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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 14-BG-607

IN RE VICTOR MBA-JONAS, PETITIONER.

A Suspended Member of the Bar of the

District of Columbia Court of Appeals

(Bar Registration No. 452042)

On Report and Recommendation of the

Board on Professional Responsibility

(BDN-19-11)

(Argued April 14, 2015 Decided July 2, 2015) 

Victor Mba-Jonas, pro se.

William R. Ross, Assistant Bar Counsel, with whom Wallace E. Shipp, Jr., 

Bar Counsel, Jennifer P. Lyman, Senior Assistant Bar Counsel, and Jelani Lowery, 

Senior Staff Attorney, were on the brief, for Bar Counsel.

Before WASHINGTON, Chief Judge, BECKWITH, Associate Judge, and REID,

Senior Judge.

PER CURIAM: Having found by clear and convincing evidence that 

petitioner, Victor Mba-Jonas, failed to satisfy any of the criteria for reinstatement 

outlined in In re Roundtree, 503 A.2d 1215, 1217 (D.C. 1985), the Ad Hoc 

Hearing Committee (“Hearing Committee”) recommended that Mr. Mba-Jonas’ 

petition for reinstatement be denied. The Board on Professional Responsibility
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took no exception to the Hearing Committee’s recommendation. We accept the 

Hearing Committee’s recommendation. 

 I.

The Maryland Court of Appeals indefinitely suspended Mr. Mba-Jonas from 

the practice of law in Maryland with the right to petition for reinstatement after 

ninety days. See Attorney Grievance Comm’n v. Mba-Jonas, 919 A.2d 669 (Md. 

2007) (“Mba-Jonas I”). Thereafter, Bar Counsel initiated reciprocal disciplinary 

proceedings. While that reciprocal proceeding was pending, the Maryland Court 

of Appeals again suspended Mr. Mba-Jonas indefinitely for additional misconduct, 

imposing a right to petition for reinstatement after six months. See Attorney 

Grievance Comm’n v. Mba-Jonas, 936 A.2d 839 (Md. 2007) (“Mba-Jonas II”). 

This court consolidated the matters and ultimately imposed identical discipline in 

both matters, suspending Mr. Mba-Jonas for ninety days with a fitness 

requirement, as in Mba-Jonas I, and six months with a fitness requirement, as in 

Mba-Jonas II.

1

 

 

1

In Mba-Jonas I and Mba-Jonas II, Mr. Mba-Jonas was disciplined for 

mismanaging client trust accounts over a substantial period of time and failing to 

disclose a material fact regarding his past representation of a client to a Maryland 

(continued . . .)
3

 II. 

“In a disciplinary case, this court accepts the [Hearing Committee’s]

findings of fact unless they are unsupported by substantial evidence of record.” In 

re Samad, 51 A.3d 486, 495 (D.C. 2012) (internal quotation marks omitted); see 

also D.C. Bar R. XI, § 9 (h)(1). Furthermore, “[a]lthough we place ‘great weight’ 

on the recommendations of the Board and Hearing Committee, this court has the 

ultimate authority to decide whether to grant a petition for reinstatement.” In re 

Sabo, 49 A.3d 1219, 1224 (D.C. 2012) (quoting In re Bettis, 644 A.2d 1023, 1027 

(D.C. 1994)). However, this court defers to the Hearing Committee’s findings of 

fact because the Hearing Committee is “the only decision-maker which had the 

opportunity to observe the witnesses and assess their demeanor.” Id. (internal 

quotation marks omitted).

A petitioner seeking reinstatement has the burden of proving by clear and 

convincing evidence that the petitioner “has the moral qualifications, competency, 

and learning in law required for admission,” and that resumption of the practice of 

 

(. . . continued)

Bar investigator who was investigating an overdraft of one of Mr. Mba-Jonas’ 

client trust accounts. 
4

law “will not be detrimental to the integrity and standing of the Bar, or to the 

administration of justice, or subversive to the public interest.” D.C. Bar R. XI, 

§ 16 (d). In determining whether a petitioner has carried its burden, this court 

considers:

(1) the nature and circumstances of the misconduct for which the 

attorney was disciplined; (2) whether the attorney recognizes the 

seriousness of the misconduct; (3) the attorney’s conduct since 

discipline was imposed, including the steps taken to remedy past 

wrongs and prevent future ones; (4) the attorney’s present character; 

and (5) the attorney’s present qualifications and competence to 

practice law.

Roundtree, 503 A.2d at 1217. 

Here, the Hearing Committee’s findings were substantially supported by the 

evidence provided and the Hearing Committee properly applied the Roundtree

factors in determining whether Mr. Mba-Jonas should be reinstated. Furthermore, 

Mr. Mba-Jonas’ contention that the Hearing Committee improperly considered his 

handling of his personal financial accounts is without merit given that this behavior 

reflects the very conduct that led to his indefinite suspension. See In re Robinson, 

705 A.2d 687, 688-89 (D.C. 1988) (recognizing that “in reinstatement cases[,] 

primary emphasis should be given to matters bearing most closely on the reasons 

why the attorney was suspended or disbarred in the first place” and declining to 

disregard petitioner’s mismanagement of personal finances because it was 
5

“behavior reminiscent of actions that led to his disbarment”). The fact that the 

petitioner in Robinson was found to have intentionally misappropriated client 

funds while Mr. Mba-Jonas was found to have been negligent in his misconduct is 

not dispositive here because, like in Robinson, examining Mr. Mba-Jonas’ 

handling of his personal financial affairs was the only means of evaluating whether 

he could once again be entrusted with client funds. Accordingly, it is

ORDERED that Victor Mba-Jonas’ petition for reinstatement is denied. 

However, pursuant to the Hearing Committee’s recommendation, Mr. Mba-Jonas 

is permitted to submit a new petition for reinstatement immediately after the date 

of issuance of this opinion. 

So ordered.