Stark County Bar Ass'n v. Williams, 137 Ohio St. 3d 112

Williams, an Ohio attorney since 1991, engaged in misconduct in seven client matters including misappropriation of funds.
She pled guilty to felony forgery and theft related to some misconduct and is serving an eight-and-a-half-year sentence; interim suspension occurred in 2012.
Board found substantial pattern of dishonesty, neglect, and misappropriation to support a recommendation of indefinite suspension with reinstatement conditions.
Relator objected to the board’s sanction, arguing aggravating factors and precedent require permanent disbarment.
Court adopts most findings but sustains relator’s objection and orders permanent disbarment, with costs taxed to Williams.
Sanction considerations include aggravating factors (dishonest motive, pattern, multiple offenses, lack of cooperation, harm to victims, no restitution) and mitigating factors (absence of prior discipline, reputation, other penalties, acknowledgment of wrongfulness) but no sustained treatment as mitigating under governing rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether misappropriation and pattern of misconduct require disbarment	Williams's pattern and nine aggravators warrant disbarment	Williams argues for lesser sanction due to mitigating factors	Permanent disbarment warranted
Whether mitigating factors offset the presumptive sanction	Mitigating factors insufficient given harm and patterns	Mental disorders and addiction support treatment-based tempering	Mitigating factors do not rebut the presumption; still disbarment
Whether the board properly treated ethical violations across counts	Counts show extensive misconduct across multiple rules	Some counts not charged or proven similarly; some charges dismissed	Court sustains relator’s objection to board’s recommended sanction and disbars
Whether reliance on character testimony outweighed misconduct	Board relied on character witnesses reducing responsibility	Character evidence insufficient to overcome pattern of misappropriation	Character evidence not enough to avoid disbarment

Disciplinary Counsel v. Longino, 128 Ohio St.3d 426 (2011-Ohio-1524) (presumptive disbarment for misappropriation and pattern of misconduct)
Disciplinary Counsel v. Wickerham, 132 Ohio St.3d 205 (2012-Ohio-2580) (pattern of dishonesty and lack of cooperation supports disbarment)
Disciplinary Counsel v. Brickley, 131 Ohio St.3d 228 (2012-Ohio-872) (theft offenses warrant disbarment; restitution and harm considered)
Disciplinary Counsel v. Hoppel, 129 Ohio St.3d 53 (2011-Ohio-2672) (mitigation where sustained treatment and recovery may temper sanction)
Larkin v. Columbus Bar Assn., 128 Ohio St.3d 368 (2011-Ohio-762) (temperance of sanction for addiction not applicable when facts differ)
Disciplinary Counsel v. Thomas, 124 Ohio St.3d 498 (2010-Ohio-604) (indefinite suspension where misappropriation and inability to restitution)
Columbus Bar Assn. v. Crossmock, 111 Ohio St.3d 278 (2006-Ohio-5706) (indefinite suspension for large misappropriation with restitution and treatment lacking)
Disciplinary Counsel v. Kelly, 121 Ohio St.3d 39 (2009-Ohio-317) (general principle for strict discipline in misappropriation cases)