IN RE: Dorothy L. TARVER (2026)

ATTORNEY DISCIPLINARY PROCEEDING

Pursuant to Supreme Court Rule XIX, § 21, the Office of Disciplinary Counsel (“ODC”) has filed a petition seeking the imposition of reciprocal discipline against respondent, Dorothy L. Tarver, an attorney licensed to practice law in Louisiana, based upon discipline imposed by the United States District Court for the Middle District of Louisiana.

UNDERLYING FACTS AND PROCEDURAL HISTORY

By way of background, the Galindo Law Firm (“GLF”) is a law firm based in Houston. Texas attorney Cristobal M. Galindo is GLF's principal and managing partner. In 2021, GLF opened an office in New Orleans to assist first-part insurance clients with Hurricane Ida claims. Initially, GLF represented clients as co-counsel with other law firms, but in the spring of 2023, GLF assumed primary responsibility for a substantial number of the Hurricane Ida cases. On April 1, 2024, GLF hired respondent to work in its New Orleans office.

In May 2024, respondent was substituted as counsel of record for Britney Boudreaux in her Hurricane Ida suit pending in the Middle District of Louisiana. Boudreaux v. Tower Hill Prime Ins. Co., No. 3:23-cv-00828-JWD-RLB. In August 2024, the parties reached a $19,000.00 settlement in the matter. Thereafter, and despite multiple requests from defense counsel, respondent failed to provide the defendant with an executed settlement agreement and release of all claims. As a result, the defendant filed a motion to enforce settlement in October 2024.

The district court issued a briefing schedule for Ms. Boudreaux to file a response to the motion to enforce settlement; however, respondent failed to file an opposition on behalf of Ms. Boudreaux or otherwise respond to the defendant's motion. After an additional three months elapsed, the defendant filed a motion seeking a status conference. On February 4, 2025, the district court granted the motion and set a status conference for February 11, 2025. On February 5, 2025, respondent filed a motion to withdraw as counsel for Ms. Boudreaux and to substitute another attorney at GLF. The district court denied that motion without prejudice and ordered respondent to appear at the previously scheduled status conference.

At the status conference, respondent represented that Mr. Galindo had “precluded” her from working on Ms. Boudreaux's case, despite the fact that she was the attorney of record. Respondent explained that she had resigned from GLF in August 2024,¹ not long after she enrolled as Ms. Boudreaux's counsel, but that Mr. Galindo had persuaded her to rejoin the firm with the understanding that she would take a leave of absence. During her leave of absence (which continued until January 20, 2025, when she was terminated by GLF), Mr. Galindo prohibited respondent from reviewing documents, accessing GLF's case management system, or communicating with clients or opposing counsel. As a result of the arrangement at GLF, respondent was unaware that Ms. Boudreaux had not executed the settlement agreement and release.²

On February 24, 2025, the Middle District issued a show cause order notifying respondent of the possibility of sanctions for her conduct, and ordered her to respond in writing.³ After receiving respondent's brief, the court conducted an en banc hearing on April 10, 2025. During the hearing, respondent, Mr. Galindo, and GLF attorney Michal Harris gave sworn testimony and argument was heard.

On November 26, 2025, the Middle District issued its Sanctions Order. In its 46-page ruling, the federal court determined that respondent violated Rules 1.1 (failure to provide competent representation to a client), 1.3 (failure to act with reasonable diligence and promptness in representing a client), 1.4 (failure to communicate with a client), and 1.16 (termination of the representation) of the Rules of Professional Conduct. For these violations, the federal court suspended respondent from the practice of law in the Middle District for eleven months and ordered her to obtain eight additional hours of continuing legal education in the area of professionalism over a 24-month period.⁴

After receiving notice of the federal court order of discipline, the ODC filed a motion to initiate reciprocal discipline proceedings in Louisiana, pursuant to Supreme Court Rule XIX, § 21. Copies of the orders issued by the court were attached to the petition, as well as the Middle District order. On January 6, 2026, this court rendered an order giving respondent and the ODC thirty days to demonstrate why the imposition of identical discipline would be unwarranted.

Respondent timely filed a response to the court's order, asserting that she was denied a full hearing before the Middle District because Ms. Boudreaux was not called to testify at the April 10, 2025 en banc hearing. Arguing that Ms. Boudreaux's testimony was relevant to issues of “credibility, intent, and mitigation,” respondent contends that this court cannot reliably accept the “procedurally truncated record” developed by the federal court. Therefore, she maintains that this court should decline to impose identical reciprocal discipline.

DISCUSSION

The standard for imposition of discipline on a reciprocal basis is set forth in Supreme Court Rule XIX, § 21(D). That rule provides:

Discipline to be Imposed. Upon the expiration of thirty days from service of the notice pursuant to the provisions of paragraph B, this court shall impose the identical discipline ․ unless disciplinary counsel or the lawyer demonstrates, or this court finds that it clearly appears upon the face of the record from which the discipline is predicated, that:

(1) The procedure was so lacking in notice or opportunity to be heard as to constitute a deprivation of due process; or

(2) Based on the record created by the jurisdiction that imposed the discipline, there was such infirmity of proof establishing the misconduct as to give rise to the clear conviction that the court could not, consistent with its duty, accept as final the conclusion on that subject; or

(3) The imposition of the same discipline by the court would result in grave injustice or be offensive to the public policy of the jurisdiction; or

(4) The misconduct established warrants substantially different discipline in this state; ․

If this court determines that any of those elements exists, this court shall enter such other order as it deems appropriate. The burden is on the party seeking different discipline in this jurisdiction to demonstrate that the imposition of the same discipline is not appropriate.

In determining the appropriate measure of reciprocal discipline, we are not required to impose the same sanction as that imposed by the jurisdiction in which the misconduct occurred. Nevertheless, only under extraordinary circumstances should there be a significant variance from the sanction imposed by the other jurisdiction. In re: Aulston, 05-1546 (La. 1/13/06), 918 So. 2d 461. See also In re Zdravkovich, 831 A.2d 964, 968-69 (D.C. 2003) (“there is merit in according deference, for its own sake, to the actions of other jurisdictions with respect to the attorneys over whom we share supervisory authority”).

In the instant case, the imposition of reciprocal discipline against respondent based upon the federal court's judgment is clearly appropriate. Our review of the record demonstrates respondent was afforded full due process rights in the federal court. The court heard sworn testimony from respondent and two GLF attorneys during the en banc hearing; it is unclear to us what more respondent's client could have added. There is no infirmity of proof establishing the misconduct. The discipline imposed by the federal court is not offensive to the public policy of this state and is not substantially different from the discipline we would impose under similar circumstances. Under these circumstances, we find it is appropriate to defer to the federal court judgment imposing discipline upon respondent.

Accordingly, we will impose reciprocal discipline in the form of an eleven-month suspension from the practice of law. Nothing in our order should be read as precluding the reinstatement of respondent in the United States District Court for the Middle District of Louisiana if permitted under the rules of that court.

DECREE

Considering the Petition to Initiate Reciprocal Discipline Proceedings filed by the Office of Disciplinary Counsel and the record filed herein, it is ordered that respondent, Dorothy L. Tarver, Louisiana Bar Roll number 29714, be and she hereby is suspended from the practice of law for a period of eleven months. All costs and expenses in the matter are assessed against respondent in accordance with Supreme Court Rule XIX, § 10.1, with legal interest to commence thirty days from the date of finality of this court's judgment until paid.

FOOTNOTES

1.   Respondent's resignation was due to “the stressful work environment, lack of support, and poor management” at GLF. She indicated that, for example, each attorney in the New Orleans office managed approximately 250-350 federal cases, without support staff.

2.   At the conclusion of the status conference, the district court granted respondent's motion to withdraw as counsel of record for Ms. Boudreaux.

3.   The show cause order noted that respondent “had already been the subject of disciplinary concern” in the Middle District, citing three instances in June and July 2024 in which she had been admonished for failing to appear for conferences and failing to comply with court orders.

4.   In the same judgment imposing discipline upon respondent, the Middle District sanctioned Mr. Galindo by precluding him from applying for admission in the United States District Court for the Middle District of Louisiana or from supervising attorneys who are admitted in the district for a period of two years. Mr. Galindo was also ordered to pay attorney's fees and a $2,500 fine, and obtain additional CLE.

PER CURIAM