New York lawyer Rahul Dev Manchanda was disbarred in 2024 by the Appellate Division’s First Judicial Department of the New York Supreme Court. The primary charge was that he persisted in using racist and anti-Semitic language in his disciplinary complaints against other lawyers and judges. “Words fail to capture the severity and extent” of the lawyer’s bigotry, the appeals court wrote in its order.

Among other offenses, Manchanda was found to have,

  • Filed documents with “unacceptably bigoted language” in state and federal courts and “a panoply” of agencies.

  • “Used intolerably vile and foul language and divulged privileged information” when responding to clients’ online complaints.

  • “Used racist, antisemitic, homophobic and misogynistic statements while holding himself out as a well-trained and extremely experienced lawyer” in New York City.

  • “Repeatedly made meritless, frivolous and vexatious arguments well beyond the point at which he should have known better.” His “targets for such filings have grown to include this very disciplinary proceeding and collateral attacks that he has launched on it in state and federal courts.”

No weenie he, the lawyer is striking back. Manchanda has now sued the Attorney Grievance Committee for New York’s First Judicial Department, seeking $20 million in damages, which he claims he would have made in his practice over the next 20 years.

Yeeeeah.….

The suit alleges that the lawyer was disbarred because he is “a Republican, conservative, Christian values lawyer” who is Indian-American, and that the discipline he has been subjected to was “a simple, draconian, defamatory, slanderous, libelous death sentence, simply for exercising protected speech” against “activist extreme feminist and lesbian judges, racist law clerks, LGBTQ+ and biased court administrators, who routinely would lose his motions, sabotage his filings” and “arbitrarily and capriciously threaten him with contempt or arrest.” Manchanda has been persecuted, his suit claims, because his actions targeted agencies in which “the vast majority of New York City government employees” are “predominantly leftist, communist, Democrat, … of African American descent, with predominantly Jewish supervisors, as well as LGBTQ+ activists and extremists.”

He also described the referee in the ethics case again him as a “biased, broken, morally, physically and mentally unstable old woman.” Okay, then!

Rahul Dev Manchanda can be fairly described as a “piece of work.” I doubt that this case will do it, but I have been anticipating for a long time now a court holding that many provisions of the Rules of Professional Conduct, and thus the bar discipline meted out for violating them, run afoul of the Constitution. I know bar associations are worried about this, which is why they tend to act only in the most egregious cases.

In its order against Manchanda, the Appeals Court cites as justification for the disbarment several of the most vague and subjective rules, such as that a lawyer shall not “engage in conduct that is prejudicial to the administration of justice” and that a lawyer shall not “engage in any other conduct that adversely reflects on the lawyer’s fitness as a lawyer.”