Skip to content
A Member of the Law Professor Blogs Network

Interim Suspension Lifted; Reprimand Imposed

The Ohio Supreme Court has publicly reprimanded an attorney and reinstated her from an interim suspension

From January 29 through March 30, 2023, Bryant was hospitalized in a series of hospitals nearly continuously and—with the exception of two to three days—involuntarily.

According to Bryant’s discharge papers, she was diagnosed with bipolar disorder, which was described on at least one occasion as “severe manic bipolar disorder with psychotic behavior.” Bryant was also diagnosed with “[p]sychosis” of “unspecified” type and “major depressive disorder, recurrent.”

 Bryant received notice of this court’s interim-suspension order following her release from the hospital on March 30. A few days later, on April 4 and 5, Bryant called Twin Valley Behavioral Healthcare Hospital and left voicemail messages stating that she was the attorney for A.S., who at that time was a patient at the hospital. Bryant had previously represented A.S. and, at the time she made the phone calls, believed that she was still counsel of record in his case.

The board found by clear and convincing evidence that Bryant made those two calls representing herself as an attorney at a time when she knew that she was under suspension and that her conduct violated Prof.Cond.R. 5.5(a) (prohibiting a lawyer from practicing law in a jurisdiction in violation of the regulation of the legal profession in that jurisdiction). We adopt this finding of misconduct.

Sanction

The parties’ stipulated exhibits include medical records relevant to Bryant’s 2023 hospitalizations that offer insight into her various health conditions. Additionally, the parties have submitted reports from Bryant’s psychiatrist, her primary-care physician, her current and former counselors, and the clinical director of OLAP (who is also a licensed independent social worker), which demonstrate that Bryant is capable of returning to the competent, ethical, and professional practice of law. The board therefore recommends that Bryant be reinstated upon appropriate application and that following her reinstatement, she be required to remain in compliance with her OLAP contract—including all recommended medical and psychiatric treatment—for at least six months. We adopt the board’s recommendations.

(Mike Frisch)