify respondent of Ms. Morgan’s complaint via certified mail, regular
mail, email, and telephone. These attempts were unsuccessful, and respondent never
submitted a response to the complaint or otherwise cooperated with the ODC’s
investigation.

DISCIPLINARY PROCEEDINGS
In June 2022, the ODC filed formal charges against respondent, alleging that
her conduct, as set forth above, violated the fol lowing provisions of the Rules of
Professional Conduct: Rules 1.1(b) (failure to comply with MCLE requirements),
1.1(c) (failure to comply with professional obligations), 8.1(b) (knowing failure to
respond to a lawful demand for information from a discipli nary authority), 8.1(c)
(failure to cooperate with the ODC in its investigation), and 8.4(a) (violation of the
Rules of Professional Conduct).
Respondent failed to answer the formal charges. Accordingly, the factual
allegations contained therein were deem ed admitted and proven by clear and
convincing evidence pursuant to Supreme Court Rule XIX, § 11(E)(3). No formal

3

hearing was held, but the parties were given an opportunity to file with the hearing
committee written arguments and documentary evidence on the issue of sanctions.
Respondent filed nothing for the hearing committee’s consideration.

Hearing Committee Report
After considering the ODC’s deemed admitted submission, the hearing
committee determined that the record supports the deemed admitted facts. Based on
these facts, the committee determined respondent violated the Rules of Professional
Conduct as alleged in the formal charges.
The committee then determined respondent knowingly violated duties owed
to the legal profession. Her conduct cause d actual harm to the disciplinary system
and potential harm to her clients. After considering the ABA’s Standards for
Imposing Lawyer Sanctions , the committee determined the baseline sanction is
suspension.
The committee found the following aggravating f actors present: a prior
disciplinary record, a pattern of misconduct, and bad faith obstruction of the
disciplinary proceeding by intentionally failing to comply with the rules or orders of
the disciplinary agency. The committee found no mitigating factors present.
After further considering this court’s prior case law addressing similar
misconduct, the committee recommended respondent be suspended from the
practice of law for one year and one day.
Neither respondent nor the ODC filed an objection to the committee’s report.
Therefore, pursuant to Supreme Court Rule XIX, § 11(G), the disciplinary board
submitted the committee’s report to the court for review.

4

DISCUSSION
Bar disciplinary matters fall within the original jurisdiction of this court. La.
Const. art. V, § 5(B). Consequently, we act as triers of fact and conduct an
independent review of the record to determine whether the alleged misconduct has
been proven by clear and convincing evidence. In re: Banks, 09-1212 (La. 10/2/09),
18 So. 3d 57.
In cases in which the lawyer does not answer the formal charges, the factual
allegations of those charges are deemed admitted. Supr eme Court Rule XIX, §
11(E)(3). Thus, the ODC bears no additional burden to prove the factual allegations
contained in the formal charges after those cha rges have been deemed admitted.
However, the language of § 11(E)(3) does not encompass legal conclusions that flow
from the factual allegations. If the legal conclusion the ODC seeks to prove (i.e., a
violation of a specific rule) is not readily apparent from the deemed admitted facts,
additional evidence may need to be submitted in order to prove the legal conclusions
that flow from the admitte d factual allegations. In re: Donnan , 01 -3058 (La.
1/10/03), 838 So. 2d 715.
The record in this deemed admitted matter supports a finding that respondent
failed to fulfill her professional obligations, failed to pay costs associated with a
prior disciplinary matter, and failed to cooperate with the ODC in two investigations.
Based upon these facts, respondent has violated the Rules of Professional Conduct
as charged.
Having found evidence of professional misconduct, we now turn to a
determination of the appropriate sanction for respondent’s actions. In determining
a sanction, we are mindful that disciplinary proceedings are designed to maintain
high standards of conduct, protect the public, preserve the integrity of the profession,
and deter future miscon duct. Louisiana State Bar Ass’n v. Reis, 513 So. 2d 1173
(La. 1987). The discipline to be imposed depends upon the facts of each case and

5

the seriousness of the offenses involved considered in light of any aggravating and
mitigating circumstances. Louisiana State Bar Ass’n v. Whittington, 459 So. 2d 520
(La. 1984).
Respondent violated duties owed to her clients and the legal profession,
causing actual harm to the disciplinary system and potential harm to her clients. In
light of her prior disciplinary history, she acted knowingly, if not intentionally. We
agree with the hearing committee that the baseline sanction is suspension. Based
upon the record submitted, we agree with the committee’s finding of aggravating
factors as well as its finding that no mitigating factors are present.
Turning to the issue of an appropriate sanction, the instant matter presents an
almost identical factual scenario as the case of In re: Fahrenholtz , 09-0748 (La.
10/2/09), 18 So. 3d 751. In Fahrenholtz, an attorney was dec lared ineligible to
practice law for failure to pay his bar dues and the disciplinary assessment and
separately for failure to comply with MCLE requirements. He also failed to
cooperate with the ODC in two investigations. For this knowing, if not intentional,
misconduct, we suspended the attorney from the practice of law for one year and one
day. In light of Fahrenholtz and the aggravating factors present, we find the
committee’s recommended sanction is appropriate.
Accordingly, we will adopt the hearing committee’s recommendation and
impose a suspension from the practice of law for one year and one day.

DECREE
Upon review of the findings and recommendations of the hearing committee,
and considering the record, it is ordered that Quiana Marie Hunt, Louisiana Bar Roll
number 35835, be and she hereby is suspended from the practice of law for one year
and one day. All costs and expenses in the matter are assessed against respondent

6

in accordance with Supreme Court Rule XIX, § 10.1, with legal interest to
commence thirty days from the date of finality of this court’s judgment until paid.