In the Matter of the Application of T. Z.-A. O. for Admission to the Bar of Maryland, Misc. 

No. 3, September Term, 2014 

BAR ADMISSION – DENIAL OF ADMISSION – Court of Appeals, upon 

consideration of unfavorable recommendations of Character Committee for Fifth Appellate 

Circuit and State Board of Law Examiners and independent review of record, held that 

applicant to Bar of Maryland had not met burden of proving that he possesses requisite 

moral character and fitness for admission to Bar of Maryland because applicant: (1) had 

demonstrated consistent pattern of financial irresponsibility; and (2) completed and signed 

car loan application which included false financial information and failed to include 

information about recent bankruptcy. 
IN THE COURT OF APPEALS

OF MARYLAND 

Misc. No. 3

September Term, 2014 

______________________________________ 

IN THE MATTER OF THE APPLICATION 

OF T. Z.-A. O. FOR ADMISSION TO THE 

BAR OF MARYLAND 

______________________________________ 

Barbera, C.J. 

Harrell

Battaglia 

Greene

Adkins

McDonald

Watts, 

JJ.

______________________________________ 

Opinion by Watts, J. 

______________________________________ 

Filed: December 22, 2014 

Argued: November 6, 2014
In this case, we are asked to reconsider the denial of the application for admission 

to the Bar of Maryland of T. Z.-A. O. (“Movant”),1 who: (1) has demonstrated a consistent 

pattern of financial irresponsibility; (2) completed and signed a car loan application which 

included false financial information and failed to include information about a recent 

bankruptcy; and (3) failed to disclose a prior arrest and conviction on his law school 

application. Both the Character Committee for the Fifth Appellate Circuit (“the 

Committee”) and the State Board of Law Examiners (“the Board”) recommended that 

Movant be denied admission to the Bar of Maryland.2

 For the below reasons, we agree 

that Movant has not demonstrated on this record that he currently possesses the requisite 

moral character and fitness for admission to the Bar of Maryland and deny Movant’s 

request for reconsideration.

3

BACKGROUND 

On May 21, 2012, Movant filed with the Board an application for admission to the 

Bar of Maryland. On June 25, 2012, the Board forwarded the application to the Committee. 

Movant passed the July 2012 Maryland Bar Examination. 

 

1On August 26, 2014, this Court granted Movant’s “Motion to Designate Applicant 

by Initials.” 

2On April 18, 2014, relying on the adverse recommendations of the Character 

Committee for the Fifth Appellate Circuit and the State Board of Law Examiners, this 

Court denied Movant admission to the Bar of Maryland. On May 19, 2014, Movant filed 

a Motion for Reconsideration, in which he requested oral argument. We granted Movant’s 

request, and heard oral argument on November 6, 2014. 

3Rule 5(a) of the Rules Governing Admission to the Bar of Maryland provides that 

an “applicant bears the burden of proving to the Character Committee, the Board, and th[is] 

Court the applicant’s good moral character and fitness for the practice of law.” 
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As a result of matters uncovered during the Committee’s investigation, on June 10, 

2013, a three-member panel of the Committee conducted a hearing to determine whether 

Movant possessed the good moral character and fitness necessary for admission to the Bar 

of Maryland. Movant appeared, represented by counsel, and testified. The panel also 

received into evidence twenty-five exhibits. On August 13, 2013, the panel issued a 

Report, unanimously recommending that Movant be denied admission to the Bar of 

Maryland. The panel made findings of fact, which we summarize.4

On May 22, 1996, in Columbus, Ohio, Movant was arrested for public indecency.5

On July 12, 1996, Movant pled guilty to the offense and was sentenced to thirty days’ 

incarceration, with one day credited toward the sentence.6 The remaining twenty-nine days 

were suspended, on the condition that Movant not be convicted of any other crime during 

the next two years. 

In 2004, Movant applied, and was accepted, to Tulane University Law School. 

Question 28(a) of the Tulane University Law School application asked: “[H]ave you ever 

been charged with, arrested for, convicted of, [or] pled guilty or nolo contendere for a 

violation of any law?” Despite certifying in the application that his responses were true, 

correct, and complete, Movant answered Question 28(a) in the negative. 

 

4The record before this Court does not include a transcript of the hearing that was 

conducted on June 10, 2013, before the panel; as such, we summarize the findings of fact 

as detailed in the panel’s Report. 

5As the Board later found, Movant was twenty-two years old at the time of his arrest. 

6

In addition to the thirty-day period of incarceration, Movant was required to pay a 

$220 fine and stay away from all city and metropolitan parks in Columbus, Ohio, for two 

years. 
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Movant disclosed the 1996 arrest and conviction for public indecency on his 

application for admission to the Bar of Florida. Upon review of Movant’s application, the 

Florida Board of Bar Examiners became aware that Movant had failed to disclose the arrest 

and conviction for public indecency on his law school application. The Florida Board of 

Bar Examiners informed Movant of the discrepancy. As a result, Movant notified Tulane 

University Law School that he had failed to disclose the arrest and conviction for public 

indecency on his application for admission.7

On May 10, 2004, a few months after applying to law school, Movant filed a 

voluntary petition for Chapter 7 Bankruptcy. At the hearing, Movant admitted that his 

financial activities had been irresponsible, and included the use of multiple credit cards 

when he had no employment or other means to pay the balances. On August 18, 2004, 

Movant discharged $58,000 in debt. 

On August 25, 2006, Movant purchased a new Honda vehicle. According to 

Movant, he initially intended to purchase a used car, but sales personnel persuaded him to 

test-drive new vehicles and initiated the car loan application process for the purchase of a 

new vehicle. Movant signed the car loan application, as well as at least four additional 

contracts and agreements related to the purchase of the car. The loan application did not 

mention Movant’s 2004 bankruptcy, and falsely stated that Movant owned a home, made 

 

7Later, an official from Tulane University Law School, Dean Susan L. Krinsky, 

provided a letter stating that Movant would have been admitted to Tulane University Law 

School even if he had disclosed the arrest and conviction. 
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no rental or mortgage payments, and earned $3,500 per month.8 By signing the car loan 

application, Movant certified that all information on the car loan application was “true, 

correct, and complete.” Movant asserted that the sales representative “must have inserted” 

the false information concerning his home ownership and income into the car loan 

application, which allowed Movant to qualify for the car loan. Movant acknowledged that, 

at the time of the car’s purchase, he was aware that the interest rate on the car loan was 

14.95% and that his monthly car payment would be $674.70. Movant nevertheless took 

possession of the car. 

In Fall 2007, Movant stopped making monthly car payments. Movant indicated he 

did so “because of what he considered contractual irregularities and/or alterations in the 

contract.” Despite developing concerns about these irregularities, Movant did not 

immediately return the car, but rather continued to use the car until surrendering it in 

February 2008. 

At the time that Movant surrendered the car, there was an arrearage of $19,000 

outstanding on the car loan. Movant testified that he litigated against the financing 

company, disputing responsibility for the deficiency. Movant testified that the financing 

company forgave the outstanding arrearage. 

As to Movant’s current financial situation, Movant is self-employed, and performs 

research and writing for a law firm in Florida. In 2012, Movant earned approximately 

 

8Later, the Board determined that, at the time that he applied for the car loan, Movant 

worked part-time as a library clerk at the Louisiana Supreme Court, earning between $500 

and $600 per month. 
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$24,000, and, from January 2013 to June 2013, Movant had earned between $18,000 and 

$19,000. Movant admitted that he has $220,000 in private and federal student loan debt. 

Movant testified that he made the minimum payments on the private loans, and that the 

federal loans were in forbearance or deferment.9

 

Based on these findings of fact,10 the Committee reached the following conclusions: 

[Movant] has yet to show financial responsibility. Since his 

bankruptcy, [Movant] has continued to accumulate debt for which [he] 

appears to have no plan to pay. Since [Movant]’s bankruptcy in 2004 

[through] which he discharged $58,000 in debt, he has accumulated the better 

part of $200,000.00 in student loans and additional consumer debt with no 

full[-]time employment ever attempted. He has also discharged the 

$19,000.00 vehicle loan by way of litigation against the credit company 

financing the loan. 

[Movant] has still failed to acknowledge the significance of having a 

loan application processed with untruthful information about his financial 

situation included over his signature. [Movant] admitted that he knew that 

there was no way that he should have qualified for the loan necessary to 

purchase the vehicle. Yet he kept and drove the vehicle until he chose to stop 

paying toward the loan. Even after he stopped making payments toward the 

loan, [Movant] continued to employ the use of the vehicle for an additional 

5 to 6 months. [Movant], in spite of knowledge of irregularities with the 

paperwork relating to the vehicle and with knowledge that he should not have 

qualified for the loan necessary to purchase the vehicle, did nothing to put 

matters right until contacted by the Florida [Board of] Bar Examiners about 

the inaccurate application for credit (and when [Movant] was confronted 

with the $19,000.00 arrearage).

The conduct of [Movant] reflects adversely on [Movant]’s personal 

commitment to honesty and truthfulness as well as his commitment to 

 

9

In the Motion for Reconsideration filed with this Court, Movant states that his 

federal student loans are no longer in forbearance, and that he is currently making payments 

as set by the Department of Education under an income-based repayment plan. 

10The Committee also found that Movant was denied admission to the Bar of Florida 

“because of the illegal behavior, the failure to report the criminal arrest and conviction 

relating to that illegal behavior when applying to Tulane Law School, financial 

irresponsibility, and for providing false information when obtaining a motor vehicle loan.” 
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financial responsibility. 

Therefore, after considering the totality of the circumstances of 

[Movant]’s conduct, and the fact that [Movant] bears the burden to prove his 

good moral character, the review of the record and the testimony of the 

[Movant] leads th[e] Committee to conclude that [Movant] has failed to meet 

his burden at this point, and it is the recommendation of the Character 

Committee for the Fifth Appellate Circuit that his application for admission 

to the [Bar of] Maryland [] be denied. 

On December 6, 2013, the Board conducted a hearing, at which Movant appeared, 

represented by counsel.11 On March 18, 2014, the Board issued a report and concluded, 

by a vote of four to two, that Movant had “not met his burden of proving that he currently 

possesses good moral character and fitness for membership in the Bar of Maryland.”

Accordingly, the Board recommended that Movant be denied admission to the Bar of 

Maryland. In its report, the Board made findings, including the following. 

Movant admitted that he signed all documents associated with the car loan 

application, including a credit application certifying that everything was correct, but stated

that he did not read the documents after the first “one or two[.]” In Fall 2007, Movant 

stopped making monthly car payments “after the credit application to purchase the [car] 

became an issue with the” Florida Board of Bar Examiners. The Board also found: 

[Movant] made a major purchase on credit two years after discharging 

$58,000 of consumer credit in bankruptcy. He had also established numerous 

consumer credit accounts when he applied for the [Bar of] Maryland []. 

[Movant] does not understand the import and obligation of his actions or his 

legal commitments. [Movant] has only taken his credit obligations seriously 

when it was evident that they may be an obstacle to becoming admitted to 

 

11Pursuant to Rule 5(c) of the Rules Governing Admission to the Bar of Maryland, 

“[i]f the Board concludes after review of the Committee’s report and the transcript that 

there may be grounds for recommending denial of the application, it shall promptly afford 

the applicant the opportunity for a hearing on the record made before the Committee.” 
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the bar.

[Movant] was thirty-one years of age and a college graduate when he 

entered law school. [Movant] was thirty-two years of age and a law student 

when he signed the documents contracting to purchase the [car]. He was 

thirty-three years of age when he applied for admission to the [Bar of] Florida 

[]. [Movant] was thirty-eight years of age when his application for admission 

to the [Bar of] Maryland [] was accepted for filing. [Movant] was an adult 

through all of the incidents and issues which are of concern to both the 

Florida and Maryland Bar Examiners, yet treats these incidents like they 

were youthful indiscretion. He has a history of incurring financial 

obligations when he lacks the means to fulfill them and uses any method he 

can to evade them. He has shown no commitment to honesty and financial 

responsibility. 

STANDARD OF REVIEW 

The issue before us is whether Movant has met the burden of proving that he 

“possesse[s] the moral character to practice law in the State of Maryland.” In re 

Application of Cramer, 427 Md. 612, 622, 50 A.3d 1066, 1071 (2012) (per curiam) 

(citations omitted). An applicant must possess good moral character for admission to the

Bar. Id. at 622, 50 A.3d at 1071-72. Good moral character is “denoted by those qualities 

of truth-speaking, of a high sense of honor, of granite discretion, [and] of the strictest 

observance of fiduciary responsibility.” Id. at 622, 50 A.3d at 1072 (citations and internal 

quotation marks omitted). We determine present moral character by evaluating whether, 

“viewing the applicant’s character in the period subsequent to his [or her] misconduct, [the 

applicant] has so convincingly rehabilitated himself [or herself] that it is proper that he [or 

she] become a member of a profession which must stand free from all suspicion.” In re 

Application of Stern, 403 Md. 615, 629, 943 A.2d 1247, 1255 (2008) (citations and internal 

quotation marks omitted). Moreover, “good moral character includes truthfulness and 
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candor, and absolute candor is a requisite of admission to the” Bar of Maryland. 

Application of Cramer, 427 Md. at 622, 50 A.3d at 1072 (citations and internal quotation 

marks omitted). 

 “The Board’s conclusions that an applicant does not possess the requisite moral 

character, and recommendation against admission to the Bar, are entitled to great weight.” 

Application of Stern, 403 Md. at 629, 943 A.2d at 1255 (citations omitted). “This Court, 

however, is charged with the responsibility to conduct an independent evaluation of the 

applicant’s moral character based upon testimony and evidence submitted before the 

Committee and the Board.” Application of Cramer, 427 Md. at 623, 50 A.3d at 1072 

(citations omitted). 

DISCUSSION 

 

Movant contends that, contrary to the recommendations of the Committee and the 

Board, he has demonstrated the moral character and fitness necessary for admission to the 

Bar of Maryland.12 As to the car loan application, Movant acknowledges that he signed

the car loan application and other documents concerning the purchase of the car, but asserts 

that the sales representative must have included the false financial information in the 

application. Movant concedes that he did not “handle the matter properly” in choosing to 

 

12As found by the Committee and the Board, Movant failed to disclose his 1996 

conviction for public indecency on his law school application. Given our conclusion as to 

Movant’s failure to honor financial obligations and his inclusion of false information on a 

car loan application set forth below, we need not address Movant’s lack of candor with 

respect to his law school application. Stated otherwise, Movant’s failure to honor financial 

obligations and his conduct with respect to the car loan application, when considered alone, 

demonstrates that he has failed to meet the burden of proving that he possesses the requisite 

moral character and fitness for admission to the Bar of Maryland. 
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stop making monthly car payments and failing to immediately surrender the car, but asserts 

that he has “learned from the experience.” Movant contends that the litigation against the 

car loan financing company, which resulted in the discharge of the outstanding loan debt, 

should not be considered evidence of “financial irresponsibility” because the litigation was 

not undertaken “vexatiously or in bad faith[.]” Movant maintains that he is current on all 

of his financial obligations and that “[t]he overwhelming majority of [his] indebtedness” 

is comprised of student loans. 

Our cases concerning admission to the Bar of Maryland have made clear that failure 

to honor financial obligations and lack of candor are serious matters that adversely reflect 

upon an applicant’s ability to practice law. See, e.g., In re Application of Hyland, 339 Md. 

521, 535, 663 A.2d 1309, 1316 (1995) (“The conduct of an applicant in satisfying his or 

her financial obligations and exhibiting financial responsibility is an important factor in 

assessing good moral character.” (Citations omitted)); In re Application of Strzempek, 407 

Md. 102, 115, 962 A.2d 988, 995 (2008) (“[A]bsolute candor is a requisite of admission to 

the” Bar of Maryland. (Citations and emphasis omitted)). 

Concerning the failure to honor financial obligations, in Application of Stern, 403 

Md. at 636, 633, 943 A.2d at 1259, 1257, we denied admission to the Bar of an applicant 

who, among other things, had “shown a pattern of financial irresponsibility[,]” and who 

had “allowed his debt to escalate and made very few efforts, if any, to resolve his financial 

obligations until he was faced with the possibility that his failure could hinder his 

admission to the Bar.” (Emphasis in original). In that case, the Committee found that the 

applicant “knew that his debts had to be paid and that he had assets to do so, but instead, 
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he continued to increase his debt until no one would extend him further credit.” Id. at 633, 

943 A.2d at 1257. Although the applicant contended that he had rehabilitated himself, 

“adopted a financial plan[,] and [] paid most of his creditors[,]” we observed that, “absent 

the exigency of the Bar admission process,” it was doubtful that the applicant would have 

made any effort to repay his debt. Id. at 635, 943 A.2d at 1258-59. We stated that the 

applicant’s “financial misconduct . . . in and of itself reflect[ed] adversely on [the 

applicant’s] character and fitness to practice law.” Id. at 634, 943 A.2d at 1258. 

In Application of Hyland, 339 Md. at 539, 527-28, 663 A.2d at 1318, 1312, we 

denied admission to the Bar of an applicant who pled guilty to fifteen counts of “failure to 

remit sales taxes” in violation of Pennsylvania law, and who “fail[ed] to remit employee 

income tax withholdings” to the Internal Revenue Service. We observed: 

Given the duties that attorneys are ordinarily required to perform, we 

think that the applicant’s failure to carry out his significant legal obligation 

to satisfy his tax debt to the federal government and the Commonwealth of 

Pennsylvania is connected to his fitness to practice law. This conduct reflects 

adversely on the applicant’s personal commitment to the proper 

administration of justice, as well as his honesty and truthfulness. 

Id. at 538, 663 A.2d at 1317 (citations omitted). In sum, we concluded “that the applicant’s 

failure to honor his financial obligations evidence[d] a disregard of a legal obligation and 

reflect[ed] adversely on his fitness to practice law.” Id. at 537, 663 A.2d at 1316 (citations 

omitted). 

Here, we conclude that Movant’s inability to honor financial obligations and to be 

financially responsible, as well as Movant’s lack of candor, reflect that he does not 

presently possess the moral character and fitness necessary to practice law in this State. 
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Movant has shown a consistent and troubling pattern of financial irresponsibility and 

failure to meet financial obligations. On May 10, 2004, only a few months after applying 

to law school, Movant filed a voluntary petition for Chapter 7 Bankruptcy; and, on August 

18, 2004, Movant discharged $58,000 in consumer credit debt. Movant admitted that his 

financial activities were irresponsible, and that those activities included the use of multiple 

credit cards when he was unemployed and had no resources with which to make monthly 

payments. Despite the bankruptcy, two years later, on August 25, 2006, Movant made a 

major purchase via credit when he financed the purchase of a new car. Movant was aware 

that the monthly car payments would be $674.70 and that he earned only between $500 

and $600 per month, yet Movant took possession of the car. Later, when issues concerning 

the car loan application were raised by the Florida Board of Bar Examiners, Movant 

stopped making monthly car payments. Nevertheless, Movant continued to use the car for 

months before surrendering it. And, when faced with an arrearage of $19,000 in 

outstanding car loan debt, Movant litigated to have the outstanding debt forgiven. In 

addition to the car loan, after his 2004 bankruptcy, Movant accumulated significant debt, 

including $220,000 in private and federal student loan debt and additional consumer credit 

accounts.13 

 

13In his application for admission to the Bar of Maryland, Movant indicated that he 

had established or maintained twenty-four separate accounts with eighteen different 

creditors over the past five years. Equally troubling is that, although he has accumulated 

and continues to accumulate substantial debt, Movant has not demonstrated that he has the 

means to pay or manage the debt. As the Committee found, Movant has not maintained 

full-time employment, and instead is self-employed, providing legal research and writing 

to a law firm in Florida. In 2012, Movant earned approximately $24,000, and during the 
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Movant’s unilateral decision to stop making monthly car payments is particularly 

concerning because it demonstrates an intentional disregard of a known legal and financial 

obligation. Cf. Application of Hyland, 339 Md. at 537, 663 A.2d at 1316 (We concluded 

“that the applicant’s failure to honor his financial obligations evidence[d] a disregard of a 

legal obligation and reflect[ed] adversely on his fitness to practice law.” (Citations 

omitted)). As in Application of Stern, 403 Md. at 633-34, 943 A.2d at 1257-58, here, 

Movant’s past financial irresponsibility makes clear that Movant “live[s] a lifestyle based 

on [overextended] credit and bad judgment.” In sum, Movant has demonstrated a 

longstanding pattern of financial irresponsibility that adversely reflects on his moral 

character and fitness to practice law.

14

 

Equally as important, Movant’s character and fitness to practice law is impugned 

by the lack of candor displayed in connection with the 2006 car loan application. As the 

Committee found, Movant signed a car loan application which contained false financial 

information. Specifically, the car loan application contained no information pertaining to 

 

first half of 2013, he earned between $18,000 and $19,000. That Movant may presently be 

current on all of his financial obligations, although commendable, does not demonstrate 

that Movant has the ability or the inclination to be consistently financially responsible, or 

that he appreciates the importance of taking responsibility for financial obligations and 

legal commitments. 

14As in Application of Hyland, 339 Md. at 538 n.4, 663 A.2d at 1317 n.4, we pause 

to state that “[w]e in no way intend to cast aspersion on those who finance their education 

through student loans or those who perform public interest legal work for low pay despite 

their outstanding loans. We recognize that because of the high cost of education, many 

people will finance their schooling through loans.” Indeed, it is not Movant’s student loans, 

but rather the amalgamation of the ever-growing amount of his debt and Movant’s history 

of incurring substantial financial obligations but not having the means to pay for them, that 

forms the basis of our determination that Movant lacks financial responsibility. 
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Movant’s 2004 bankruptcy, and falsely stated that Movant owned a home, had no rental or 

mortgage payments, and earned $3,500 per month. By signing the car loan application, 

Movant certified that all information on the car loan application was “true, correct, and 

complete.” 

Rather than accepting responsibility for the false information in the car loan 

application, Movant blames the car sales representative and posits that the car sales 

representative must have inserted the false financial information on the car loan 

application. At the time Movant applied for the car loan, however, he was earning between 

$500 and $600 per month, and had filed for bankruptcy only two years earlier. The 

Committee specifically found that Movant did not believe he should have qualified for the 

car loan due to his “insufficient income” and recent bankruptcy. Thus, despite Movant’s 

allegations of a duplicitous car sales representative, Movant was aware that, based on his 

income and prior bankruptcy, it was unlikely that he should have been approved for the 

loan in the first place. More importantly, Movant signed the loan application containing 

the false information. And, when Movant was incredibly approved for the car loan, he did 

not question the matter but instead drove off in a new car. Under these circumstances, it is 

difficult to view Movant’s signing of the car loan application containing false financial 

information as anything other than an incident that reflects negatively on his character for 

candor. 

Both the Committee and the Board recommended that Movant be denied admission 

to the Bar of Maryland. As stated above, we afford “great weight” to the Board’s 

conclusion that an applicant does not possess the present good moral character and fitness, 
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as well as to its recommendation against admission to the Bar of Maryland. Application 

of Cramer, 427 Md. at 623, 50 A.3d at 1072. “Indeed, that this Court accepts the 

recommendation of the Board is the rule and the failure to do so, the exception.” In re 

Application of Brown, 392 Md. 44, 65, 895 A.2d 1050, 1062 (2006) (Bell, C.J., dissenting) 

(citations omitted). 

Here, we are not examining a singular instance of failure to provide a full and candid 

disclosure that could potentially be rehabilitated through later disclosure; instead, we are 

confronted with Movant’s pattern of financial irresponsibility and his lack of candor on the 

car loan application. At the time of the events detailed above—when Movant declared 

bankruptcy, incurred additional debt, and applied for admission to the Bar of Florida and 

the Bar of Maryland—Movant was over the age of thirty.15 In other words, Movant’s 

misconduct cannot be written off as youthful indiscretions or attributed to juvenility. As 

the Board found, and we agree, Movant has shown a lack of “commitment to honesty and 

financial responsibility.” 

Having made an independent review of the record and after considering the 

circumstances surrounding Movant’s conduct, we conclude that Movant has failed to meet

 

15On his application for admission to the Bar of Maryland, Movant indicated that he 

was born in 1974. In its findings, the Board stated that Movant was thirty-one years old 

when he began law school, thirty-two years old when he signed the car loan application, 

thirty-three years old when he applied for admission to the Bar of Florida, and thirty-eight 

years old when he applied for admission to the Bar of Maryland. 
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the burden of proving that he possesses the requisite moral character and fitness for 

admission to the Bar of Maryland. Movant’s Motion for Reconsideration of this Court’s 

April 18, 2014, denial of his application for admission to the Bar of Maryland is, hereby, 

denied. 

IT IS SO ORDERED.