Matter of Attorneys in Violation of Judiciary Law § 468-a (Zhe Sang)
Docket PM-73-26
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- Filed
- Jurisdiction
- New York
- Court
- Appellate Division of the Supreme Court of the State of New York
- Type
- Opinion
- Case type
- Other
- Disposition
- Granted
- Citation
- 2026 NY Slip Op 02324
- Docket
- PM-73-26
Motion for reinstatement to the practice of law following the court's September 2024 suspension order under Judiciary Law § 468-a and related disciplinary rules.
Summary
The Appellate Division, Third Department granted a petition by suspended attorney Zhe Sang to be reinstated to the practice of law. The court reviewed Sang's affidavit and the Attorney Grievance Committee's response and found by clear and convincing evidence that Sang complied with the suspension order and applicable rules, possesses the required character and fitness, and that reinstatement serves the public interest. The court ordered Sang reinstated effective immediately.
Issues Decided
- Whether the suspended attorney complied with the suspension order and disciplinary rules required for reinstatement.
- Whether the attorney demonstrates the requisite character and fitness to resume practice.
- Whether reinstatement is in the public interest under the rules governing attorney discipline and reinstatement.
Court's Reasoning
The court applied the reinstatement standard in the Rules for Attorney Disciplinary Matters (22 NYCRR § 1240.16[a]) and evaluated the respondent's sworn affidavit alongside the Committee's response. It found by clear and convincing evidence that the respondent complied with the suspension order and court rules, demonstrated character and fitness, and that reinstatement would serve the public interest. Those findings supported immediate reinstatement.
Authorities Cited
- Rules for Attorney Disciplinary Matters22 NYCRR § 1240.16
- Rules of the Appellate Division, Third Department22 NYCRR § 806.16
- Matter of Attorneys in Violation of Judiciary Law § 468-a (prior suspension order)230 AD3d 1498 (3d Dept 2024)
Parties
- Petitioner
- Attorney Grievance Committee for the Third Judicial Department
- Respondent
- Zhe Sang
- Judge
- Clark, J.P.
- Attorney
- Monica A. Duffy (for Attorney Grievance Committee)
Key Dates
- Decision date
- 2026-04-16
- Calendar date
- 2026-03-16
- Respondent affidavit sworn
- 2026-02-03
- Committee responsive correspondence
- 2026-03-12
- Prior suspension order
- 2024-09-01
What You Should Do Next
- 1
Confirm active registration and compliance
The reinstated attorney should ensure their registration and any administrative requirements with the bar and court are current and comply with any conditions of reinstatement.
- 2
Notify clients and courts as appropriate
The attorney should inform former and prospective clients and any courts where matters are pending of their reinstatement and take steps to reengage in representation if appropriate.
- 3
Consult counsel if interested in further review
If any party wishes to challenge the reinstatement, they should consult counsel promptly about possible avenues for review or relief.
Frequently Asked Questions
- What did the court decide?
- The court granted the attorney's motion and reinstated them to practice law effective immediately.
- Who is affected by this decision?
- The reinstated attorney, clients they may represent, and the public, because the attorney may resume legal practice under the court's supervision.
- Why was the attorney reinstated?
- The court found by clear and convincing evidence that the attorney complied with the suspension order and rules, demonstrated the required character and fitness, and that reinstatement was in the public interest.
- Can this decision be appealed?
- Decisions of the Appellate Division on attorney discipline and reinstatement are typically final within that department; further review would require an appropriate application to a higher court.
The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.
Full Filing Text
Matter of Attorneys in Violation of Judiciary Law § 468-a (Zhe Sang) - 2026 NY Slip Op 02324 Matter of Attorneys in Violation of Judiciary Law § 468-a (Zhe Sang) 2026 NY Slip Op 02324 April 16, 2026 Appellate Division, Third Department In the Matter of Attorneys in Violation of Judiciary Law § 468-a. Attorney Grievance Committee for the Third Judicial Department, Petitioner; Zhe Sang, Respondent. (Attorney Registration No. 5256391.) Decided and Entered:April 16, 2026 PM-73-26 Calendar Date: March 16, 2026 Before: Clark, J.P., Reynolds Fitzgerald, Fisher, Powers And Corcoran, JJ., Concur. Monica A. Duffy, Attorney Grievance Committee for the Third Judicial Department, Albany (Alison M. Coan of counsel), for Attorney Grievance Committee for the Third Judicial Department. Zhe Sang, Shanghai, China, respondent pro se. Motion by respondent for an order reinstating them to the practice of law following their suspension by September 2024 order of this Court ( Matter of Attorneys in Violation of Judiciary Law § 468-a , 230 AD3d 1498, 1518 [3d Dept 2024]; see Rules for Atty Disciplinary Matters [22 NYCRR] § 1240.16; Rules of App Div, 3d Dept [22 NYCRR] § 806.16). Upon reading respondent's affidavit sworn to February 3, 2026 and the March 12, 2026 responsive correspondence from the Attorney Grievance Committee for the Third Judicial Department, and having determined, by clear and convincing evidence, that, (1) respondent has complied with the order of suspension and the rules of this Court, (2) respondent has the requisite character and fitness to practice law, and (3) it would be in the public interest to reinstate respondent to the practice of law ( see Rules for Atty Disciplinary Matters [22 NYCRR] § 1240.16 [a]), it is ORDERED that respondent's motion for reinstatement is granted; and it is further ORDERED that respondent is reinstated as an attorney and counselor-at-law, effective immediately. Clark, J.P., Reynolds Fitzgerald, Fisher, Powers and Corcoran, JJ., concur.