Columbus Bar Ass'n v. Roy, 143 Ohio St. 3d 60

Cynthia Marie Roy, admitted 1982, was the subject of a four-count grievance filed by the Columbus Bar Association arising from representation of Cynthia Murray in a divorce matter.
A probable-cause panel dismissed all counts except an allegation that Roy failed to notify Murray she did not carry professional liability insurance in violation of Prof.Cond.R. 1.4(c).
Roy admitted she lacked professional liability insurance while representing Murray and that she never gave Murray the required notice or obtained a signed acknowledgment.
The board adopted the panel’s findings and recommended a public reprimand.
The Supreme Court of Ohio accepted the board’s findings, found the Prof.Cond.R. 1.4(c) violation, noted mitigating factors (no prior discipline, cooperative, obtained insurance), found no aggravating factors, and imposed a public reprimand and costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Roy violated Prof.Cond.R. 1.4(c) by failing to inform a client she lacked professional liability insurance	Relator: Roy failed to notify Murray as required, so she violated the rule	Roy admitted lack of notice but did not contest relevant facts; no substantive defense to the notification requirement	Court: Roy violated Prof.Cond.R. 1.4(c); finding adopted
Appropriate sanction for the violation	Relator: Public reprimand is appropriate given the misconduct and comparable cases	Roy: Mitigating factors (no prior record, cooperation, obtained insurance) warrant a limited sanction	Court: Public reprimand warranted given misconduct and mitigating factors; costs taxed to Roy

Stark Cty. Bar Assn. v. Buttacavoli, 775 N.E.2d 818 (Ohio 2002) (factors to consider when imposing sanctions)
Disciplinary Counsel v. Broeren, 875 N.E.2d 935 (Ohio 2007) (weighing aggravating and mitigating factors)
Akron Bar Assn. v. DeLoach, 978 N.E.2d 181 (Ohio 2012) (public reprimand for failure to give written notice of lack of professional-liability insurance)