The Supreme Court of Pennsylvania held that because of the "egregious" nature of the offense an attorney may not rely on purported "mitigating evidence" to avoid disbarment when he perpetrates a fraud on the judicial system by using an impersonator to orchestrate the conviction of one client to benefit another client.
Office of Disciplinary Counsel v. Raiford, 687 A.2d 1118 (Pa. 1997).
Gerald J. Kross,
Professional Ethics - Attorney Misconduct - Rules of Disciplinary Enforcement,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol36/iss3/9