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Geauga County Bar Ass'n v. Corrigan
130 Ohio St. 3d 84
| Ohio | 2011
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Background

  • Respondent James G. Corrigan, admitted 1981, subject to a Geauga County Bar Association grievance.
  • Relator alleged Corrigan failed to cooperate in disciplinary investigation after a former client grievance.
  • Board found Corrigan violated Prof.Cond.R. 8.1(b) for knowingly failing to respond.
  • Evidence showed multiple failed contact attempts: letters returned, voicemail issues, and unresponsiveness.
  • Corrigan apologized but did not participate in the committee process; he claimed travel and mail issues but was found uncooperative.
  • Court imposed six-month suspension, stayed in full on condition of no further misconduct; costs taxed to Corrigan.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Corrigan violated Prof.Cond.R. 8.1(b). Corrigan knowingly failed to respond during investigation. Corrigan claimed travel and mail issues prevented timely response. Yes, violation found.
Appropriate sanction for the misconduct. Six-month suspension appropriate. Mitigating factors may favor lighter sanction. Six-month stayed suspension appropriate.
Whether the sanction should be immediate or deferred based on cooperation. Maintain discipline and deterrence. Potential leniency due to lack of prior discipline and mitigation. Stay of six months conditioned on no further misconduct.
Consideration of aggravating vs. mitigating factors. Cooperation lacking; no dishonest motive mitigating. Mitigating factors present; lack of prior discipline. Aggravating factors outweighed by mitigation; still six-month stay.

Key Cases Cited

  • Cleveland Metro. Bar Assn. v. Jaffe, 121 Ohio St.3d 260 (2009-Ohio-763) (analogous six-month stayed suspension for comparable conduct)
  • Mahoning Cty. Bar Assn. v. Jones, 127 Ohio St.3d 424 (2010-Ohio-6024) (six-month stayed suspension for comparable conduct)
  • Stark Cty. Bar Assn. v. Buttacavoli, 96 Ohio St.3d 424 (2002-Ohio-4743) (uses aggravating/mitigating factors framework)
Read the full case

Case Details

Case Name: Geauga County Bar Ass'n v. Corrigan
Court Name: Ohio Supreme Court
Date Published: Sep 22, 2011
Citation: 130 Ohio St. 3d 84
Docket Number: 2011-0706
Court Abbreviation: Ohio