Geauga County Bar Ass'n v. Haig, 129 Ohio St. 3d 601

Haig, a non-attorney loan officer, drafted legal documents filed in two Geauga County foreclosure cases.
The documents included requests for additional time and answers filed in CitiMortgage, Inc. v. Detweiler and CitiMortgage, Inc. v. Miller.
The Board on the Unauthorized Practice of Law found these actions violated licensure requirements and recommended injunctive relief.
Haig admitted, in a letter to relator, that he did not realize his conduct violated the law.
The Supreme Court adopted the Board’s recommendation, enjoining Haig from further unauthorized practice and declining a civil penalty.
Costs of the proceedings were taxed to Haig.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Haig engaged in unauthorized practice of law by drafting pleadings.	Haig drafted legal documents for others, violating licensure rules.	Haig was unaware his actions were unlawful and did not intend harm.	Haig engaged in unauthorized practice of law
Whether injunction is appropriate without imposing a civil penalty.	Injunction is proper to prevent ongoing UPL.	No civil penalty is required given lack of harm and unintentional conduct.	Injunction issued; no civil penalty imposed
Whether the Board's findings and mitigation are supported by the record.	Record supports UPL and need for relief; mitigation considered.	Cooperation and lack of awareness justify limited sanctions.	Record supports findings; mitigation considered, no penalty

Greenspan v. Third Fed. S. & L. Assn., 122 Ohio St.3d 455, 2009-Ohio-3508, 912 N.E.2d 567 (Ohio 2009) (OC jurisdiction over practice of law and unauthorized practice)
Lorain Cty. Bar Assn. v. Kocak, 121 Ohio St.3d 396, 2009-Ohio-1430, 904 N.E.2d 885 (Ohio 2009) (official authority to police unauthorized practice)
Miami Cty. Bar Assn. v. Wyandt & Silvers, Inc., 107 Ohio St.3d 259, 2005-Ohio-6430, 838 N.E.2d 655 (Ohio 2005) (unauthorized practice includes preparation of documents)