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In the Matter of a Member of the Bar of the Supreme Court of Delaware

2026-08-18

Summary · law.co

Holding. The Delaware Supreme Court approved the Board's conditional admission agreement and order of discipline. DiLeonardo was suspended for six months and one day, and must comply with additional conditions including winding down his practice, paying costs, refraining from managing a law firm or overseeing recordkeeping for one year post-reinstatement, and obtaining certified public accountant pre-certification for two years thereafter. Four counts were dismissed with prejudice as part of the agreement.

Gabriel A. DiLeonardo, Sr., a Delaware attorney, was charged with multiple violations of professional conduct rules stemming from his mishandling of client trust account funds and office recordkeeping at his law firm from 2023 to 2026. The violations included failing to safeguard client funds on multiple occasions by commingling money from different clients, maintaining inadequate books and records, exceeding client account balances when making disbursements, failing to supervise support staff, and making negligent misstatements on his compliance certificates submitted to the Delaware Supreme Court regarding the state of his office records.

Through a conditional admission agreement, DiLeonardo acknowledged eight of the charges against him. The Board applied the ABA Standards for lawyer discipline and determined that suspension was the appropriate sanction given that he engaged in a pattern of misconduct involving client property with multiple violations, though he had no prior disciplinary history. The Board also took into account that DiLeonardo's conduct reflected a refusal to acknowledge the wrongfulness of his actions.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Safeguarding of client trust account funds
  • Maintenance of law office books and records
  • Supervision of nonlawyer staff
  • Accuracy of compliance certifications filed with the court

Procedural posture

The Office of Disciplinary Counsel filed a petition charging DiLeonardo with professional conduct violations; DiLeonardo conditionally admitted to most charges and agreed to a disciplinary sanction with the ODC's consent; the Board held a hearing and approved the conditional admission agreement; the Delaware Supreme Court then reviewed and approved the Board's decision.

Authorities cited

Opinion · public domain

majority opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

IN THE MATTER OF A MEMBER §

OF THE BAR OF THE SUPREME § No. 97, 2026

COURT OF DELAWARE:

Board Case No. 117282-B

GABRIEL A. DILEONARDO, SR.,

CO? Or Or Kr Or

Respondent.

Submitted: August 11, 2026

Decided: August 18, 2026

Before SEITZ, Chief Justice; TRAYNOR and GRIFFITHS, Justices.

ORDER

A panel of the Board on Professional Responsibility (“the Board”) filed

a Report and Approval of Conditional Admission and Order of Discipline by

Consent pursuant to Rules 9(d) and 17(c) of the Lawyers’ Rules of

Disciplinary Procedure (“Report”). Having reviewed the matter under Rule

9(e), the Court approves the Report.

NOW, THEREFORE, IT IS ORDERED that the Board’s Report (copy

attached) is APPROVED. This matter is CLOSED.

BY THE COURT:

/s/ Collins J. Seitz, Jr.

Chief Justice

BOARD ON PROFESSIONAL RESPONSIBILITY

OF THE SUPREME COURT OF THE STATE OF DELAWARE

In the Matter of a

Member of the Bar of

the Supreme Court of

Delaware:

CONFIDENTIAL

GABRIELA. DILEONARDO, SR., Board Case No. 117282-B

Name Nee Nee ee ee ee” eee” eee”

Respondent.

REPORT AND APPROVAL OF CONDITIONAL ADMISSION

AND ORDER OF DISCIPLINE BY CONSENT

1. Pending before a panel of the Board on Professional Responsibility (the “Board”) is a Petition for Discipline in Board Case No. 117282-B (the “Petition”) involving Gabriel A. DiLeonardo, Sr., Esquire (the “Respondent”), a member of the Bar of the Supreme Court of the State of Delaware at all times relevant hereto, having been admitted to practice in Delaware on September 6, 2018 (Bar ID No. 6524).

2. The Petition, which charges the Respondent with violations of Rules 1.15, 5 3, 8.1, and 8.4 of the Delaware Lawyers’ Rules of Professional Conduct (the “DLRPC”) arising out of his handling of the books, records, and the attorney trust account of DiLeonardo Law LLC, is hereby incorporated by reference into the Board’s record in this matter.

3. The Office of Disciplinary Counsel (the “ODC”) has submitted to the Board a Conditional Admission notarized by the Respondent and signed by Respondent’s counsel, and an accompanying Affidavit of Gabriel A. DiLeonardo, Sr. (“Affidavit”), pursuant to Rule 17 of the Delaware Lawyers’ Rules of Disciplinary Procedure (the “Procedural Rules”). The Respondent conditionally admits the following Counts of the Petition:

a. Count I: On at least eight (8) occasions, the Respondent failed to safeguard client funds when he disbursed funds from his lawyer trust account on behalf of one client that relied, in part, on another clients’ trust funds, in violation of DLRPC 1.15(a) (Conditional Admission § 1; Aff. 7 1);

. Count If: The Respondent failed to properly maintain the books and records of DiLeonardo Law LLC from September 2023 until March 2026, in violation of DLRPC 1.15(d) (Conditional Admission 2; Aff.

12);

. Count IV: On at least four (4) occasions, the Respondent disbursed funds from his trust account in excess of those received for a particular client, in violation of DLRPC 1.15(d)(12)(C) (Conditional Admission q 3; Aff. ¥ 3);

. Count V: The Respondent failed to properly supervise nonlawyer assistants related to properly maintaining the books and records of DiLeonardo Law LLC, in violation of DLRPC 5.3 (Conditional

Admission § 4; Aff. ¥ 4);

. Count VIII: The Respondent made negligent misrepresentations regarding the status of DiLeonardo Law LLC’s books and records on his 2024 Certificate of Compliance, which was submitted to the Delaware Supreme Court, in violation of DLRPC 8.4(c) (Conditional Admission 4 5; Aff. J 5);

. Count IX: The Respondent negligently made misrepresentations regarding the status of DiLeonardo Law LLC’s books and records on his 2025 Certificate of Compliance, which was submitted to the Delaware Supreme Court, in violation of DLRPC 8.4(c) (Conditional Admission { 6; Aff. 6);

. Count XI: The Respondent negligently made misrepresentations regarding the status of DiLeonardo Law LLC’s books and records on his 2024 Certificate of Compliance submitted to the Delaware Supreme Court, in violation of DLRPC 8.4(d) (Conditional Admission { 7; Aff. q 7); and

. Count XII: The Respondent negligently made misrepresentations regarding the status of DiLeonardo Law LLC’s books and records on his 2025 Certificate of Compliance submitted to the Delaware Supreme Court, in violation of DLRPC 8.4(d) (Conditional Admission { 8; Aff. 7 8).

. A description of the specific factual allegations and the Counts of the Petition being conditionally admitted is set forth in the Respondent’s attached Affidavit, which constitutes an affidavit of consent under Procedural Rule 17(b).

. The ODC has agreed to the Conditional Admission, including the proposed disciplinary sanction and the enumerated conditions and procedures described in paragraphs 7-9 below. (Conditional Admission { 14.)

. In exchange for the Conditional Admission, and subject to approval by both the Board and the Delaware Supreme Court, the ODC has agreed to dismiss, with prejudice, Counts II, VI, VII, and X of the Petition. (Conditional Admission § 10.)

. In light of the foregoing admitted violations, pursuant to Procedural Rule 8(a)(2), the Respondent agrees to a sanction of suspension for a period of six (6) months and one (1) day. (Conditional Admission { 11; Aff. ¥ 9.)

. Following the period of suspension, the Respondent may petition for reinstatement pursuant to Procedural Rule 22. (Conditional Admission § 12.)

. The Respondent has further agreed to accept, pursuant to Procedural Rules 8(a)(10) and 8(b), the following additional conditions:

a. Pursuant to Procedural Rule 27, the Respondent shall pay all costs associated with these proceedings, promptly upon presentation of a statement by the ODC;

b. The Respondent shall fully cooperate in good faith with a receiver, appointed pursuant to Procedural Rule 24, for the winddown of his current Delaware law practice(s);

c. The Respondent may not serve as the managing partner of a Delaware law firm nor be the Delaware lawyer in charge of books and records for a period of one (1) year after reinstatement;

d. The Respondent shall notify the ODC within thirty (30) days if, at any point after one (1) year from reinstatement, he begins serving as the managing partner of a Delaware law firm and/or he becomes the Delaware lawyer in charge of books and records; and

e. The Respondent shall, for the two (2) years following his becoming the Delaware lawyer in charge of books and records, have completed a precertification by a licensed certified public accountant approved by the Lawyers’ Fund for Client Protection and shall promptly provide the pre-certification report to the ODC.

(Conditional Admission § 13; see also Aff. § 9 (agreeing to accept “the conditions as set forth in the Conditional Admission’’).)

10.The undersigned Panel convened on July 29, 2026 to consider whether to approve the Conditional Admission and proposed sanction pursuant to Procedural Rule 17(c). The Panel deemed admitted into the record solely for the purposes of the Procedural Rule 17(c) hearing, and subject to the terms articulated on the record during the hearing, the following documents:

a. The Petition and ODC’s Exhibits A-JJ;

b. The Respondent’s Answer to the Petition and Respondent’s Exhibits A-T;

c. the Conditional Admission; and

d. the Affidavit.

11.At the hearing, the Panel heard argument from ODC and counsel for the Respondent, as well as a statement from the Respondent, concerning the admissions and the proposed disciplinary sanction, and questioned ODC concerning the circumstances giving rise to the Petition and the Conditional Admission. The Panel also confirmed with Respondent under oath his agreement to the terms of the Conditional Admission and the proposed sanction, including that his agreement to both was made knowingly, freely and voluntarily, after discussing the terms and potential consequences with his Delaware counsel.

12.Under Standard 4.12 of the ABA’s Standards for Imposing Lawyer Sanctions (the “ABA Standards”), “[s]uspension is generally appropriate where a lawyer knows or should know that he is dealing with client property and causes injury or potential injury to a client.” Based on the Conditional Admission, the Panel is satisfied that suspension is appropriate here, in the absence of any ageravating or mitigating factors.

13.In reaching its conclusion as to the disciplinary sanction described herein, and pursuant to Procedural Rule 8(c) and Standard 9.22 of the ABA Standards, the Board considered as aggravating factors (which both the Respondent and ODC agreed applied in this matter): (a) a pattern of misconduct; (b) multiple offenses; and (c) the Respondent’s refusal to acknowledge the wrongful nature of the conduct. (Conditional Admission § 15.) The Board also considered other potential aggravating factors identified in Standard 9.22, but determined that none applied.

14.In reaching the foregoing conclusion as to the disciplinary sanction described herein, and pursuant to Procedural Rule 8(c) and Standard 9.32 of the ABA Standards, the Board considered as a mitigating factor (which both the Respondent and ODC agreed applied to this matter) the absence of a prior disciplinary record. (Conditional Admission § 16.) The Board also considered other potential mitigating factors identified in Standard 9.22, but determined that none applied. The Panel determined that the aggravating factors and the mitigating factor did not compel a sanction more or less severe than the sanction agreed upon by the parties.

15.In considering the proposed sanction, the Board noted that the agreed upon suspension was consistent with precedent from the Delaware Supreme Court for similar violations. See In re Beauregard, 189 A.3d 1236, 1252-53 (Del. 2018); In re Bailey, 821 A.2d 851, 867 (Del. 2003).

16.Having carefully and duly considered all of the issues related to this matter, the Board is satisfied that the disciplinary sanction provided for in the tendered Conditional Admission, as described above, is adequate and appropriate in light of the admissions in, and terms of, the Conditional Admission. WHEREFORE, IT IS HEREBY ORDERED THAT:

1. The tendered Conditional Admission is hereby approved and accepted, pursuant to Procedural Rule 17, and the Conditional Admission and the attached Affidavit are hereby incorporated by reference.

2. In resolution of Counts I, I, IV, V, VI, [X, XI, and XII of the Petition, the Board hereby imposes the sanction of a suspension for a period of six (6) months and one (1) day, pursuant to Procedural Rule 8(a)(2), together with the additional conditions set forth in Paragraph 9 above, grounded upon the Respondent’s admissions that he violated the DLRPC corresponding to each of these Counts. Following the period of suspension, the Respondent may petition for reinstatement pursuant to Procedural Rule 22.

3. In resolution of Counts II, VI, VU, and X of the Petition, the Board hereby dismisses such Counts with prejudice as part of its acceptance and approval of the Conditional Admission and this Order of Discipline by Consent.

4. The Board’s imposition of such sanction is subject to the conditions set forth herein, which, if not complied with, shall be grounds under Procedural Rule 7 for further disciplinary action against the Respondent.

5. Pursuant to Procedural Rule 27 and as described in Paragraph 9(a) above, the Respondent shall pay all costs associated with these proceedings.

6. The Board considers all issues surrounding this disciplinary matter to be resolved by this Report and Order of Discipline by Consent, subject to review by the Delaware Supreme Court pursuant to Procedural Rule 9(e). BOARD ON PROFESSIONAL RESPONSIBILITY

Arthur R. Bookout, Esquire (Chair)

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Michael L. Vild, Esquire

Kristen Voris Kulpers

Dated: “6 /_!\ /e2rL