On June 11, 2019 an appellate court upheld the suspension of an attorney for 18 months. During the course of representing a female client in a domestic relations matter, the client and attorney admittedly texted intimate photographs of each other along with sexually explicit messages. The client claimed that they engaged in oral sex in a stairwell at the Courthouse located at 111 Centre Street in Manhattan--which the attorney denied. The matter was brought to the attention of the Attorney Grievance Committee when the attorney failed "to obtain a favorable result in her child support matter and his refusal to refund her retainer".

In summary the client alleged that the attorney: "took my money, sex chat me, collected tons of pictures of my body parts, he had oral sex and he did a bad job on my case." The Court noted that the Rules of Professional Conduct prohibit an attorney from engaging in sexual relations with a client in a domestic relations matter. In The Matter of David Scuderi, 2019 NYSUM 120783