IN RE: Elizabeth S. HORN (2026)

This matter arises from a Petition to Initiate Reciprocal Discipline Proceedings filed by the Office of Disciplinary Counsel (“ODC”) against respondent, Elizabeth S. Horn, an attorney licensed to practice law in Louisiana and North Carolina, based upon discipline imposed by the Virginia State Bar.¹

UNDERLYING FACTS AND PROCEDURAL HISTORY

Respondent is employed by the Thomas Law Firm in Fairfax, Virginia and works remotely from her home in Winston-Salem, North Carolina. The law firm represented the plaintiff in Melanie Dos Reis v. David Baum, et al., a business litigation matter pending in Fairfax Circuit Court. In August 2024, respondent submitted the plaintiff's initial and supplemental discovery responses to defense counsel. In the signature block of each of these pleadings, respondent indicated that her pro hac vice admission was “pending.” However, a motion for Admission Pro Hac Vice was not filed until more than a month after the discovery responses were submitted. Respondent and the Thomas Law Firm ultimately withdrew from the representation of the plaintiff in December 2024, prior to a hearing on the motion. In April 2026, respondent agreed to be publicly reprimanded by the Virginia State Bar for making a false statement of fact and engaging in the unauthorized practice of law, in violation of Rules 4.1(a) and 5.5(c) of the Virginia Rules of Professional Conduct.

After receiving the Virginia 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 Fifth District, Section I Subcommittee of the Virginia State Bar was attached to the motion. On July 27, 2026, this court rendered an order giving respondent thirty days to demonstrate why the imposition of identical discipline in this state would be unwarranted. Respondent failed to file any response in 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 Virginia proceeding, nor do we discern any from our review of the record. Furthermore, there is no reason to deviate from the sanction imposed in Virginia 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 Virginia judgment imposing discipline upon respondent. Accordingly, we will impose reciprocal discipline of a public reprimand.

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, Elizabeth S. Horn, Louisiana Bar Roll number 35829, be and she hereby is publicly reprimanded.

FOOTNOTES

1.   Respondent is not a member of the Virginia State Bar and is not admitted to practice in Virginia; however, she provided legal services in Virginia and represented a client in a proceeding in Fairfax County, Virginia, thereby subjecting herself to the disciplinary authority of Virginia.

PER CURIAM