What is the legal test for disbarring an attorney who has been found in breach of the California Bar Association's discipline guidelines?

In assessing discipline, consideration must be given to a prior disciplinary record, if any. (Lewis v. State Bar (1973) 9 Cal.3d 704, 715, 108 Cal.Rptr. 821, 511 P.2d 1173.) As indicated, petitioner's prior record discloses repeated violations of similar character within the last several years.

Where an attorney has "habitually failed to file necessary documents for his clients, failed to appear at scheduled hearings, misled his clients as to the status of their affairs, and avoided communications by telephone, in writing, and in person," this court has found a willful violation of his oath as an attorney. (Grove v. State Bar (1967) 66 Cal.2d 680, 683, 58 Cal.Rptr. 564, 566, 427 P.2d 164, 166.) "Habitual disregard by an attorney of the interests of clients is ground for disbarment under Business and Professions Code sections 6103 and 6106. Even when such neglect is grossly negligent or careless, rather than willful and dishonest, it is an act of moral turpitude and professional misconduct, justifying disbarment." (Id. at pp. 683-684, 58 Cal.Rptr. at p. 566, 427 P.2d at p. 166.)