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Cleveland Bar Ass'n v. Baron

Citations: 106 Ohio St. 3d 259; 834 N.E.2d 343Docket: No. 2004-2168

Court: Ohio Supreme Court; September 28, 2005; Ohio; State Supreme Court

Narrative Opinion Summary

In this case, the Cleveland Bar Association charged a non-attorney with unauthorized practice of law. Despite attempts to serve the complaint via certified mail, service was completed through ordinary mail after the defendant failed to sign for it. The defendant, never licensed to practice law, was found to have provided legal advice and assistance in bankruptcy proceedings, including document preparation and fee acceptance, without adhering to federal regulations for bankruptcy petition preparers. Her recommendation to alter a debtor's bankruptcy filing was a key factor in the unauthorized practice finding. After failing to appear in court, she was ordered to return received fees and was fined. The Board on the Unauthorized Practice of Law granted summary judgment, and the court affirmed these findings. As a result, an injunction was issued to prevent future unauthorized legal activities, and the defendant was assessed the costs incurred. The judgment was unanimous, emphasizing that only licensed attorneys may provide legal services in Ohio.

Legal Issues Addressed

Assessment of Costs

Application: The costs incurred during the proceedings were assessed against Baron.

Reasoning: Costs incurred were assessed against her.

Injunction Against Unauthorized Practice

Application: The court issued an injunction preventing Baron from engaging in unauthorized legal activities in the future.

Reasoning: The board concluded that Baron engaged in unauthorized practice and recommended an injunction against her.

Service of Complaint by Ordinary Mail

Application: The complaint was successfully served to Baron via ordinary mail after she failed to sign for certified mail.

Reasoning: Attempts to serve her with the complaint via certified mail failed as she did not sign for it; service was ultimately completed by ordinary mail.

Unauthorized Practice of Law

Application: The court found that engaging in activities such as preparing legal documents, providing legal advice, and accepting fees without a legal license constitutes unauthorized practice of law.

Reasoning: Baron has never been licensed to practice law in Ohio or any jurisdiction. Evidence indicated she assisted at least one debtor in preparing legal documents for bankruptcy, providing legal advice, and accepting fees without complying with federal regulations for bankruptcy petition preparers.