That a lawyer has been disciplined for similar conduct in another grievance case does not justify lessening the sanctions in a second case that occurred around the same time, according to the Supreme Court.

Instead, the court said in a December 9 opinion, such a pattern of misconduct justifies a more severe punishment in the second case.

The attorney had been suspended by the court for one year in 2018 for disparaging without basis opposing counsel; alleging bias and shortcomings of the legal system; implying that a Third District Court of Appeal judge favored his opposing counsel; allowing his client to make false statements that constituted a “fraud on the court;” and, when he and his client were financially sanctioned, placing his interests over those of the client.