The Ohio Supreme Court reprimanded an attorney for signing a client’s name to an affidavit

The parties stipulated and the board found that in April 2013, Beth Cochran hired Moore to represent her in a child-custody matter involving Cochran’s granddaughter. Cochran told Moore that she had concerns about the child’s safety while she was in the care of her parents. Believing the situation Cochran described was serious and urgent, Moore prepared a motion for emergency custody and an affidavit supporting the motion. Moore signed Cochran’s name to the affidavit without indicating either that the signature was not Cochran’s or that she had signed Cochran’s name with Cochran’s authorization. She then notarized her signing of Cochran’s name, falsely representing that it had been “sworn to and subscribed in” her presence by Cochran. Moore filed the motion and affidavit in the Knox County Juvenile Court on May 1, 2013. The parties stipulated and the board found that by engaging in this conduct, Moore knowingly made a false statement of fact or law to a tribunal in violation of Prof.Cond.R. 3.3(a)(1). We adopt the board’s findings of fact and misconduct.

Sanction

The board adopted the parties’ joint recommendation that Moore be publicly reprimanded for her misconduct. In support of this sanction, the parties and the board noted that we have publicly reprimanded attorneys for similar acts of misconduct—including one case in which the attorney engaged in multiple acts of similar misconduct and another in which the attorney also encouraged her client to lie to the court about who had signed the client’s name on the affidavit…

Having considered Moore’s misconduct, the applicable aggravating and mitigating factors, and the sanctions imposed for comparable misconduct, we agree that the appropriate sanction in this case is a public reprimand.