Case Explained: In re MARK ANTHONY KEY

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-28 The fourth-circuit affirmed the imposition of reciprocal attorney discipline against Mark Anthony Key, suspending him from practice before the court until he is reinstated by the North Carolina State Bar. The court held that Key’s failure to timely file required documents in multiple Fourth Circuit cases constituted disciplinable misconduct under Federal Rule of Appellate Procedure 46 and Local Rule 3(b), as such failures demonstrated a lack of diligence and promptness in violation of North Carolina Rule of Professional Conduct 1.3. Regarding the reciprocal suspension, the court applied the standard from *Selling v. Radford*, which presumes that identical discipline is appropriate if the state proceeding provided notice and an opportunity to be heard, the evidence supports the findings, and there is no grave reason to ignore the state’s action. The court found these requirements met, rejecting Key’s arguments that the North Carolina Disciplinary Hearing Commission proceedings lacked due process or sufficient evidence, and noting that Key had full access to discovery and a seven-day hearing. Consequently, the court suspended Key from practice in the Fourth Circuit for the same duration as his North Carolina suspension and declined to impose additional discipline for the filing failures. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.