In re Keller, 506 P.3d 1101

Keller (admitted 2004) represented Carmen Vallejos in a 2016–17 estate claim that settled for $350,000 plus clear title to a minivan.
The estate’s representative signed the vehicle title in the wrong box; Keller discovered the error but took no corrective action for eight months.
During that period Keller repeatedly lied to Vallejos about the title’s status; the corrected title was finally delivered in August 2018.
Vallejos filed a grievance; Keller repeatedly failed to cooperate with the Bar’s investigation and produced documents only after a court-ordered motion to compel.
The Disciplinary Board trial panel found violations of RPC 1.3, RPC 8.4(a)(3), and RPC 8.1(a)(2) and imposed a 120-day suspension. Keller conceded the facts and violations but argued the sanction was excessive given minimal actual harm and his remorse.
On de novo review the Oregon Supreme Court found the violations proven by clear and convincing evidence, declined to afford significant weight to remorse, and affirmed a 120-day suspension (to commence 60 days after the decision).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Keller violate RPC 1.3 (neglect)?	Keller knowingly failed for eight months to secure clear title, causing client harm.	Keller admitted facts but portrayed harm as minimal.	Violation proved; acted knowingly; caused actual and potential injury.
Did Keller violate RPC 8.4(a)(3) (dishonesty)?	Keller repeatedly misrepresented status of the title to his client.	Keller conceded misrepresentations but urged mitigation.	Violation proved; misrepresentations were knowing and aggravating.
Did Keller violate RPC 8.1(a)(2) (failure to respond to disciplinary authority)?	Keller provided incomplete responses, ignored inquiries, and resisted discovery until compelled.	Keller offered no adequate explanation for noncooperation.	Violation proved; failure to cooperate was knowing and harmed the disciplinary process.
Was a 120-day suspension appropriate given harms and mitigation (remorse)?	Bar: suspension appropriate given knowing neglect, deception, noncooperation, and aggravating factors.	Keller: lesser sanction warranted because actual monetary harm was minimal and he was remorseful.	Court: 120 days appropriate; remorse given little weight; aggravating factors outweigh mitigation.

In re Schaffner, 323 Or. 472 (1996) (120-day suspension for knowing client neglect plus failure to cooperate)
In re Redden, 342 Or. 393 (2007) (60-day suspension for two-month neglect of a matter)
In re Butler, 324 Or. 69 (1996) (one-year suspension for knowing neglect that led to dismissal and false assurances)
In re Miles, 324 Or. 218 (1996) (120-day suspension for failure to respond to disciplinary requests)
In re Obert, 352 Or. 231 (2012) (six-month suspension for excessive fee and failure to cooperate, plus other competency failures)
In re Obert, 336 Or. 640 (2004) (30-day suspension where much misconduct was negligent and mitigating factors present)
In re Long, 368 Or. 452 (2021) (discussion of ABA Standards framework for sanctions)
In re Devers, 328 Or. 230 (1999) (on weight and proof of mitigating evidence such as cooperation)