Why Attorney Gregory Slate Was Disbarred

On March 2, 2018, the Court of Appeals of Maryland—then the state's highest court—ordered the disbarment of Gregory Allen Slate. The court concluded that Slate had knowingly withheld the most damaging facts about a federal lawsuit from Maryland's attorney-admissions authorities and had falsely represented that he had made the required disclosure.

The case behind the disbarment

The disciplinary proceeding traced back to a federal copyright lawsuit Slate filed against American Broadcasting Companies. The case concerned hidden-camera footage created during a police-accountability project involving ABC and the Police Complaint Center.

In 2013, U.S. District Judge Beryl A. Howell ruled against Slate. Her opinion did more than reject his copyright theory. The court described what it regarded as a persistent course of bad-faith litigation conduct, including a fabricated letter, testimony that was likely perjurious or at least intentionally misleading, repeated discovery abuse, and the use of judicial process to harass and discredit Diop Kamau, a central witness in the case.

The letter that could not fit the timeline

One of the most important pieces of evidence was a letter dated August 21, 2006, which Slate claimed he had sent to an ABC producer. The letter attempted to establish that Slate had already separated himself from the Police Complaint Center and asserted individual rights in the investigative footage.

The problem was a reference in the letter to Slate's recent success in receiving an Emmy Award. The chronology did not permit that statement to have been written on the date shown. The relevant nominations were announced later, the winners were announced months afterward, and Slate's name was not added to the winning entry until December 2006.

Judge Howell concluded that the letter had been fabricated after the fact. The court also documented contradictions between Slate's sworn testimony and contemporaneous emails concerning receipts, camera equipment, and his dealings with ABC.

What Slate told Maryland

Slate applied for admission to the Maryland bar in 2014. He identified the ABC lawsuit and stated that it had been dismissed while an appeal was pending. But Maryland's disciplinary courts found that he did not disclose the federal opinions or their central findings concerning fabrication, misleading testimony, discovery abuse, and bad-faith litigation.

His application also asked whether there were other unfavorable incidents bearing on his character or fitness that had not otherwise been disclosed. Slate answered no. He later affirmed under oath that the application remained accurate.

What Judge Hong concluded after the evidentiary hearing

Judge Jeannie J. Hong conducted the disciplinary hearing over three days in October 2017. Applying Maryland's clear-and-convincing-evidence standard, she concluded that Slate violated MLRPC 8.1(a), 8.1(b), 8.4(c), 8.4(d), and 8.4(a). Her findings were not limited to a single omitted attachment: she found knowing concealment across repeated opportunities to disclose the Howell opinions and the findings they contained.

Judge Hong also found that Slate's misconduct was aggravated by a dishonest or selfish motive and by his refusal to acknowledge the wrongful nature of the conduct. She found that he had not established any mitigating factors.

What Maryland's highest court affirmed

Slate argued that identifying the ABC case itself was enough, that admissions officials could have found the opinions on their own, and that he would have produced certified copies if the application had specifically demanded them. Maryland rejected that explanation. The appellate court repeatedly emphasized that the concealment was knowing, not a mere mistake.

Why the sanction was disbarment

On its independent review, the Court of Appeals identified five aggravating factors: a dishonest or selfish motive, a pattern of dishonesty, multiple professional-rule violations, refusal to acknowledge wrongdoing, and a likelihood that the dishonesty would be repeated. Judge Hong had found no mitigating factors; the high court identified only two—no prior attorney discipline and limited experience in the practice of law.

Those limited mitigating considerations did not alter the result. The Court of Appeals said there was little doubt that, had Slate's dishonesty been known during the admissions process, he would have been found to lack the character and fitness necessary for admission. It further concluded that there were no compelling extenuating circumstances that would justify a sanction short of disbarment.

The court explained that attorney discipline is imposed to protect the public and public confidence in the legal profession, deter similar misconduct, and remove lawyers who are unfit to continue practicing. It ordered Slate disbarred and ordered him to pay the costs of the disciplinary proceeding.

A brief timeline

The bottom line

Gregory Slate was disbarred because Maryland concluded that he knowingly concealed material judicial findings bearing directly on honesty and fitness, falsely reaffirmed the accuracy of his bar application under oath, failed to supplement the application or disclose the information during the character-review process, and later misrepresented to Bar Counsel that he had provided all required information.

The underlying federal record was not a vague criticism. It included a judicial finding that a key letter had been fabricated after the fact, findings concerning misleading testimony and discovery abuse, and a finding that legal process had been used to harass and discredit a witness.

This report does not ask readers to substitute the authors' opinion for the public record. It asks readers to examine the record and understand why Maryland concluded that disbarment was necessary.