The Florida Supreme Court has disbarred a lawyer who died more than a year ago.
Sabrina Starr Spradley, a 41-year-old attorney in private practice in Delray Beach, Florida, was disbarred in December. But according to an official death certificate provided to Law.com from the Florida Department of Health, she died in October 2019.
The Florida Bar requests a dismissal of formal charges against an attorney if it is notified of their death, but the rules do not require another attorney or family member to share that news, Jennifer Krell Davis, the deputy director of communications for the bar association, told Law.com.
“We do have 108,000 lawyers in Florida,” she said. “There are a lot of individuals that we regulate. We rely on people to inform us.”
Spradley was first suspended by the Florida Supreme Court in March 2018 for failing to respond to a complaint filed against her. Prior to the suspension, the Florida Bar counsel gave her more time to respond after she said she was a victim of domestic violence and looking for a new apartment.
She was suspended again in April 2019 and ordered to pay restitution to two attorneys for making statements that she knew to be “made with reckless disregard as to their truth or falsity.”
The third complaint against Spradley was filed after she failed to notify her clients, judges and attorneys that the bar had twice suspended her license, which resulted in another three-year suspension. She was then disbarred after being held in contempt of the court’s order.
Randolph Braccialarghe, a law professor at the Nova Southeastern University, has worked for the Florida Bar in ethics-related cases for more than 30 years. He described the situation to Law.com as “one of those unfortunate circumstances where there was no way the bar would know.”
“How many lawyers and judges know a tenth of the lawyers practicing in their jurisdiction?” he said.