Disciplinary Counsel v. Alo, 150 Ohio St. 3d 306

Mohammed Noure Alo, admitted 2004, was criminally convicted (guilty plea) for aiding and abetting wire fraud/defrauding citizens of Ohio of the honest services of a public official in a bribery/kickback scheme tied to the state treasurer’s office; he accepted at least $123,622.50 funneled as purported legal fees.
Federal sentencing: 48 months imprisonment, three years supervised release, forfeiture of $123,622.50, and joint/several restitution findings.
Alo had multiple parallel disciplinary actions: interim and indefinite suspensions for failing to answer prior complaints, prior discipline for widespread client misconduct (failure to perform work, retainers kept, failure to refund), and suspension for failing to register as an attorney.
Relator filed a disciplinary complaint based on the criminal conduct; Alo defaulted by not responding, and the Board appointed a master who found the misconduct proven and recommended permanent disbarment.
Board found violations of Prof.Cond.R. 8.4(b), 8.4(c), and 8.4(h); aggravating factors included prior discipline, dishonest/selfish motive, pattern of misconduct, multiple offenses, noncooperation, and client harm; no mitigating factors.
The Ohio Supreme Court adopted the board’s findings and, citing prior precedent where felony convictions or similar schemes led to disbarment, ordered Alo permanently disbarred and taxed costs to him.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Alo’s conduct violate professional rules?	Alo’s felony participation in bribery/kickbacks and admitted receipt of disguised fees violated 8.4(b),(c),(h).	Defaulted; no responsive defense presented.	Yes; clear-and-convincing proof of violations.
Is permanent disbarment appropriate sanction?	Given felony conviction, client-fee misappropriation, prior discipline, pattern, and noncooperation, disbarment is warranted.	Defaulted; no mitigation offered.	Permanent disbarment ordered.
Effect of prior disciplinary findings and client losses	Prior default findings showing retainers kept and client harm aggravate sanction.	No response to contest prior findings.	Prior misconduct and Lawyers’ Fund payments strengthen case for disbarment.
Procedural posture: remand and default process	Relator sought remand to Board for permanent disbarment after interim default suspension.	Alo failed to answer at every stage; did not oppose remand.	Court granted remand, Board/master recommended, and Court adopted recommendation.

Disciplinary Counsel v. Bricker, 137 Ohio St.3d 35, 997 N.E.2d 500 (2013) (recognizing that certain misconduct merits an 8.4(h) violation).
Disciplinary Counsel v. Stern, 106 Ohio St.3d 266, 834 N.E.2d 351 (2005) (attorney felony conviction based on corruption supports disbarment).
Disciplinary Counsel v. Zaccagnini, 130 Ohio St.3d 77, 955 N.E.2d 977 (2011) (disbarment for attorney participation in kickback-driven public-contract scheme).