Raoul Grifoni-Waterman, an attorney who was admitted to practice law in New York in 2020, has successfully resigned from the New York bar for nondisciplinary reasons. The Appellate Division of the Supreme Court of the State of New York made this ruling on October 8, 2026, following Grifoni-Waterman's application. This decision is significant as it highlights the process by which attorneys can resign without facing disciplinary action.
Grifoni-Waterman, who has listed a business address in The Hague, Netherlands, filed his application for resignation with the court, which was not opposed by the Attorney Grievance Committee for the Third Judicial Department. This case is identified under docket number PM-223-26.
The Attorney Grievance Committee (AGC) is responsible for overseeing attorney conduct and ensuring that legal professionals adhere to ethical standards. In this instance, the AGC indicated that they did not oppose Grifoni-Waterman's resignation, which facilitated the court's acceptance of his request.
In his affidavit, sworn on July 21, 2026, and filed on August 5, 2026, Grifoni-Waterman expressed his desire to resign from the bar. The court reviewed his application and the AGC's response before making a decision. The ruling stated, "we grant his application and accept his resignation," indicating that the court found Grifoni-Waterman eligible for resignation without any disciplinary issues.
The judges involved in this ruling included Pritzker, J.P., Ceresia, Fisher, Powers, and Cocoran. They unanimously agreed to grant Grifoni-Waterman's application, which now officially removes him from the roll of attorneys in New York.
As a result of this ruling, Grifoni-Waterman's name has been stricken from the roll of attorneys and counselors-at-law in New York, effective immediately. The court also ordered that he must cease practicing law in any capacity within the state. This means he cannot act as an attorney or provide legal advice in New York.
Furthermore, Grifoni-Waterman is required to surrender any Attorney Secure Pass issued to him within 30 days of the court's decision. This is a standard procedure to ensure that he no longer has access to legal practice resources in New York.
The implications of this ruling extend to other attorneys who may be considering resignation for nondisciplinary reasons. It sets a precedent that the court will consider such applications favorably when there are no ethical violations involved. This decision underscores the importance of maintaining the integrity of the legal profession while allowing for voluntary exits from practice.
Going forward, this ruling may encourage other attorneys in similar situations to pursue resignation without fear of disciplinary repercussions, provided they meet the necessary criteria. It also reinforces the role of the Attorney Grievance Committee in evaluating and responding to such applications.
Details were not available in the court filing regarding whether Grifoni-Waterman has any pending legal matters or if he plans to practice law in another jurisdiction. However, his resignation from the New York bar is now complete, and he must adhere to the court's orders regarding his legal practice.
As for potential appeals, it is unclear if Grifoni-Waterman intends to challenge this decision, but typically, resignations for nondisciplinary reasons are not subject to appeal. The court's acceptance of his resignation is final.