IN RE: Christopher R. BURNS (2026)

ATTORNEY DISCIPLINARY PROCEEDING

This matter arises from a Petition to Initiate Reciprocal Discipline Proceedings filed by the Office of Disciplinary Counsel (“ODC”) against respondent, Christopher R. Burns, an attorney licensed to practice law in Louisiana and New Hampshire, based upon discipline imposed by the Supreme Court of New Hampshire.

UNDERLYING FACTS AND PROCEDURAL HISTORY

In October 2023, respondent was retained to represent Jeffrey Koss in a small claims action against a contractor. Mr. Koss paid respondent a $3,000.00 advanced fee. Respondent deposited the advanced fee into his client trust account; however, his trust account balance was negative at the time of deposit. Nine days after depositing the advanced fee into his client trust account, respondent disbursed the entirety of the advance fee directly to himself without it being earned.

Opposing counsel served respondent with discovery. Respondent did not forward these discovery requests to Mr. Koss. After the delay to respond to the discovery passed, opposing counsel filed a conditional default against Mr. Koss. Respondent again did not advise the client of same. Respondent did file untimely “discovery”; however, he merely sent over thirty pages of documents that were provided to him by Mr. Koss at their first meeting. Moreover, respondent sent the discovery to opposing counsel with a notarial signature that Mr. Koss personally appeared and signed the discovery, which Mr. Koss denies. Further, the notary stamp reveals the notary is not authorized to perform electronic notary services in New Hampshire.

Mr. Koss repeatedly contacted respondent to discuss the matter, but respondent failed to communicate. Moreover, respondent again failed to respond properly to discovery, causing the filing of a motion for entry of final judgment along with payment of costs. Despite that motion being served, respondent failed to inform Mr. Koss about the motion for final judgment. Respondent did not file an objection, and the court granted the motion and entered final judgment assessing costs against Mr. Koss. Even after this final judgment, respondent continued to misrepresent to Mr. Koss the status of the case and the work he performed.

Mr. Koss learned of the judgment, and after advising respondent of same, respondent advised Mr. Koss that he would file a motion to vacate the judgment. Respondent failed to file any additional pleadings on Mr. Koss's behalf. Around June 2024, Mr. Koss hired additional counsel, paying him approximately $2,000.00 to attempt to strike the default judgment. Mr. Koss never received a refund of the advanced fees paid to respondent.

On May 13, 2026, the Supreme Court of New Hampshire disbarred respondent. In its order, the court adopted the following facts:

Attorney Burns committed serious misconduct. He immediately began converting a client's funds for his own uses without ever earning it, depleting the funds in nine days. He failed to represent the client in any meaningful way, let alone with a minimum amount of competence or diligence, and then submitted falsely notarized interrogatories to opposing counsel, lied to his client over a period of months, caused a default judgment with costs to be entered against the client, and failed to respond to the disciplinary authority. Attorney Burns lied to the Committee and showed no remorse.

The court determined respondent's conduct violated the following provisions of the New Hampshire Rules of Professional Conduct: Rules 1.1 (failure to provide competent representation), 1.3 (failure to act with reasonable diligence and promptness in representing a client), 1.4 (failure to communicate with a client), 1.15 (safekeeping client property), 3.3 (candor toward the tribunal), 3.4 (failure to make reasonably diligent effort to comply with a legally proper discovery request by an opposing party), 4.1 (making a false statement of material fact or law to a third person, including opposing counsel), 8.1(b) (knowing failure to respond to lawful demand for information from a disciplinary authority), and 8.4(c) (engage in conduct involving dishonesty, fraud, deceit, or misrepresentation).

After receiving the New Hampshire order of discipline, the ODC filed a motion to initiate reciprocal discipline proceedings in Louisiana, pursuant to Supreme Court Rule XIX, § 21. A copy of the decision issued by the Supreme Court of New Hampshire was attached to the motion. On June 1, 2026, this court rendered an order giving the parties thirty days to demonstrate why the imposition of identical discipline in this state would be unwarranted. Respondent failed to file an answer to this court.

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 the instant case, respondent has made no showing of infirmities in the New Hampshire proceeding, nor do we discern any from our review of the record. Furthermore, there is no reason to deviate from the sanction imposed in New Hampshire as 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”).

Under these circumstances, we find it is appropriate to defer to the New Hampshire judgment imposing discipline upon respondent. Accordingly, we will impose reciprocal discipline and disbar respondent.

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, Christopher R. Burns, Louisiana Bar Roll number 29523, be and he hereby is disbarred. His name shall be stricken from the roll of attorneys, and his license to practice law in the State of Louisiana shall be revoked. 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.

PER CURIAM