In re Zentz

under the rules of a tribunal); 5.5(b) (unauthorized practice of law), 8.4(a)' (inducing or assisting another to violate rules of professional conduct), 8.4(c) (dishonesty), and 8.4(d) (conduct prejudicial -to the administration of justice). Attorney Grievance Comm’n v. Zentz, 371 Md. 152 , 807 A.2d 48 (2002). The sanctions arose in essence from respondent haying assisted a disbarred attorney in filing papers in the United States Bankruptcy Court. On April 23, 2003, the United States District Court for the District of Maryland (“Maryland District Court”) reprimanded respondent based on the same misconduct disciplined by the Court of Appeals of Maryland. The Maryland District Court also barred him from practice before any Bankruptcy Court of the United States. Respondent consented to the discipline.! On October 1, 2004, Bar Counsel reported the discipline imposed by the Court of Appeals of Maryland. On November 2, 2004, Bar Counsel reported the Maryland District Court discipline.^[1] On October 13, 2004 and November 15, 2004, this court issued orders directing Bar Counsel to inform the Board of her position regarding reciprocal discipline or whether to proceed de novo. Bar Counsel recommended the functionally equivalent reciprocal discipline of a public censure for both matters. Respondent has not filed a response nor participated in these proceedings. On January 5, 2006, this court consolidated sua sponte both matters.

In its report and recommendation, the Board found that the record supported the imposition of reciprocal discipline. In cases like this, where neither Bar Counsel nor the respondent opposes reciprocal discipline, “ ‘the most the Board should consider itself obliged to do ... is to review the foreign proceeding sufficiently to satisfy itself that no obvious miscarriage of justice would result in the imposition of identical discipline — a situation that we anticipate would rarely, if ever, present itself.’ ” In re Childress, 811 A.2d 805 , 807 (D.C.2002) (quoting In re Spann, 711 A.2d 1262 , 1265 (D.C.1998)). Here, there was no miscarriage of justice in the Maryland proceedings as the record reveals that respondent was not denied due process and respondent was represented by counsel when he voluntarily consented to both disciplines. The Board also noted that the Maryland District Court order barring respondent from practice before all United States Bankruptcy Courts should not be the discipline upon which this reciprocal discipline is based as it does not fall within the range of sanctions imposed in this jurisdiction for similar misconduct.^[2] Further, this court has held that censure in the District of Columbia is the functional equivalent of a reprimand by the Maryland Court of Appeals. See, e.g., In re Miller, 883 A.2d 105 (D.C.2005); In re Bridges, 805 A.2d 233 , 234 (D.C.2002); In re Greenberg, 762 A.2d 42 , 42 (D.C.2000) (per curiam).