In re Application of McKinney, 981 N.E.2d 847

McKinney applied to take the February 2011 Ohio bar exam; Cincinnati Bar Association disapproved for lack of candor related to her first-year employment termination.
A three-member panel recommended disapproval but allowed a future reapplication for the July 2014 bar exam after full proceedings.
The full Board adopted the panel’s findings but recommended permanent disapproval and barring future reapplication due to dishonesty and evasiveness.
McKinney disputed the permanent bar and sought to take the February 2013 bar exam; the court adopted the Board’s recommendation to disapprove current application but allowed July 2014 reapplication.
Material conduct included creating fictitious letters on firm letterhead to avoid lease liability and deceptive responses about termination during admissions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether McKinney should be disapproved for bar admission.	McKinney argues for eventual admission after reform.	Board concludes she lacks the requisite character and honesty.	Current application disapproved.
Whether McKinney should be forever barred from reapplying.	McKinney urges possibility of future eligibility.	Board recommends permanent disqualification due to deception and evasiveness.	Sustain objection in part; McKinney may reapply for the July 2014 bar exam.
Appropriate path for McKinney to reenter the bar process.	She has matured and should be allowed a later opportunity.	A full character-and-fitness investigation is needed at reapplication.	Permit reapplication for July 2014 with full investigation.

In re Application of Davis, 38 Ohio St.2d 273 (1974) (emphasizes need for full disclosure of past false statements in admission)
Cincinnati Bar Assn. v. Statzer, 101 Ohio St.3d 14 (2003) (deference to panel credibility determinations in disciplinary matters)
Cleveland Bar Assn. v. Cleary, 93 Ohio St.3d 191 (2001) (credibility evaluation in character-and-fitness context)