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BOARD NOTES
published by the

Board of Professional Responsibility
of the
Supreme Court of Tennessee

Spring 2021

Inside:
2

Spotlight: 2021 Ethics Workshop

3

It’s Not My Problem…Or Is It?

Chief Disciplinary Counsel, Board of Professional Responsibility

6

Creating a Modern CLE Rule for a
Modern Age

11

Responding to Online Criticism

19

Board of Professional
Responsibility –
New Disciplinary Counsel

“I’m not a cat.” (Link to video) One attorney’s struggle to remove a
filter during a zoom hearing gave us smiles and taught us these lessons:
be competent with technology and professional and compassionate in
dealing with others. I am grateful that during the pandemic, Board of
Professional Responsibility staff have been able to work remotely and
in the office to assist lawyers and judges with registration, ethics
questions and continuing legal education while also protecting the
public by investigating and prosecuting complaints of misconduct. Stay
well and take care.

Greeting from Sandy Garrett

20

Tennessee Lawyers’ Fund for
Client Protection –
New Board Members

22

Board of Professional
Responsibility –
New Board Members

23

Disciplinary Actions
October 2020 - March 2021
1

2021 Ethics Workshop

WE’RE BACK IN
“Bee”siness*
The Board of Professional Responsibility is excited to announce the return of the Ethics Workshop.
After a brief hiatus in 2020 due to the pandemic, the Board is hosting the 2021 Ethics Workshop
on November 12, 2021 in a hybrid format. As always, attendees will have the opportunity to earn
6.5 dual CLE credits. Tickets will go on sale via Eventbrite in early August 2021. Once tickets are
on sale, an email will be sent to all Tennessee attorneys with instructions to register. Stay tuned for
more details in the coming months. Updates will be posted to the Board’s website (www.tbpr.org).

*Bee puns really sting.

2

It’s Not My Problem . . . Or Is It?
Buddy Stockwell
Executive Director, TLAP
In the last five years, TLAP and other state LAPs have witnessed a national mental health and wellbeing movement in the legal profession. Across the nation, courts, bar associations, and bar counsel
have come together to both acknowledge and address the severe mental health and wellness
concerns that are now so prevalent in our profession.
Fortunately, the stigma associated with reaching out for help with mental health issues is waning
somewhat, but there are still major barriers that must be overcome if we are to really heal our
profession.
One barrier is presented when people fail to acknowledge that mental health issues such as addiction
and depression are actual diseases. They may say something like “that person chose to drink too
much alcohol and it’s their fault they became an alcoholic, so why should it be my problem? They
did this to themselves!” The truth is that no one chooses to drink too much and become an alcoholic,
and willpower is ineffective in fighting the disease if you are unfortunate enough to have contracted
it.
The common thread that runs through these types of viewpoints is an underlying tone of “it’s not
my problem.”
Of course, people are certainly entitled to their viewpoints and TLAP fully respects that. But to those
who may feel that the mental health of the profession is not their problem (simply because they are
personally okay), we at TLAP encourage them to seriously reconsider that line of thinking.
The fact is that in the practice of law we often cannot choose who we will or won’t interact with, be
it co-counsel, opposing counsel, or the judge presiding over the matter.
When there is an impaired professional in our ranks, and when we personally encounter them in a
legal case, it can be severely problematic and stressful, tremendously costly to all involved, and can
even block the path to the public’s access to fairness and justice.
An impaired or disruptive lawyer or judge is everyone’s problem.
I have practiced in large firm, small firm, and solo settings. During those years I encountered a few
opposing counsel (and once in a very great while a judge) who were all extremely problematic to deal
with. They all earned widespread reputations in the profession for being “difficult” on one end of
the spectrum or the other. Either they were extremely aggressive and disruptive, or so passive that
moving a case forward seemed impossible . . . and all while the rest of us simply did our best to make
headway while weathering their troublesome behavior.
In such cases, there are also direct monetary costs visited upon our clients in the form of increased
initial client retainers once the opposing lawyer has been identified as routinely disruptive and
difficult, etc.

3

It is certainly an extremely touchy subject, but from a purely clinical viewpoint, it is more likely than
not that some of these unusually disruptive professionals are impaired on some level by a mental
health, addiction, or personality disorder issue that can drive such aberrant behavior.
Law, like any other industry, suffers significant harm from undiagnosed and untreated mental health
issues such as alcoholism, drug addiction, and depression. According to the American Journal of
Preventive Medicine, excessive drinking negatively impacts our bottom lines by as much as $223.5
billion annually.1
As to drug addiction, the National Institute on Drug Abuse cites that drug use disorders (both illicit
and prescription), are very costly to our nation “exacting more than $740 billion annually in costs
related to crime, lost work productivity and health care.”2
Per the American Psychiatric Association Center for Workplace Mental Health: “Depression costs
employers an estimated $44 billion each year in lost productivity. About half of employees with
depression are untreated. Yet with proper treatment, people with depression can get better. The key
is to help employees access effective care.”3
And while all of the above information demonstrates how we are all affected by the problems, TLAP
encourages a shift in everyone’s viewpoint toward solutions and compassion for their brothers and
sisters in the profession who, through no fault of their own, developed mental health issues under
the pressures of practicing law. The ripple effect of recovery is powerful, and we all benefit from it.
In the legal profession here in Tennessee, TLAP is a key to effective care. TLAP is your highly
specialized program that offers professional clinical assistance specifically tailored to the demanding
needs of impaired lawyers and judges. Be it depression, addiction, an anxiety disorder, or some
other mental health issue, TLAP can help that disruptive or disengaged lawyer get better, and that
benefits all of us.
Early intervention is key to reducing consequences and damage to both the person and the
profession. Of course, TLAP encourages people to reach out confidentially before a mental health
issue ripens into a situation that includes both mental health challenges and allegations of unethical
conduct and potential licensure issues. When someone receives confidential and effective clinical
help from TLAP early on, the person, their family, their peers, their clients, the profession, and the
public all benefit. Everyone wins.
But what about the cases where a person was not able to get help early on, and now they face
disciplinary issues in addition to mental health issues? There is still powerful hope and help through
1

https://www.sciencedirect.com/science/article/pii/S0749379711005381

2

https://www.drugabuse.gov/related-topics/trends-statistics

3

http://workplacementalhealth.org/Mental-Health-Topics/Depression

4

TLAP to objectively demonstrate that the person has been reliably diagnosed, successfully treated,
and is being monitored in such a way that fully supports their recovery and fitness to practice law. In
those cases, everyone still wins and successful TLAP monitoring can also be a mitigating factor in
disciplinary matters.
If you think you have (or are concerned about someone else regarding) a problem with alcohol,
drugs, depression, or any other mental health condition, contact TLAP. Your call or email is
confidential. You do not even have to give your name. Whether you need immediate help or want
general information TLAP is there! Call (615) 741-3238 or email to Tlap@tncourts.gov.

5

Creating a Modern CLE Rule for a Modern Age
By Judy Bond-McKissack
Executive Director, Tennessee Commission on CLE
On December 30, 2020, the Commission on Continuing Legal Education (CLE) filed an
amendment to Rule 21. The Supreme Court has established May 17, 2021 as the deadline for any
interested person to file comments with the Court.
The Commission’s petition presents eight (8) proposals to the Court. To assist interested
persons in understanding the proposals, each proposal is discussed below. The Commission hopes
this discussion brings added clarity to the understanding of the Commission’s proposals.
1.
The Proposal to Allow for Partial Year Exemptions
Since the inception of Rule 21, active attorneys have had a mandatory continuing legal
education requirement. That requirement has been a “all or none” continuing legal education
requirement. An attorney must earn and report the required number of credits in the correct
category for each compliance year. This has been true without exception and without regard for any
hardship the attorney may suffer, in particular medical impairments and surgical interventions
needed by an attorney which renders the attorney unable to meet his or her CLE obligation. The
Commission has engaged with attorneys having visual, ambulatory, neurological and other
conditions. As a result of this knowledge the Commission seeks to bring some relief and equity to
the rule in these types of situations. The Commission’s proposal is not intended to address life-long
conditions and eliminate the CLE obligations of those attorneys. Rule 21, Section 3 has long
addressed those attorneys with disabilities and already provides a process that those attorneys can
use to address their needs.
2.
Requests for Accommodations and Exceptional Relief
Rule 21, Section 2.04 grants the Commission the authority to grant exceptional relief for
requests including requests for appropriate waivers, extensions of time, hardship, and extenuating
circumstances. The current regulations under which the Commission operated does not address or
provide any guidance for Commission Members or attorneys about the operation of Rule 21, Section
2.04 and 3.02 (a) and (b). The proposed rule change would give the Commission specific authority
to develop regulations providing detailed information to provide guidance to the Commission, its
staff, and attorneys. In anticipation of this request pending before the Court, the Commission had
drafted and made available on its website a single combined form for attorneys to use to request
relief.

6

3.
Correcting the Omission from the 2019 Rule Change
The Commission’s request to amend Section 4.07(a) is a housekeeping provision intended
to correct an unintended removal of a previously enacted authorization to provide CLE credit to
attorneys serving on the BPR Board or any of its hearing committees. The Commission is asking the
Court to revise this provision and return it to its original position within Rule 21. The Commission
did not discover the omission of the BPR credit provision until it was comparing the proposed rule
to the existing rule. Being unaware of the omission, the Commission had continued to allow CLE
credit for BPR members and committee members and therefore there are not any attorneys who
have suffered a loss of CLE credit. However, the Commission understands that its authority rests
on the language of the rule and that it is necessary to restore this provision to continue to award this
credit. The Commission also recognizes the degree of work being provided by these attorneys to
assist the Court and the Board of Professional Responsibility in carrying out the disciplinary
provisions of its mission.
4.
Revised CLE Credit for Discretionary Credit
a) Pro Bono vs Indigent Defense Credit. Since its inception as part of Rule 21, the
Commission has awarded CLE credit to attorneys who provide Court appointed pro bono work or
pro bono work for organizations who are grantees under the Legal Services Corporation(LSC) Act,
and pro bono mediation services. The list of such organizations has changed over the years as
Tennessee LSC funded organizations have merged however the credit has always been available to
attorneys since the Court mandated three (3) hours of ethics credit each compliance year. When
the rule became effective on December 10, 1998, attorneys were required to provide eight (8) hours
of pro bono work to qualify for one ethics credit. Later, on April 3, 2009, the Supreme Court
decreased the requirement to five (5) hours of pro bono work for each CLE credit. In November of
2014, the Commission conducted an analysis of the impact of Pro Bono work and recommended
that the reduced five (5) for one (1) requirement be made permanent.
b) Indigent Defense credit was allowed at a lower rate because attorneys who provided
indigent defense work also were eligible to receive State compensation for their work. The
Commission is aware that the State awarded compensation has never fully compensated these
attorneys and has not kept up with the rate of inflation and without a COLA adjustment, the attorneys
who provide indigent defense work have worked for many years at a rate that has been inadequate.
The Commission is also mindful of the recent increase in the state rate being paid to attorneys who
provide indigent defense. Despite the increase, the state rate still does not fully compensate these
attorneys. It is the Commission’s hope that the increase int e amount of credit awarded for indigent
defense to match the amount awarded for pro bono work will fill this void)

7

c) As an agency of the Tennessee Supreme Court, the Commission operates at the pleasure
of and the auspices of the Supreme Court. In reviewing the Court’s minutes and history of the award
of CLE credit for Public Service work, the Commission became aware that the current public service
credit was broader than intended based on the history of the discussions by the Court around this
issue. The Commission takes the position that to carry out its mandate, the language of Rule 21
must be revised to carry out the original intent of the Court. Over the years the staff of the
Commission has had conversations with present and past members of the Court and the messaging
around this issue has always been that the discretionary credit is broader than the Court intended
originally and present day.
5.
Clarification Of Course Requirements
Section 5.01(f) clarifies that courses are accredited for a period of one year from the date of
creation of the course and that the course can be re-accredited for an additional year so long as the
course content is current. The Commission has used this same standard for course accreditation
for over thirty (30) years.
In April, 2019, the Commission revised Rule 21 to specify twelve (12) activities that are
eligible for live CLE credit They are found at section 5.01 (g)1-12.
5.01 (g) 1 deletes the reference to the section number of the Regulations which is being
changed by the re-numbering of the proposed revised Regulations which will be submitted to the
Supreme Court.
5.01 (g) 3 clarifies that ethics credit can only be earned for teaching at a law school. The
Commission understands that business, corporate and other behavior directed at how to be a good
corporate citizen may be included in the curriculum at other educational institutions. However, legal
ethics are not the same as business, corporate or other ethical behavior. Continuing Legal
Education’s focus on ethics is that which is focused on the legal obligations of attorneys.
The other changes to section 5.01(g) were discussed above under public service credit.
Section 5.01 (h) simply corrects the case of the verb in the sentence from “is” to “are” and is
housekeeping in nature.
6.
Adding the New Provision to Clarify the Timing of Reporting of CLE Attendance
Attorneys who attend CLE programming have a right and expectation that credit for the
course they have completed will be submitted to the Commission in a timely manner. CLE
providers are aware of the compliance reporting deadlines in the states where they have courses
accredited. They advertise those deadlines as part of the promotion of the CLE Courses they sell.
Despite this knowledge, Commission staff see attendance reporting by some providers months and
years after courses are completed. This late reporting has a direct and detrimental impact on
attorney compliance. The Commission does not have any way of knowing when attorneys complete
courses unless and until that information is reported to the Commission. Therefore, it is essential
that attendance be reported in a timely manner. This new provision will ensure that there is no
ambiguity about when attendance is to be reported.

8

7.

Authorization to Provide Statements, Reports, and other Documents by Electronic

Means.
Since the beginning of the requirement for mandatory continuing legal education, the
Commission has provided reports to attorneys in a paper format. As time has passed, the
Commission had heard complaints from attorneys who are being pushed by the growing and
increasing impact of living in a society where everyone is being pushed to a paperless society. We
are all aware of businesses who have discontinued mailing paper statements and who charge an
additional fee to individuals who do not opt into electronic statements. These changes are driven
by many factors including rapid and easy delivery and reduced economic cost (after implementation)
and a growing desire of many individuals to find a simple, quick solution to the myriad demand
placed on them as part of their daily lives. The Commission is sensitive to and sees the same
pressures. As a result, the Commission placed a notice on its website several years ago alerting
attorneys that the Commission was moving to electronic delivery of documents and encouraging
them to make sure their electronic mail address on record with the Board of Professional
Responsibility was accurate. As an adjunct to this notice, the Commission has been working with a
team of developers to build out new capacity in the MCLE system which would track document
delivery, retain copies of each report, update compliance records when information is updated and
other essential actions. The MCLE system is linked to the Commission’s website. For over ten (10)
years electronic notices have been delivered by e-mail notification through the Commission’s website
notifying attorneys when course attendance posts to their record and when submitted attendance
cannot be posted to their record due to insufficient funds on the attorney account to pay the posting
fee. In addition, over 10 years ago, the Commission began to offer attorneys an electronic survey to
claim non-resident exemption. Currently over 80% of non-resident attorneys choose this option.
The Commission receives electronic messages from these attorneys stating how quick and easy the
process is and thanking the Commission for offering this service.
The Commission has concluded that the time has arrived to take this next step with electronic
delivery of compliance documents. Attorneys licensed in Tennessee have grown accustomed to
electronic delivery of documents related to their licensure. The Department of Revenue moved to
online payment of the professional privilege tax in January 2013. The Board of Professional
Responsibility has offered online registration for an extended period of time and updated their
online filing system in 2017. Both agencies charge attorneys additional fees for paper delivery of
documents.
8.
Requirement to Pay for Attendance at the time of Reporting.
For over ten (10) years Rule 21 has contained a provision requiring attorneys to pay for
attendance at the time the attendance is submitted. The Rule has been silent about the requirement
for providers. That has resulted in providers becoming more and more lax in making timely
payments for attendance that is submitted. Rule 21 Section 8.02 establishes a deadline of thirty (30)
days for providers to report an attorney's attendance at a continuing legal education program. While
it is reasonable and a common business practice to expect a provider to pay for that attendance at
the time it is submitted, the staff of the Commission has observed that providers will submit
attendance and fail to pay the reporting fee for months even after being sent reminders that the fee
is due and that credits do not post to attorney records until paid. The new language makes it clear
9

to providers that payment of attendance fees is required to assure that attorneys receive the benefit
of reported attendance in a timely manner.
The Commission offers the proposed changes as part of its mission to monitor developments
in the operation of Rule 21, to design, promulgate for discussion, test and recommend modifications
to the Supreme Court and to propose changes to modernize the Rule in the best interest of all
participants in the CLE process.

10

Responding to Online Criticism
Steven J. Christopher
Deputy Chief Disciplinary Counsel – Investigations
Board of Professional Responsibility
Purchasers of legal services are increasingly turning to the internet when seeking to find a
lawyer, in the same manner as consumers of other goods and services. Research reveals that an
internet search is now the most popular method of locating a lawyer.4 Thirty eight percent (38%) of
those interviewed in a study by Findlaw.com and Thomson Reuters Corporation stated that they
would search for a lawyer primarily through the internet.5 Twenty nine percent (29%) would seek a
recommendation from a relative or friend, and ten percent (10%) would consult a local bar
association.6 The yellow pages, previously a primary means of locating a lawyer, was only identified
by four percent (4%) of respondents.7 A survey by Software Advice similarly revealed that seventy
five percent (75%) of prospective clients would travel further to seek representation with an attorney
with favorable online reviews over an attorney with negative reviews.8 Research further reveals that
a greater percentage of persons view a lawyer’s website or do a general online search (eighty one
percent (81%) and sixty three percent (63%), respectively) in seeking legal representation, than those
who attempt to locate a lawyer through a referral from a friend or colleague.9
As online searches for legal representation become increasingly pervasive, negative online
reviews by clients and third parties can materially impair a lawyer’s ability to attract new clients.
However, unlike the providers of most other goods and services, a lawyer’s duty of confidentiality
limits the way a lawyer may respond to online critics. While there is not yet any legal authority on
point in Tennessee, the manner in which an attorney may respond to online negative reviews has
been the subject of a number of formal ethics opinions, post prominently in ABA Formal Ethics
Opinion 21-496 (2021), issued January 13, 2021. 10 This article will provide an analysis of an
attorney’s ethical responsibilities in connection with responding to negative online reviews, as well as
a summary of best practices.
The Duty of Confidentiality
The principal ethical rule implicated in responding to negative postings by clients, former
clients, and third parties, is confidentiality. For current clients, lawyers are prohibited from disclosing
“The Internet is Now the Most Popular Way to Find and Research a Lawyer, Says FindLaw Survey,” Press Release, Apr. 17,
2014, http://thomsonreuters.com/press-releases/042014/internet_lawyer_search_survey. Cited in John G. Browning, State Bar of
Texas, 2018 Advanced Fam. L. 22-IV.
4

5

Id.

6

Id.

7

Id.
Cited in “How Should Lawyers Respond to Negative Online Reviews?”, Everest Legal Marketing, Doug Bradley, Nov. 16, 2018.

8

Sherry Karabin, Marketing Legal Services in a Brave New Internet World, Law Technology News (Mar. 31, 2014),
http://www.lawtechnologynews.com/id=1396262346123/Marketing-Legal-Services-in-a-Brave-new-Internet-World. See also John G.
Browning, State Bar of Texas, 2018 Advanced Fam. L. 22-IV.
9

10

ABA Formal Op. 21-496 (Jan. 13, 2021).

11

any information relating to the representation, unless the client gives informed consent to the
disclosure, the disclosure is impliedly authorized to carry out the representation, or one of the
grounds for permissive or mandatory disclosure codified at RPC 1.6(b)-(c) applies.11
The disclosure of information relating to the representation of a former client is governed
by RPC 1.9.12 A lawyer who has formerly represented a client in a matter shall not thereafter reveal
information relating to the representation of the client unless the former client gives informed
consent in writing, disclosure would be permissible or required with respect to a present client under
RPC 1.6, or the information has become generally known. 13 The distinction between a lawyer’s
confidentiality obligations to current and former clients in the context of online reviews will be
discussed in greater detail below.
The confidentiality rule is broadly construed to include information obtained from any
source, not just the client.14 Consequently, the duty of confidentiality is far broader in scope than
attorney-client privilege, which applies only to communications between lawyers and clients for the
purpose of providing legal advice or representation.15 The prohibition not only applies to disclosures
of information relating to the representation, but any disclosure that could reasonably lead to the
discovery of such information by a third party.16 Additionally, disclosure is narrowly construed and
only permitted to the extent reasonably necessary to accomplish one of the enumerated exceptions.17
Consequently, before exercising any ground of permissive or mandatory disclosure, the lawyer
should give significant thought to whether the disclosure is reasonably necessary to effect the purpose
of the exception to disclosure, and whether the objective could be effected by other means.
Within the context of online reviews, an attorney’s duty of confidentiality is therefore
implicated by any statement by the lawyer regarding a client that discloses information relating to the
representation. Consequently, as an attorney is prohibited from disclosing information relating to
the representation, an attorney’s duty of confidentiality will attach to any online review regardless of
whether the reviewer is a current or former client.
Attorneys Are Strongly Discouraged from Seeking a Client’s Waiver of Confidentiality Permitting a
Response to a Negative Review
As indicated above, RPC 1.6(a) provides that an attorney may disclose information relating
to the representation if the client provides informed consent. However, from a practical standpoint,
it can be safely assumed that a client who posts a negative review will not be receptive to an attorney’s
TENN. SUP. CT. R. 8, § 1.6(a). Tennessee’s Rules of Professional Conduct, codified at Rule 8 of the Tennessee Supreme Court
Rules, will be cited herein using the citation form “RPC _._.”The ABA Model Rules of Professional Conduct will be cited herein
using the citation form “Model Rule _._.”
11

12

See RPC 1.6, Comment [20]. “The duty of confidentiality continues after the client-lawyer relationship has terminated.”

13

RPC 1.9(c).

14

RPC 1.6, Comment [3].

15

Id.

RPC 1.6, Comment [4]. “A disclosure of information in a way that cannot reasonably be linked to the client does not reveal
information relating to the representation of a client in violation of RPC 1.6. For example, a lawyer’s use of hypotheticals to discuss
issues relating to the representation is permissible so long as there is no reasonable likelihood that the listener will be able to ascertain
the identity of the client or the situation involved.”
16

17

RPC 1.6 Comment [15].

12

request that the client to waive confidentiality in order to permit the attorney to post a response
which will likely include information disparaging to the client. Additionally, prospectively obtaining
a client’s blanket waiver of confidentiality at the commencement of the representation or otherwise
prior to the circumstances that result in the negative review would not be feasible considering the
requirements for obtaining a client’s informed consent.
“Informed consent” is defined as “the agreement by a person to a proposed course of
conduct after the lawyer has communicated adequate information and explanation about the
material risks of and reasonably available alternatives to the proposed course of conduct.” RPC
1.0(e). A client’s confidentiality waiver is not required to be reduced to writing.18 However, the
guidance provided for obtaining informed consent in the comments to RPC 1.0 places a very high
burden on the attorney.19 It would not be sufficient, for example, for a lawyer to merely include
generalized language in their fee agreement permitting the lawyer to respond to a negative posting if
subsequently made by the client. A lawyer seeking informed consent where required under the
Rules of Professional Conduct is instead required to provide reasonably sufficient information to the
client with regard to their waiver to permit them to make an informed decision.20 Ordinarily, this
will include consultation with the client that explains the advantages and disadvantages of the
proposed waiver, and a discussion of reasonable alternatives. 21 In some circumstances, this
consultation will require the advisability of seeking the advice of independent counsel.22
At the commencement of the representation, the specific circumstances regarding the
attorney’s conduct which ultimately leads to a negative posting could not yet be known or anticipated.
Consequently, the lawyer would not be in a position to obtain informed consent to the waiver of
information relating to the representation, as the information at issue would not yet be known.
Under these circumstances, it is simply not feasible for a lawyer to fulfill the lawyer’s obligations in
seeking an informed waiver of the client’s confidentiality for the purpose of posting a negative review.
The Disclosure of Information for Purposes of Responding To Negative Online Postings Regarding
Current Clients Does Not Fall Within Any Permissive or Mandatory Exception to Tennessee’s
Confidentiality Rule
Of the permissive and mandatory grounds for disclosure of information relating to an
attorney’s representation of a client defined at RPC 1.6(b)-(c), the only ground that would potentially
permit an attorney to respond to online reviews is RPC 1.6(b)(5), which states as follows:
A lawyer may reveal information relating to the representation of a client to the extent the
lawyer reasonably believes necessary to establish a claim or defense on behalf of the lawyer
in a controversy between the lawyer and the client, to establish a defense to a criminal charge
or civil claim against the lawyer based upon conduct in which the client was involved, or to
RPC 1.6(a)(1). There is no discussion of the requirements for obtaining informed consent specific to confidentiality in the comments
to RPC 1.6, but guidance is found in Comments [6] and [7] to RPC 1.0, where “informed consent” is defined. While not directly on
point, the discussion regarding informed consent for conflict waivers at Comments [20] and [22] of RPC 1.7 is also instructive.
18

19

RPC 1.0 Comment [6] and [7].

20

RPC 1.0 Comment [6].

21

Id.

22

Id.

13

respond to allegations in any proceeding concerning the lawyer’s representation of the
client.23
While this exception has not been the subject matter of a formal ethics opinion in Tennessee,
the applicability of this exception to negative online reviews has been analyzed by legal authorities in
a number of jurisdictions, most notably by the American Bar Association in ABA Formal Ethics
Opinion 21-496.24 The overall conclusion reached by the ABA Committee was that the exception
was inapplicable to an attorney responding to online negative reviews, and that as no other permissive
or mandatory ground for disclosure applies, attorneys are strictly prohibited from disclosing any
information relating to the representation solely to respond to a negative online posting.25
The ABA Committee reasoned that a negative online review, standing alone, does not
constitute a “controversy” between a lawyer and client, due to its “informal nature.” 26 Likewise, ABA
Committee argued that the term “proceeding” in Model Rule 1.6(b)(5) is limited to a matter pending
before a tribunal.27 Additionally, even to the extent that a client’s grievance aired on an internet
platform could be construed as a controversy within the scope of Model Rule 1.6(b)(5), a response
by the attorney would not be reasonably necessary to establish a claim or defense by the lawyer.28
For example, a client posting false claims might provide the lawyer with a potential claim for
defamation.29 A responsive posting is not required as a precondition to filing suit, and the lawyer
could pursue other means of addressing the posting, such as a demand letter sent privately to the
client requesting that the post be amended or deleted.
Formal ethics opinions from other jurisdictions have reached the same conclusion as the
ABA Committee in their analyses. 30 For example, the Pennsylvania State Bar Ethics Committee
concluded that an online dispute between lawyer and client regarding the lawyer’s legal services is
not a “controversy” and no “proceeding is pending or imminent just because the client impugns the
lawyer online.” 31 The State Bar of Texas likewise concluded that the exception relating to
RPC 1.6(b)(5).
Tennessee adopted Model Rule 1.6(b)(5), so as the ABA Committee applied the Model Rules of Professional Conduct to its
analysis, this formal ethics opinion is particularly instructive.
23
24

25

ABA Formal Eth. Op. 21-496 (Jan. 13. 2021).

26

Id.

27

Id.

Id. Model Rule 1.6 and RPC 1.6 only permits disclosure of information relating to the representation of a client to the extent
reasonably necessary to effect the purpose of disclosure. See Model Rule 1.6(b)-(c); RPC 1.6(b)-(c).
28

The issue of a lawyer filing a defamation claim against a client for negative online postings is outside the scope of this article. While
the Tennessee Rules of Professional Conduct do not directly address the issue, lawyers should exercise extreme care in fully
considering the implications of threatening or filing suit against clients in light of their ethical requirements.
29

See, e.g., New York State Ethics Op. 1032 (lawyer prohibited from disclosure of confidential information just to respond to only
criticism); Pa. Ethics Op. 2014-200 (lawyer may not give detailed response to online criticism of the lawyer by a client; the self-defense
exception is not triggered solely by a negative online review); W. Va. Legal Ethics Op. 2015-02 (lawyer may respond to online reviews
but may not disclose confidential information while doing so); Los Angeles County Ethics Op. 525 (lawyer can respond online to a
client’s disparaging comments only if confidential information is not disclosed); Fla. Bar Ethics Op. 20-01 (lawyer may not disclose
information relating to a client’s representation in response to a negative online review); State Bar of Tex. Professional Ethics Comm.
Op. No. 662 (lawyer may not publish a response to a former client’s negative review on the internet if the response reveals confidential
information).
30

31

Pa. Ethics Op. 2014-200.

14

controversies between lawyer and client “only applies to formal actions, proceedings, or charges”
and “cannot reasonably be interpreted to allow public disclosure of a former client’s confidences just
because a former client has chosen to make negative comments about the lawyer.”32
Only two jurisdictions, Colorado and the District of Columbia, have reached a contrary
result. In Colorado, Colorado Ethics Op. 136 (2019), the Colorado Ethics Committee concluded
that online criticism could potentially rise to the level to constitute a “controversy.” 33 However, the
drafters encouraged the exercise of caution for attorneys in the information ultimately disclosed.34
This Opinion was cited and discussed unfavorably in the ABA Formal Ethics Op. 496.35
The District of Columbia’s conclusion potentially permitting disclosure of information in
response to online reviews appears to arise out the fact that this jurisdiction’s confidentiality rules
provides broader grounds for disclosure. 36 The District of Columbia’s Rule 1.6(e)(3) provides that a
lawyer may “reveal client confidences to the extent reasonably necessary to respond to specific
allegations by the client concerning the lawyer’s representation of the client.”37 However, the opinion
cautioned that this confidentiality exception excludes “general criticisms” of an attorney and
cautioned that “disclosures should be no greater than the lawyer reasonably believes necessary.” 38
Attorneys who disclose confidential information run the risk of being sanctioned by their
disciplinary authority. Attorneys who have disclosed information relating to the representation of a
client in responding to negative online postings have been disciplined for doing so in a number of
jurisdictions. 39 Appellate Courts have consistently declined to find any applicable exception to
confidentiality in their jurisdiction’s rules to warrant disclosure of client information.40
The Disclosure of Information Regarding Former Clients Also Prohibited
The ABA Committee as well as state jurisdictions analyzing the propriety of attorneys
responding to negative reviews have generally not drawn a distinction between disclosure for
purposes of current and former clients, concluding that disclosure is improper regardless of whether
the representation has concluded. However, Tennessee’s Rule of Professional Conduct 1.9(c),
32

State Bar of Tex. Professional Ethics Comm. Op. No. 662.

33

Colo. Ethics Op. 136 (2019).

34

Id.

35

See ABA Formal Ethics Op. 496, supra.

36

D.C. Bar Formal Ethics Op. 370.

37

Id.

38

Id.

See, e.g., People v. Underhill, 2015 WL 4944102 (Colo. O.P.D.J. Aug. 12, 2015) (lawyer given 18-month suspension for responding
to client online criticism through posting sensitive confidential information); In re Tsamis, Commission No. 2013PR00095 (Ill. 2014)
(lawyer publicly reprimanded for disclosure of confidential information beyond what was reasonably necessary in response to negative
client reviews); In re Quillinan, 20 DB Rptr. 288 (2006) (disciplinary board approved 90-day stipulation to disciplinary suspension
for disclosure of confidential information to worker’s compensation listserv after client terminated lawyer); In re Skinner, 740 S.E.2d
171 (Ga. 2013) (upholding rejection of attorneys’ petition for reprimand by disciplinary board for posting client personal and
confidential information in response to negative reviews); C.f. In re David J. Steele, No. 49800-1509-DI-527 (Ind. 2015) (lawyer
disbarred for manipulation of online reviews and publishing sensitive client information to punish clients for disparaging reviews).
39

40

Id.

15

which governs the scope of confidentiality with regard to former clients, differs from ABA Model
Rule 1.9(c), which has been adopted in most jurisdictions. 41 A separate discussion of whether
attorneys are permitted to respond to negative online postings within the context of Tennessee’s
confidentiality rule regarding former clients is thereby warranted.
Tennessee’s RPC 1.9(c) states as follows:
A lawyer who has formerly represented a client in a matter or shall not thereafter reveal
information relating to the representation or use such information to the disadvantage of the
former client unless the former client gives informed consent, confirmed in writing, the
disclosure would be required or permissible with regard to a current client, or the
information has become generally known.42 [Emphasis added].
The ABA Model Rule 1.9(c), in contrast, states as follows:
A lawyer who has formerly represented a client in a matter or whose present or former firm
has formerly represented a client in a matter shall not thereafter: (1) use information relating
to the representation to the disadvantage of the former client except as these Rules would
permit or require with respect to a client, or when the information has become generally
known; or (2) reveal information relating to the representation except as these Rules would
permit or require with respect to a client.43 [Emphasis added].
Tennessee’s rule provides for a broader exception to confidentiality for former clients than
the Model Rule. Tennessee’s rule permits an attorney to both use or reveal information relating to
the representation of a former client, even where such information is disadvantageous, if the former
client provides informed consent, if the disclosure would be authorized with regard to a present
client under RPC 1.6, or where the information has become “generally known.” 44 Unlike
Tennessee’s rule, the Model Rule distinguishes between the information that may be “used” or
“revealed” with regard to the former client. Information may be used to the disadvantage of the
former client when the information is “generally known,” but the Model Rule does not permit the
attorney from “revealing” the information when generally known.
When an attorney posts a response to a negative review where information relating to the
representation is disclosed, the attorney is revealing the information at issue, not merely using the
information. Consequently, under the ABA Model Rule, the “generally known” exception is
inapplicable and as a result, there was no need for the ABA Committee or those of other jurisdictions
adopting the Model Rule to separately discuss the implications of the generally known standard.
The term “generally known” is not defined in the Tennessee Rules of Professional Conduct
or in the Model Rules. However, the Comments to the Tennessee Rules of Professional Conduct
and that of other jurisdictions would suggest that the term is very narrowly construed.45 The fact that
Model Rule 1.9(c) is the majority rule in most jurisdictions. Research revealed forty-five jurisdictions that have either adopted the
model rule or do not permit revealing information under the “generally known” exception in their RPC 1.9(c).
41

42

RPC 1.9(c)(1)-(3).

43

Model Rule 1.9(c).

44

See RPC 1.9 Comment [8].

RPC 1.9, Comment [8a]. Research did not reveal any substantive distinction between how “generally known” is construed for
purposes of former clients in Tennessee and in other jurisdictions.
45

16

information is public record, standing alone, does not bring the information within the scope of
“generally known.”46
ABA Formal Opinion 479, “The Generally Known Exception to Former-Client
Confidentiality,” provides guidance on the intended scope of this confidentiality exception. The
ABA Committee states that information is generally known if the information is “widely recognized
by members of the public in the relevant geographic area; or is widely recognized in the former
client’s industry, profession, or trade.” The ABA Committee stated that information can become
widely recognized, for example, when promulgated through traditional or online media sources,
including social media. “Information that is publicly available is not necessarily generally known.”47
The ABA Committee cited favorably the following definition from Roy Simon in New York
Rules of Professional Conduct Annotated (2017):
[T]he phrase “generally known” means much more than publicly available or accessible. It
means that the information has already received widespread publicity. For example, a lawyer
worker on a merger with the Fortune 500 company could not whisper a word about it during
the pre-offer stages, but once the offer is made—for example, once AOL and Time Warner
have announced their merger, and the Wall Street Journal has reported it on the front page,
and the client has become a former client—then the lawyer may tell the world. After all, most
of the world already knows.48
The ABA Committee’s narrow reading of “generally known” is mirrored by other jurisdictions in
their formal ethics opinions and in other authorities.49
While the “generally known” exception applies to the revelation of information regarding
former clients, it will rarely, if ever, be applicable in the context of responding to negative online
postings, particularly considering its narrowly construed meaning. The specific information that
would be disclosed for an attorney to counter the information in a client’s negative posting would
most likely involve conduct or communications by the attorney, the client, or third parties not part
of the public record, let alone public knowledge to the degree contemplated by the reading of the
“generally known” exception to the confidentiality rule.
To any extent that the information at issue would fall within the exception, the posting of
information is nonetheless only permissible to the extent reasonably necessary and tailored to effect
the purpose of disclosure. Attorneys should thereby exercise extreme caution in the reliance on this
exception to disclosure for the purpose of responding to online reviews.
What Response Is Permitted?

See id. See also The Generally Known Exception to Former-Client Confidentiality, ABA Formal Ethics Op. 479 (Dec. 15, 2017).
See also RPC 1.9, Comment [8a]. N.Y. State Bar Association Comm. on Prof. Ethics Op. 1057 (June 5, 2015) (“information is not
generally known simply because it is in the public domain or available in a public file”).
46

47

ABA Formal Ethics Op. 479.

48

Id.

See, e.g., N.Y. State Bar Op. 991 (2013)(“information is generally known only if it is known to a sizeable percentage of people in
the local community or in the trade, field, or profession to which the information relates); Ill. State Bar Op. 05-01 (2006)
(“information is generally known if it is common knowledge in the community”).
49

17

While the disclosure of any information relating to the representation of a client for purposes
of responding to an online review is prohibited, the ABA Committee and other legal authorities have
provided suggestions for alternative ways of addressing negative client reviews. It is permissible for
the lawyer to provide the reader with notice that due to their professional constraints under the
applicable rules of confidentiality, the lawyer is prohibited from responding with specificity.50 Such a
disclaimer avoids disclosure of any information relating to the representation while also providing
confirmation to online readers that the attorney is prohibited from providing their side of the story.
While being very careful to avoid disclosing any information relating to the representation, a
number of authorities have also argued that it is permissible for the lawyer, without disclosing
confidential information, to make a generalized response that the post is inaccurate.51 The Texas Bar
recommended the following sample response in its formal ethics opinion:
A lawyer’s duty to keep client confidences has few exceptions and out of an abundance of
caution I do not feel at liberty to respond in a point by point fashion in this forum. Suffice
it to say that I do not believe that the post presents a fair and accurate picture of the events.52
Commentators on the subject of attorney responses to negative online reviews consistently
suggest that it is a better course of action to approach the issue from a business and practical
standpoint rather than an adversarial one.53 The ABA Committee and other commentators have
specifically recommended that many times, no response is the best response.54 Commentators have
argued that as any response will engender further responses in the review thread, particularly from
the already angry reviewer, an attorney’s response will frequently cause the posting to be higher in
the search results for a particular attorney when a prospective client searches for representation
through a general online inquiry. 55 On this basis, it may be the best course of action for an attorney
to simply refrain from responding directly to the post.
Attorneys may also contact the client privately and request that the posting be removed or at
least amended. 56 As internet postings are often made while in a state of heightened emotion, there
is a possibility that a client may have changed their position, particularly if provided with the
attorney’s side of the story. 57 Clients may be particularly receptive to removal or amendment of the
post if the attorney apologizes for any errors in the handling of the matter that may have led to the
negative review and offers to take appropriate remedial action.

50

ABA Formal Op. 21-496. The same suggestion was made in a number of the Formal Ethics Opinions cited above.

See. e.g., Fla. Bar Ethics Op. 20-01 (Oct. 9, 2020) (a lawyer may respond with a general statement that the lawyer is not permitted
to respond as the lawyer would wish but that the online review is neither fair nor accurate).
51

52

Tex. Professional Ethics Comm. Op. No. 662 (Aug. 2016).

53

ABA Formal Eth. Op. 21-496.

54

Id.

55

Id.

56

Doug Bradley, “How Should Lawyers Respond to Negative Online Reviews,” supra.

57

Id.

18

Board of Professional Responsibility
New Disciplinary Counsel
Douglas R. Bergeron joined the Tennessee Board of Professional Responsibility as
Disciplinary Counsel in the Investigations Division in August of 2020. Prior to joining the Board,
Doug focused his twenty-six-year career handling insurance and business defense litigation. Doug
received his B.S. degree in Finance from the University of Central Florida and his law degree from
University of Memphis Cecil C. Humphreys School of Law.

Joe Byrd joined the Board of Professional Responsibility in May 2020. Joe was raised in
suburban Detroit, Michigan and entered the practice of law as a second career after serving as a
pastor and seminary professor. In 2002, he graduated from University of Toledo College of Law
and was admitted to practice in Michigan in 2002 and Tennessee in 2003. Early in his practice he
focused in local government with the Michigan firm of Braunlich, Russow and Braunlich. His family
later relocated to Cleveland, Tennessee where he was staff attorney for the Church of God
Department of Stewardship. He then was an Associate Attorney with Logan Thompson PC where
his primary client was Bradley County serving as County Attorney and Delinquent Tax Attorney.
Joe has been a solo practitioner serving as general counsel for various non-profit organizations while
maintaining a limited probate and estate and elder law practice. He was admitted to practice in
Florida in 2013 and prior to coming to the Board of Professional Responsibility in 2020, he was the
City Attorney for the City of Apopka in Florida.

Jim Milam joined the Office of Disciplinary Counsel in March 2021 and works in the
litigation division where he represents the Board of Professional Responsibility of the Supreme
Court of Tennessee in cases on appeal. Previously, he served for 30 years an Assistant District
Attorney General in the 19th and 20th Judicial Districts, including 15 years as lead prosecutor for
the Fraud and White Collar Crime Unit in the Davidson County District Attorney’s Office. He has
tried dozens of criminal jury trials in his career as a prosecutor. He also has worked as an Assistant
Attorney General handling criminal appeals for the Attorney General’s Office and began his legal
career in private practice in the Chattanooga area. Jim is a native of Nashville and graduated from
the University of North Carolina at Chapel Hill, where he earned both his undergraduate and law
degrees. He is licensed to practice law in Tennessee and Georgia.

19

Tennessee Lawyers’ Fund for Client Protection
New Board Members

Pamela Z. Clary has served as a senior project manager and lead advisor to ComCap
Partners’ municipal finance and economic and community development clients since 2003. Prior
to joining ComCap Partners, Ms. Clary served as Deputy Director of Finance and Deputy Director
of Housing and Community Development for the City of Memphis. Prior to her position with the
City, Ms. Clary was employed by a national municipal financial advisory firm.
Ms. Clary is a graduate of Drexel University (PA) where she received a BS in Design/Textiles
and LaSalle University (PA) where she received a MBA in Finance.
Ms. Clary currently serves on various boards which include the Memphis Shelby County
Airport Authority and the Pension Board and Investment Committee for Memphis Light Gas and
Water. She is certified as an independent registered municipal advisor with the Securities and
Exchange Commission and the Municipal Securities Rulemaking Board, a member of the National
Association of Municipal Advisors and the Urban Land Institute.

Michael G. Curcio, first elected to the Tennessee House of Representatives in 2016,
represents Hickman and parts of Dickson and Maury Counties. As state representative, Michael is
committed to serving the needs of his constituents while bringing common sense conservative
Tennessee values to the legislature.
Michael was the first freshman member in modern history to be appointed chairman of a
committee. In 2018, Michael was appointed Chair of the House Judiciary Committee, at that time
the largest committee in the House of Representatives, overseeing a vast subject matter spanning law
enforcement, the judiciary, an oversight committee designed to protect children and families,
constitutional matters, and our system of civil justice. He currently serves as Chair of the Criminal
Justice Committee.

Amanda Lynn Morse graduated with highest honors from the University of
Tennessee College of Law in 2013. During law school, Ms. Morse interned with the United States
Attorney’s Office of the Eastern District of Tennessee and the Federal Defenders of East Tennessee.
Prior to attending law school, Ms. Morse was a severe child abuse investigator for the Department
of Children Services. Ms. Morse joined the Knox County Law Director’s Office in 2013 and
represents Knox County in a variety of civil legal matters including GTLA cases as well as special
education law.

Quinton E. Thompson is currently a Personal Injury Litigation Associate at Morgan
& Morgan's Memphis office, where he primarily deals with automobile collisions, slip and falls, and
wrongful deaths cases. He earned his B.S. degree from the University of Tennessee Knoxville where
he graduated magna cum laude with degrees in both Business Administration Management and

20

Psychology. Mr. Thompson went on to earn his J.D. from Vanderbilt University Law School in
2015.
In addition to practicing law, Mr. Thompson believes in giving back to his community. He
is the current President of both the Ben F. Jones Chapter of the National Bar Association and the
Young Lawyers Division of the Memphis Bar Association. He is also the former chair and current
member of the Minority Summer Law Internship Committee with the Memphis Bar Association. A
program that places minority high school students with paid legal internships across the city of
Memphis.

21

Board of Professional Responsibility
New Board Members

Sherriff Floyd Bonner Jr. was sworn into office as the 47th sheriff of Shelby County in
2018.
Sheriff Bonner is a second-generation law enforcement officer and a lifelong resident of
Shelby County. Throughout his 41-year career, he has proven to have extensive experience in
leadership and development within law enforcement and jail operations.
After graduating from Hillcrest High School, Floyd Bonner, Jr. earned an Associate degree
in Psychology from Jackson State Community College in Tennessee. Later, His academic studies
were completed at the University of Memphis earning a Bachelor of Arts degree in Criminal Justice.
While handling the job as the Chief Deputy, he attended the Police Leadership Graduate Program
(Southern Police Institute) at the University of Louisville where he was recognized as a Dean’s
Scholar.
Sheriff Bonner and his wife, Audrey, have been married 39 years. They have two sons and
three grandchildren.

Charles K. Grant is a veteran litigator who has tried more than 50 jury trials to verdict
in both federal and state courts, and represented numerous clients in mediation and arbitration
proceedings across more than a dozen states.
Mr. Grant represents clients in complex employment litigation, including collective actions
under the Fair Labor Standards Act, as well as business litigation matters. He is a shareholder in the
Baker, Donelson, Bearman, Caldwell & Berkowitz, PC's Nashville office and a former member of
the Firm's Board of Directors. Mr. Grant's clients also include licensed professionals, such as lawyers,
physicians and dentists, whom he has represented before licensing boards.
Mr. Grant graduated from The Citadel in 1988 and from the Washington and Lee University
School of Law, J.D. in 1991. Mr. Grant was admitted to the practice of law in Tennessee in 1995.

22

Disciplinary Actions
• (October 2020 – March 2021)

PERMANENT DISBARMENTS
JAMES AUSTIN DUKES, BPR #026731
TENNESSEE ATTORNEY
Effective October 9, 2020, James Austin Dukes, of Tangipahoa Parrish, Louisiana, was permanently
disbarred from the practice of law in Tennessee. Mr. Dukes was found guilty of theft of $25,000.00 or more;
theft of assets of aged; and exploitation of the infirmed in Docket 1-703267 in the State of Louisiana, Parish
of Tangipahoa. Mr. Dukes requested to permanently resign from the practice of law in Louisiana in lieu of
discipline. As a result, on July 2, 2020, the Supreme Court of the State of Louisiana entered an order stating
that “James A. Dukes shall be permanently prohibited from practicing law in Louisiana” and “shall be
permanently prohibited from seeking readmission to the practice of law in this state.”
On August 28, 2020, the Supreme Court of Tennessee entered a Notice of Reciprocal Discipline
directing Mr. Dukes to inform the Court within thirty (30) days of receipt of the Notice as to why the discipline
imposed by the Supreme Court of Louisiana should not be imposed by this Court. Mr. Dukes provided no
response to the Supreme Court.
Mr. Dukes must comply with Tennessee Supreme Court Rule 9, Section 28 regarding the obligations
and responsibilities of disbarred attorneys.

MATTHEW DAVID DUNN, BPR #030759
WILLIAMSON COUNTY
Effective January 29, 2021, the Supreme Court of Tennessee permanently disbarred Matthew David
Dunn from the practice of law and ordered him to pay restitution in the amount of $5,995.00 and costs of the
disciplinary proceeding. A Petition for Discipline involving one complaint was filed against Mr. Dunn and
tried before a Hearing Panel.
The Panel found Mr. Dunn accepted a referral from an intermediary organization not properly
registered with the Board, received a fee for services from a client but did not perform any legal services, failed
23

to respond to the client’s requests for information about the representation or communicate in any manner, and
abandoned the client.
The Panel found Mr. Dunn’s conduct violated Tennessee Rules of Professional Conduct 1.3 (diligence),
1.4 (communication), 1.5 (fees), 7.6 (intermediary organizations), and 8.1 (bar admissions and disciplinary
matters).
Mr. Dunn must comply with the requirements of Tennessee Supreme Court Rule 9, Section 28,
regarding the obligations and responsibilities of permanently disbarred attorneys.

JAMES LESTER KENNEDY, BPR #005453
KNOX COUNTY
Effective January 7, 2021, the Supreme Court of Tennessee permanently disbarred James Lester
Kennedy from the practice of law and ordered the costs of the disciplinary proceeding be paid.
A Hearing Panel found Mr. Kennedy distributed attorneys’ fees and personal expenses in a probate
matter to himself and others which were not authorized by the court. The Panel determined Mr. Kennedy
failed to demonstrate good faith, diligence, prudence and caution and also failed to demonstrate loyalty and
fidelity to the estate as required.
Mr. Kennedy violated Tennessee Rules of Professional Conduct 1.3 (Diligence), 3.4 (c) (Fairness to
Opposing Party and Counsel), and 8.4 (c) and (d) (Misconduct).
Mr. Kennedy must comply with the requirements of Tennessee Supreme Court Rule 9, Section 28,
regarding the obligations and responsibilities of disbarred attorneys.

WILLIAM BRANCH LAWSON, BPR #010796
UNICOI COUNTY
Effective October 27, 2020, the Supreme Court of Tennessee permanently disbarred William Branch
Lawson from the practice of law and ordered restitution in the amount of $67,850.00, and costs of the
disciplinary proceeding be paid.
The Board filed a Petition for Discipline against Mr. Lawson consisting of five (5) separate disciplinary
complaints. The Hearing Panel found Mr. Lawson failed to appear in court or provide any legal services for
24

which he was paid fees by clients, failed to refund unearned fees to his clients, misappropriated the fees paid
to him, misappropriated funds held in his trust account for a third party to settle other obligations and cases,
failed to act with diligence in the representation of his clients, abandoned his practice, failed to respond to the
Board’s lawful request for information and engaged in conduct involving dishonesty, fraud, deceit and
misrepresentations in violation of Tennessee Rules of Professional Conduct 1.3 (diligence), 1.5 (fees), 1.15
(safekeeping property and funds), 1.16 (declining or terminating representation) 8.1 (bar admissions and
disciplinary matters), and 8.4(a) and (c) (misconduct).
Mr. Lawson must comply with the requirements of Tennessee Supreme Court Rule 9, Section 28,
regarding the obligations and responsibilities of permanently disbarred attorneys.

JUDSON WHEELER PHILLIPS, BPR #013029
DAVIDSON COUNTY
On February 4, 2021, the Supreme Court of Tennessee permanently disbarred Judson Wheeler Phillips
from the practice of law. Mr. Phillips must pay the court costs within ninety days of the entry of the Order of
Enforcement.
Mr. Phillips consented to permanent disbarment because he could not successfully defend himself on
charges alleged in pending disciplinary complaints. Pursuant to Tennessee Supreme Court Rule 9, Mr. Phillips
is not eligible for reinstatement to the practice of law in this state. Tennessee Supreme Court Rule 9, Section
23, requires Mr. Phillips’ consent to disbarment be maintained under seal.
Mr. Phillips must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28
regarding the obligations and responsibilities of disbarred attorneys.

SUSPENSIONS

CARLA L. AREVALO, BPR #0031003
DAVIDSON COUNTY
On October 30, 2020, the Supreme Court of Tennessee entered an order suspending Carla L. Arevalo
from the practice of law for a period of four (4) years with three (3) years active retroactive to her temporary
25

suspension of January 11, 2018, pursuant to Tennessee Supreme Court Rule 9 Section 12.2. As a condition of
reinstatement, Ms. Arevalo must pay restitution to her client, contact Tennessee Lawyers Assistance Program
for evaluation and reimburse the Board of Professional Responsibility for all costs in the disciplinary
proceeding.
Ms. Arevalo, while suspended for non-payment of the annual registration fee and non-compliance with
IOLTA reporting requirements, engaged in the unauthorized practice of law and accepted fees in two matters.
After Ms. Arevalo was terminated, she failed to promptly return the files to her client as requested and refund
any fees. Ms. Arevalo also failed to respond to the Board concerning the disciplinary complaint.
Ms. Arevalo admitted her conduct violated Rules of Professional Conduct 1.16(d) (declining or
terminating representation); 5.5(a) (unauthorized practice of law); 8.1(b) (bar admission and disciplinary
matters) and 8.4(a) (misconduct).
Ms. Arevalo must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4 regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

DOUGLAS RALPH BEIER, BPR #005777
HAMBLEN COUNTY
On October 2, 2020, the Supreme Court of Tennessee entered an order suspending Douglas Ralph Beier
from the practice of law in Tennessee for a period of two (2) years.
The Supreme Court found that Mr. Beier violated Tennessee Rules of Professional Conduct in two
separate client matters. In the first matter, the Court held that Mr. Beier falsely signed a party’s name to an
affidavit, falsely notarized that same signature, and filed the affidavit in both juvenile and chancery court
without alerting either court that he was the one who applied the signature. The Court found Mr. Beier
violated RPC 3.3(a)(1) (candor toward the tribunal) and 8.4(c) (conduct involving dishonesty, fraud, deceit,
or misrepresentation) in that matter.
In the second matter, the Court held that Mr. Beier, in the representation of a client in probate court,
improperly charged a one-third contingency fee, utilized a fee agreement which was insufficiently clear,
included real property in the estate which passed by operation of law, falsely stated in the petition that his
client was the only heir when he knew of four other half-siblings, failed to inform the court of the other
descendants, and took advantage of his client’s disability in order to charge an unreasonable fee. The Court
found that Mr. Beier violated RPC 1.5(a) (fees), 3.3(a)(1), 3.3(a)(3), and 8.4(a) and (c).
26

Pursuant to Tennessee Supreme Court Rule 9, Section 28.1, the suspension is effective upon entry of
the order by the Court. Mr. Beier must comply with the requirements of Tennessee Supreme Court Rule 9,
Sections 28 and 30.4, regarding the obligations and responsibilities of suspended attorneys and the procedure
for reinstatement.

BRADLEY MICHAEL CARTER BPR #024093
WILLIAMSON COUNTY
On October 9, 2020, the Supreme Court of Tennessee entered an order suspending Bradley Michael
Carter from the practice of law for a period of two (2) years with four (4) months active suspension and the
remainder on probation pursuant to Tennessee Supreme Court Rule 9 Section 12.2, and the payment to the
Board for all costs in the disciplinary proceeding.
Mr. Carter admitted to receiving client fees and failing to properly account to the partners in the firm
for those fees, thereby under-reporting revenue owed to the firm pursuant to the terms of his employment. Mr.
Carter admitted his conduct violated the Rules of Professional Conduct 8.4 (a) and (c) (Misconduct).
Mr. Carter must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4 regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

MARK STEVEN GRAHAM, BPR #011505
KNOX COUNTY
On February 11, 2021, the Tennessee Supreme Court suspended Mark Steven Graham from the practice
of law for three (3) years, retroactive to March 11, 2020, the date of his temporary suspension from the practice
of law. One (1) year shall be served as an active suspension and the remainder on probation. Mr. Graham
must obtain an evaluation with the Tennessee Lawyers Assistance Program, engage a Practice Monitor, pay
restitution, and pay the Board of Professional Responsibility’s costs and expenses and court costs.
On May 8, 2020, a Petition for Discipline was filed against Mr. Graham that included one complaint
of misconduct. Mr. Graham represented a foreign company involved in intellectual property litigation in the
United States. The company retained an expert witness, and the client sent funds to Mr. Graham for payment
of the expert witness fees. Mr. Graham failed to pay the expert as agreed and used a portion of the funds to
pay his outstanding attorney fees.
27

Mr. Graham executed a Conditional Guilty Plea admitting his conduct violated Tennessee Rules of
Professional Conduct 1.15(a), (b) and (d) (safekeeping property and funds) and 8.4(a), and (c) (misconduct).
Mr. Graham shall comply in all aspects with Tennessee Supreme Court Rule 9, Sections 28 and 30.4,
regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

BOBBY GENE GRAY, JR, BPR #011507
MCNAIRY COUNTY
On January 7, 2021, the Supreme Court of Tennessee entered an order suspending Bobby Gene Gray
from the practice of law for a period of three (3) years with eight (8) months active suspension and the
remainder on probation, pursuant to Tennessee Supreme Court Rule 9 Section 12.2, retroactive to May 1, 2020.
Mr. Gray must pay the Board of Professional Responsibility’s costs and expenses and court costs within ninety
days.
Mr. Gray admitted to taking controlled substances from an evidence room while he served as an
assistant district attorney. He entered a plea to official misconduct, theft of less than $1,000.00, and simple
possession of a controlled substance and received judicial diversion.
Mr. Gray executed a conditional guilty plea acknowledging his conduct violated Rules of Professional
Conduct 8.4 (b) and (c) (Misconduct).
Mr. Gray must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4 regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

MATTHEW LEDVINA, BPR #022889
TENNESSEE ATTORNEY
On January 29, 2021, the Tennessee Supreme Court suspended Matthew Ledvina from the practice
of law for six (6) years with four (4) years active suspension and the remainder on probation retroactive to
March 11, 2020. In addition to his suspension, Mr. Ledvina must file a petition to surrender his law license
pursuant to Tennessee Supreme Court Rule 7, Section 15.01.
The Board filed a Petition for Final Discipline against Mr. Ledvina based upon his felony conviction
in the United States District Court for the District of Massachusetts for conspiracy to commit securities fraud.
28

Mr. Ledvina submitted a conditional guilty plea admitting his conduct violated Tennessee Rules of
Professional Conduct 8.4(a), (b) and (c) and agreeing to petition the Supreme Court to surrender his license
to practice law in Tennessee.
Mr. Ledvina must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28
and 30.4, regarding the obligations and responsibilities of suspended attorneys.

JENNIFER LYNN MAYHAM, BPR #034346
LAUDERDALE COUNTY
January 29, 2021, the Supreme Court of Tennessee entered an order suspending Jennifer Lynn Mayham
from the practice of law for a period of five (5) years, with one (1) year active suspension, and the remainder
on probation pursuant to Tennessee Supreme Court Rule 9, Section 12.2. Ms. Mayham was further ordered to
obtain an evaluation with the Tennessee Lawyer’s Assistance Program, engage the services of a Practice
Monitor, pay restitution in the amount of $4,700.00 and reimburse the Board for all costs in the disciplinary
proceeding.
Ms. Mayham was convicted of misdemeanor drug possession and pled guilty to misdemeanor perjury.
Ms. Mayham failed to reasonably communicate with seven clients regarding the status of their case and
accepted retainers, after which she failed to perform the professional services for which she was retained. Ms.
Mayham also failed to respond to the Board’s request for information during the investigation and comply
with the Order of Temporary Suspension entered June 21, 2018.
Ms. Mayham executed a conditional guilty plea admitting her conduct violated Rules of Professional
Conduct (RPC) 1.3 (diligence); 1.4 (communication); 1.16 (declining or terminating representation); 3.3
(candor toward the tribunal); 8.1 (maintaining the integrity of the profession); and 8.4 (a), (b), (c), (d) and (g)
(misconduct).
Ms. Mayham must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4 regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

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TESHAUN DAVID MOORE, BPR #027816
SHELBY COUNTY
On December 11, 2020, the Supreme Court of Tennessee entered an order suspending TeShaun David
Moore from the practice of law for a period of six (6) years with four (4) years active suspension and the
remainder on probation, pursuant to Tennessee Supreme Court Rule 9 Section 12.2, retroactive to March 7,
2018. Mr. Moore was further ordered to obtain an evaluation with the Tennessee Lawyers Assistance Program,
engage the services of a Practice Monitor, and pay restitution. Mr. Moore must pay the Board of Professional
Responsibility’s costs and expenses and court costs within ninety days.
Mr. Moore admitted he failed to distribute funds to multiple clients following settlements, failed to
distribute funds related to liens by insurance companies concerning money held in trust, missed scheduled
court dates, failed to communicate with clients and failed to notify clients he had been suspended from the
practice of law.
Mr. Moore executed a conditional guilty plea acknowledging his conduct violated Rules of Professional
Conduct 1.3 (Diligence), 1.4 (Communication), 1.5 (Fees), 1.15 (Safekeeping Property and Funds), 1.16
(Declining or Terminating Representation), 3.2 (Expediting Litigation), 3.3 (Candor Toward the Tribunal), 4.1
(Truthfulness in Statements to Others), 8.1 (Disciplinary Matters), and 8.4 (Misconduct).
Mr. Moore must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4 regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

ALBERT FITZPATRICK OFFICER, BPR #011629
OVERTON COUNTY
On March 11, 2021, the Supreme Court of Tennessee entered an order suspending Albert Fitzpatrick
Officer, III from the practice of law for a period of six (6) years, with six (6) months active suspension, and
the remainder on probation pursuant to Tennessee Supreme Court Rule 9, Section 12.2. Mr. Officer was
further ordered to continue his monitoring agreement with the Tennessee Lawyers Assistance Program, engage
the services of a Practice Monitor, pay restitution in the amount of $1,250.00, and reimburse the Board for all
costs in the disciplinary proceeding.
Mr. Officer entered a guilty plea to the amended criminal charge of misdemeanor DUI; failed to take
action to prosecute or advance a client’s case; failed to advise his client in a matter that had been appealed,
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failed to file appellate responses resulting in the court removing him as the attorney of record; failed to deposit
client funds into his trust account and appeared in court representing his clients while administratively
suspended.
Mr. Officer executed a conditional guilty plea admitting his conduct violated Rules of Professional
Conduct (RPC) 1.3 (diligence); 1.4 (communication); 1.15 (safekeeping property – failing to deposit clients
funds in his trust account); 1.16 (declining or terminating representation); 3.2 (expediting litigation); 5.5
(unauthorized practice of law); 8.1 (maintaining the integrity of the profession); and 8.4 (a), (b), (c), and (g)
(misconduct).
Mr. Officer must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4 regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

DAVID SCOTT PARSLEY, BPR #013606
DAVIDSON COUNTY
Effective October 12, 2020, the Supreme Court of Tennessee entered an order suspending David Scott
Parsley from the practice of law for one (1) year with three (3) months active suspension and the remainder on
probation. During the period of probation, Mr. Parsley shall meet with a practice monitor monthly.

The

Practice Monitor shall assess Mr. Parsley’s case load, case management, trust account, compliance with trust
account rules, accounting procedures, and office management procedures, in accordance with Tennessee
Supreme Court Rule 9, Section 12.9(b).

Mr. Parsley must pay to the Board all costs in the disciplinary

proceeding.
Mr. Parsley engaged in a business transaction with a client and friend without properly informing them
of the conflict of interest in violation of RPC 1.3 (diligence) and 1.8 (conflict of interest).
Mr. Parsley is immediately suspended from the practice of law and prohibited from using any indicia
of lawyer, legal assistant, or law clerk or maintaining a presence where the practice of law is conducted. Mr.
Parsley must notify all clients being represented in pending matters, as well as co-counsel and opposing counsel
of the Supreme Court’s Order suspending his law license and shall deliver to all clients any papers or property
to which they are entitled.
Mr. Parsley must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28 and
30.4, regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.
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STEPHEN KENNETH PERRY, BPR #022540
TENNESSEE ATTORNEY
On October 2, 2020, the Tennessee Supreme Court suspended Stephen Kenneth Perry of Alexandria,
Virginia from the practice of law for two (2) years, retroactive to the date of his January 2, 2019 temporary
suspension pursuant to Tennessee Supreme Court Rule 9, Section 12.2(b). As a condition of reinstatement,
Mr. Perry must pay restitution to his client and undergo a Tennessee Lawyers Assistance Program evaluation.
Mr. Perry must pay the Board of Professional Responsibility’s costs and expenses and court costs within ninety
days of the entry of the Order of Enforcement.
On July 30, 2019, the Board filed a Petition for Discipline against Mr. Perry. The Petition included
one complaint of misconduct. The Hearing Panel found Mr. Perry essentially abandoned his client’s case and
failed to respond to the Board in violation of Rules of Professional Conduct 1.3 (diligence), 1.4
(communication, 1.5 (fees), 1.16 (terminating representation), 3.2 (expediting litigation), 8.1(b) (bar admission
and disciplinary matters) and 8.4(d) (conduct prejudicial to the administration of justice).
Mr. Perry shall comply in all aspects with Tennessee Supreme Court Rule 9, Sections 28 and 30.4,
regarding the obligations and responsibilities of suspended attorneys and the procedure for reinstatement.

RICHARD LOUIS REYNOLDS, BPR #023174
TENNESSEE ATTORNEY
On March 1, 2021, the Tennessee Supreme Court suspended Richard Louis Reynolds from the practice
of law until further orders of the Court pursuant to Tennessee Supreme Court Rule 9, Section 22.3. Mr.
Reynolds pled guilty and was convicted of Misprision of a Felony in the matter of United States of America v.
Richard Reynolds, Case No. 3:20-CR-00227-M(1), in the United States District Court for the Northern District
of Texas Dallas Division. The Supreme Court’s Order is effective immediately.
Pursuant to the Order of the Supreme Court, the matter has been referred to the Board to institute formal
proceedings to determine the extent of the final discipline to be imposed upon Mr. Reynolds as a result of his
convictions of misdemeanors and a serious crime.
Mr. Reynolds must comply with the requirements of Tennessee Supreme Court Rule 9, Section 28,
regarding the obligations and responsibilities of suspended attorneys.
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WINSTON BRADSHAW SITTON, BPR #018440
DAVIDSON COUNTY
On January 22, 2021, Winston Bradshaw Sitton, an attorney licensed to practice law in Tennessee, was
suspended from the practice of law for four (4) years with one (1) year to be served as an active suspension
and the remainder on probation by Order of the Tennessee Supreme Court. The Court further ordered Mr.
Sitton to pay costs and expenses associated with the case.
On August 23, 2018, a Petition for Discipline was filed against Ms. Sitton concerning one complaint
of misconduct. Mr. Sitton posted a series of public Facebook posts in response to a friend’s inquiry about the
legality of carrying a weapon in her car. Mr. Sitton was aware that the friend had a very contentious and
allegedly abusive relationship with the father of her child. In a series of Facebook posts responding to the
question, Mr. Sitton told her that it was better to get a “taser” or “tear gas.” If she were to get a shotgun, he
said, she should first fill it with rock salt, then bird shot, and then “load for bear.”
Mr. Sitton next posted: If you want to kill him, then lure him into your house and claim he broke in
with intent to do you bodily harm and that you feared for your life. Even with the new stand your ground law,
the castle doctrine is a far safer basis for use of deadly force.
Replying to Mr. Sitton’s post, his Facebook friend commented, “I wish he would try.” Mr. Sitton then
posted: As a lawyer, I advise you to keep mum about this if you are remotely serious. Delete this thread and
keep quiet. Your defense is that you are afraid for your life — revenge or premeditation of any sort will be
used against you at trial.
A hearing panel found that Mr. Sitton violated Tennessee Rules of Professional Conduct 8.4(a) and (d),
misconduct, and recommended that he be suspended from the practice of law for sixty (60) days.
The Tennessee Supreme Court exercised its discretion to review the discipline. Following a review of
the record, the Court observed that practicing law is a privilege and lawyers in any setting — including on
social media — are bound by the ethics rules. The Court held that had Mr. Sitton’s advice been followed, it
could have led to a disastrous outcome and encouraging the Facebook friend to make premeditated use of force
appear as self-defense was “grave misconduct.” Finally, the Court held that posting his bad advice publicly
fostered a cynical perception that the judicial process is corrupt, and lawyers are co-conspirators who help
clients manufacture fake defenses against criminal charges. Based on the Court’s review, the hearing panel’s
proposed sanction of a sixty (60) day suspension was increased to a suspension of four (4) years with one (1)
year to be served as an active suspension and the remainder on probation. Mr. Sitton must comply with
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Tennessee Supreme Court Rule 9, Section 28 regarding the obligations and responsibilities of suspended
attorneys and may not return to the active practice of law until an order of reinstatement has been entered by
the Supreme Court.
Justice Holly Kirby authored the majority opinion for the Court and Justice Sharon Lee filed a separate
opinion concurring in the increase in the sanction.

TEMPORARY SUSPENSIONS
CHARLES DAVID DEAS, BPR #002049
BLOUNT COUNTY
On October 8, 2020, the Supreme Court of Tennessee temporarily suspended Charles David Deas from
the practice of law and ordered him to contact Tennessee Lawyers Assistance Program within ten (10) days of
the entry of the order for evaluation. Based upon the information provided by the Circuit and General Sessions
Courts of Blount County, Tennessee, the Court found Mr. Deas posed a threat of substantial harm to the public,
and a substantial concern had been raised regarding his ability to currently practice law. Section 12.3 of
Supreme Court Rule 9 provides for the immediate summary suspension of an attorney’s license to practice law
in cases where an attorney poses a threat of substantial harm to the public.
Mr. Deas is immediately precluded from accepting any new cases, and he must cease representing
existing clients by November 8, 2020. After November 8, 2020, Mr. Deas shall not use any indicia of lawyer,
legal assistant, or law clerk nor maintain a presence where the practice of law is conducted. Mr. Deas must
notify all clients being represented in pending matters, as well as co-counsel and opposing counsel of the
Supreme Court’s Order suspending his law license and shall deliver to all clients any papers or property to
which they are entitled.
This suspension remains in effect until dissolution or modification by the Supreme Court. Mr. Deas
may for good cause request dissolution or modification of the suspension by petition to the Supreme Court.

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URURA W. MAYERS, BPR #023319
SHELBY COUNTY
On November 30, 2020, the Supreme Court of Tennessee temporarily suspended Urura W. Mayers
from the practice of law upon finding that Ms. Mayers misappropriated funds of a client and poses a threat of
substantial harm to the public. Section 12.3 of Supreme Court Rule 9 provides for the immediate summary
suspension of an attorney’s license to practice law in cases of an attorney’s misappropriation of a client’s
funds.
Ms. Mayers is immediately precluded from accepting any new cases, and she must cease representing
existing clients by December 30, 2020. After December 30, 2020, Ms. Mayers shall not use any indicia of
lawyer, legal assistant, or law clerk nor maintain a presence where the practice of law is conducted.
Ms. Mayers must notify all clients being represented in pending matters, as well as co-counsel and
opposing counsel of the Supreme Court’s Order suspending her law license. Ms. Mayers is required to
deliver to all clients any papers or property to which they are entitled.
Ms. Mayers must comply with the requirements of Tennessee Supreme Court Rule 9, Sections 28
and 12.3(d), regarding the obligations and responsibilities of temporarily suspended attorneys and the
procedure for reinstatement.
This suspension remains in effect until dissolution or modification by the Supreme Court. Ms. Mayers
may for good cause request dissolution or modification of the suspension by petition to the Supreme Court

PUBLIC CENSURES

NICHOLAS D. BUNSTINE BPR #009751
KNOX COUNTY
On January 14, 2021, Nicholas D. Bunstine, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Bunstine represented a client in defense of a civil proceeding brought by the client’s mother for
rescission of a quit claim deed. At all relevant times during the representation, Mr. Bunstine was aware that
his client’s mother was represented by counsel.

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While the suit remained pending, Mr. Bunstine received word from his client that her mother no longer
wished to have the quit claim deed rescinded. Mr. Bunstine prepared an affidavit for the mother’s signature
confirming the mother’s changed position and provided the affidavit to his client. Mr. Bunstine’s client
presented the affidavit to her mother, who proceeded to execute the affidavit. Mr. Bunstine filed a motion to
dismiss the suit based upon the content of the affidavit, which was granted by the Court.
By these acts, Nicholas D. Bunstine, has violated Rules of Professional Conduct 4.2 (communication
with a person represented by counsel), and 8.4(d) (misconduct) and is hereby Publicly Censured for this
violation.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

ADDIE MARIE BURKS, BPR #011805
SHELBY COUNTY
On January 15, 2021, Addie Marie Burks, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Ms. Burks received funds on a client’s case in November 2019, and she delayed distributing the funds
until August 2020. Also, Ms. Burks distributed all the funds directly to the client instead of first resolving
existing medical liens. Ms. Burks did not have a written fee agreement for a contingency fee agreement, and
she commingled a small portion of her fee with client funds when she failed to timely remove her entire fee
from trust. In another matter for the same client, Ms. Burks failed to timely distribute a small amount to a
medical provider for over two years.
By these acts, Addie Marie Burks has violated Rules of Professional Conduct 1.1 (competence), 1.3
(diligence), 1.15 (safekeeping funds), 1.5 (fees) and 8.4(d) (prejudice to the administration of justice) and is
hereby Publicly Censured, with the requirement that she attend the Board of Professional Responsibility’s
Trust Account Workshop scheduled for March 2021.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

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JAMAAL L. BOYKIN, #031037
DAVIDSON COUNTY
On October 23, 2020, Jamaal L. Boykin, an attorney licensed to practice law in Tennessee, received a
Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Boykin was fully retained to represent a client in a bankruptcy proceeding. Mr. Boykin never filed
a bankruptcy petition for his client but led his client to believe that a petition was filed. Mr. Boykin then ceased
communicating with his client and effectively abandoned the representation. In mitigation, Mr. Boykin
corrected the issues which led to his misconduct and provided a full refund to the client.
By these acts, Jamaal L. Boykin has violated Rule of Professional Conduct 1.3 (diligence), 1.4
(communication), 1.5 (fees), 1.16 (terminating representation), and 8.4(a)(c)(d) (misconduct) and is hereby
Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

KATHLEEN LAIRD CALDWELL, BPR #009916
SHELBY COUNTY
On April 1, 2020, Kathleen Laird Caldwell, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Ms. Caldwell verbally agreed to represent a client in a post-conviction criminal case and on appeal for
a flat fee of $7,500.00. Ms. Caldwell’s office received $3,500.00 toward the fee and deposited the refundable
fee directly into an operating account without a written fee agreement signed by the client. Ms. Caldwell met
with the client in the Shelby County Jail but had not reviewed materials related to the client’s criminal case,
had not filed any post-trial motions, had not entered an appearance with the criminal court, and had not begun
the appeal process. Less than one month after the representation began, Ms. Caldwell’s representation was
terminated and the client requested a refund of the unearned portion of the fee. Ms. Caldwell only offered to
refund $950.00 to the client and provided an invoice for services billed at the rate of $300.00 per hour which
Ms. Caldwell acknowledged had never previously been discussed with the client.
By these acts, Kathleen Laird Caldwell has violated Rule of Professional Conduct 1.2 (scope of
representation), 1.4 (communication), 1.5 (fees), and 1.15 (safekeeping property), and is hereby Publicly
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Censured for these violations. As a condition of the Public Censure, Ms. Caldwell shall reimburse $2,750.00
in fees directly to her former client within 120 days less any funds previously refunded by Ms. Caldwell.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

MICHAEL EDWARD CASAS, BPR #019806
KNOXVILLE CORPORATE COUNSEL
On October 23, 2020, Michael Edward Casas, an attorney serving as corporate counsel in Knoxville,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Casas is licensed to practice law in the states of Florida and New York. Mr. Casas accepted a
corporate counsel position in the state of Tennessee without timely registering with the Board of Law
Examiners and the Board of Professional Responsibility. Mr. Casas provided legal services to his employer
for a period of eight (8) months before he completed the proper registration requirements.
By these acts, Michael Edward Casas has violated Rule of Professional Conduct 5.5(a) (unauthorized
practice of law) and is hereby Publicly Censured for this violation.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

WILFRED SHAWN CLELLAND, BPR#014272
HAMILTON COUNTY
On January 20, 2021, Wilfred Shawn Clelland, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Clelland settled a client’s personal injury claim and received settlement funds in August of 2017.
The settlement proceeds were subject to outstanding medical bills and/or liens. Mr. Clelland performed little,
if any, work in negotiating the liens for over three years. He also failed to provide updates to the client, held
settlement funds in his IOLTA account for three years, and provided false or misleading statements to the
client.

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By these acts, Wilfred Shawn Clelland, has violated the following Rules of Professional Conduct: 1.3
(diligence), 1.4 (a)(3) (communication), 1.15 (safekeeping property and funds) and 8.4 (misconduct) and is
hereby Publicly Censured for this violation.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

CHARLES DAVID DEAS, BPR #002049
DAVIDSON COUNTY
On January 26, 2021, Charles David Deas of Maryville, TN, an attorney licensed to practice law in
Tennessee, received a Public Censure from the Board of Professional Responsibility of the Tennessee
Supreme Court.
Mr. Deas deposited his own funds into his trust account in order to issue a cashier’s check from the
account which is a violation of Rule 1.15 (safekeeping funds) and resulted in potential harm to his clients.
Mr. Deas also failed to adequately protect the bank checks for his trust account, and he failed to have proper
procedures in place to make sure his assistant was in compliance with the Rules of Professional Conduct, in
violation of Rule 5.3 (nonlawyer assistance).
By these acts, Charles Deas has violated Rules of Professional Conduct 1.15 (safekeeping funds) and
5.3 (nonlawyer assistance) and is hereby Publicly Censured.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

ELBERT EVERETT EDWARDS, BPR #004364
SHELBY COUNTY
On March 17, 2021, Elbert Everett Edwards, an attorney licensed to practice law in Tennessee,
received a Public Censure from Supreme Court of Tennessee conditioned upon his attending the next Board
of Professional Responsibility Ethics Workshop.
While in private practice, Mr. Edwards worked as a contract attorney for a debt collection company.
Mr. Edwards was retained by the company to collect a debt but never contacted or communicated with the
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client who was unaware of the representation. The client, not having retained Mr. Edwards or executed a
written retainer agreement, objected to the contingency fee charged by Mr. Edwards after successfully
collecting the debt. Mr. Edwards executed a conditional guilty plea admitting his conduct violated RPC 1.2
(Scope of Representation), 1.4 (Communication) and 8.4 (Misconduct).
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

SHANNON DAVID ELSEA, BPR #017346
SHELBY COUNTY
On October 23, 2020, Shannon David Elsea, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
In the representation of a client, Mr. Elsea failed to diligently represent the client’s interests and failed
to adequately communicate with the client. Mr. Elsea also provided deceptive information to both his client
and the Board.
In the representation of a separate client, Mr. Elsea failed to diligently represent the client’s interests,
adequately communicate with the client, or expedite the litigation. Mr. Elsea also deceived his client into
believing a settlement had occurred and deceived the court clerk and opposing counsel as to the true status of
the case which interfered with the timely administration of justice. In mitigation, Mr. Elsea was experiencing
personal issues that caused him undue stress and anxiety which Mr. Elsea is currently addressing.
By these acts, Shannon David Elsea has violated Rule of Professional Conduct 1.3 (diligence), 1.4
(communication), 1.5 (fees), 3.2 (expediting litigation), 4.1 (truthfulness in statements to others), 8.1(b)
(disciplinary matters), and 8.4(a)(c)(d) (misconduct), and is hereby Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

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SAMANTHA FLENER, BPR #038282
DAVIDSON COUNTY
On January 13, 2021, Samantha Flener, an attorney licensed to practice law in Tennessee, received a
Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Ms. Flener was licensed to practice law only in New York when she relocated to Tennessee and began
work at a Tennessee law firm. Ms. Flener applied for permission to be admitted by UBE Score Transfer with
the Board of Law Examiners and her application referenced the need to apply for practice pending admission
if she was currently working in Tennessee as a lawyer or other law-related position. Ms. Flener also certified
on the application that she had read Tennessee Supreme Court Rule 7 and the Board policies and procedures
posted on its website. Ms. Flener did not apply for practice pending admission and was not authorized to
practice law in Tennessee until after she had been employed as a firm lawyer for a period of eight months.
By these acts, Ms. Flener has violated Rule of Professional Conduct 5.5 (unauthorized practice of law)
and is hereby Publicly Censured for this violation.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

JASON RALPH HINES, BPR #028139
ROANE COUNTY
On March 29, 2021, Jason Ralph Hines, an attorney licensed to practice law in Tennessee, received a
Public Censure from Supreme Court of Tennessee and was ordered to pay the costs of the disciplinary action
to the Board of Professional Responsibility.
Mr. Hines, retained in a post-divorce action, engaged in inappropriate text communications with his
client which potentially impaired his professional judgment and that of his client; failed to deposit client funds
into his client trust account; provided inappropriate financial assistance to his client; and failed to promptly
refund advance payment of unearned fees.
Mr. Hines executed a conditional guilty plea admitting his conduct violated Rules of Professional
Conduct 1.7(a) (conflict of interest); 1.15 (a) (safekeeping property); 1.8(3) (conflict of interest: prohibited
transactions); and 1.16(d) (declining or terminating representation).

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A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

PHILLIP GORDON HOLLIS, BPR #007461
BENTON COUNTY
On February 9, 2021, Phillip Gordon Hollis, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Hollis failed to provide notice to his clients, opposing counsel, and the courts that he had been
administratively suspended on March 11, 2020, and his clients were unable to get in touch with him. Mr.
Hollis failed to appear for a scheduled court hearing and subsequently informed the court that he had provided
written notice to his clients of his suspension. On June 23, 2020, Mr. Hollis was ordered by the court to provide
copies of the notices he had provided to his clients but was unable to do so. Mr. Hollis later acknowledged he
had not sent such letters to his clients and was removed as counsel by the court.
By these acts, Mr. Hollis has violated Rule of Professional Conduct 1.3 (diligence), 1.4
(communication), 1.16(d) (terminating representation), 3.2 (expediting litigation), 3.3 (candor toward
tribunal), 3.4(c) (disobeying obligation under rules of tribunal), and 8.4(a)(c)(d) (misconduct) and is hereby
Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

GEORGE TURNER HOWARD, III, BPR #007111
KNOXVILLE COUNTY
On October 16, 2020, George Turner Howard, III, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Howard shared fees with outside counsel without first obtaining the informed consent of his clients
in writing. Mr. Howard also provided financial assistance to clients, held out certain non-lawyer staff as
persons holding corporate officer positions in his firm, and made deceptive statements through his advertising.
Mr. Howard has corrected these issues and has agreed to discontinue such conduct.

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By these acts, George Turner Howard, III has violated Rule of Professional Conduct 1.5(e) (fees),
1.8(e) (conflict of interest), 5.4(d) (professional independence of a lawyer), 7.1 (communications concerning
a lawyer’s services), 7.4 (communication of fields of practice and specialization) and is hereby Publicly
Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

JAMES RANDALL KRENIS, #021563
MADISON COUNTY
On October 23, 2020, James Randall Krenis, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Krenis was paid a portion of a non-refundable fee to assist a client but failed to provide legal
services until the full amount of the non-refundable fee was paid. Mr. Krenis also charged other fees which
were unreasonable. Mr. Krenis later changed the scope of his representation and increased his fees without
obtaining the informed consent of his client in writing or giving his client the opportunity to meet with
independent counsel. Mr. Krenis failed to file any pleadings or make any court appearances on behalf of his
client and failed to adequately communicate with his client about the status of the representation.
By these acts, James Randall Krenis has violated Rule of Professional Conduct 1.2 (scope of
representation), 1.3 (diligence), 1.4 (communication), 1.5 (fees), 1.8(a) (conflict of interest), and 8.4(a)(d)
(misconduct), and is hereby Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

SCOTT DAVID JOHANNESSEN, BPR #026767
DAVIDSON COUNTY
On October 12, 2020, Scott David Johannessen, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Johannessen is the sole member of a limited liability company, and that company is a member of
another company called FYI. On March 2, 2018, Mr. Johannessen was appointed by resolution as the attorney
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for FYI for particular issues. On October 15, 2018, Mr. Johannessen hired an attorney and filed an involuntary
bankruptcy petition against FYI in his role as the sole member of the other limited liability company. On
October 16, 2018, Mr. Johannessen then filed a notice of appearance in the bankruptcy proceeding, as a pro se
creditor of FYI, alleging that there was a debt FYI owed him personally. The bankruptcy of FYI was later
dismissed.
Mr. Johannessen’s filing of an involuntary bankruptcy petition against FYI, in his role as the sole
member of a limited liability company, after a resolution had been passed naming him as FYI’s attorney created
a significant risk that the representation of his client would be materially limited by his interest as sole member
of the other company. Mr. Johannessen’s subsequent notice to also appear on his own behalf in the bankruptcy,
against FYI, created a significant risk that his representation of FYI and his personal interest concerning the
other company would be materially limited by his personal interest as a creditor against FYI.
By these acts, Scott David Johannessen has violated Rules of Professional Conduct 1.7 (conflict of
interest), 8.4(d) (prejudice to the administration of justice) and 1.1 (competence) and is hereby Publicly
Censured.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

LAWRENCE BUFORD HAMMETT, II, BPR #013816
DAVIDSON COUNTY
On January 20, 2021, Lawrence Buford Hammet, II, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Hammet withdrew disputed funds from his client trust account and paid himself a fee which
exceeded the amount that his client alleged was agreed upon at the commencement of the representation. The
client filed a civil suit against Mr. Hammet which was appealed after trial. The Court of Appeals found that
Mr. Hammet failed to keep the disputed funds in his client trust account until the dispute was resolved and that
Mr. Hammet improperly calculated his fees which were unreasonable. The Court of Appeals awarded
judgment to the client in the amount of $67,335.69 and remanded the case to the trial court for a determination
of pre-judgment interest. The trial court subsequently awarded pre-judgment interest to the client in an
additional amount of $22,092.10.
44

By these acts, Lawrence Buford Hammet, II has violated Rule of Professional Conduct 1.5 (fees) and
1.15(e) (safekeeping property) and is hereby Publicly Censured for these violations. As a condition of the
Public Censure, Mr. Hammet shall satisfy the judgments against him on or before January 19, 2021.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

IVAN OMAR LOPEZ, #026441
DAVIDSON COUNTY
On November 12, 2020, Ivan Omar Lopez, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Tennessee Supreme Court pursuant to Tennessee Supreme Court Rule 9, Section
12.4.
The Board of Professional Responsibility filed a Petition for Discipline against Mr. Lopez based upon
his failure to ensure the timely entry of a final decree of divorce in 2015, and his failure to take timely action
in 2019 upon being advised the final decree was not in the court file and had not been entered.
Mr. Lopez executed a conditional guilty plea acknowledging his misconduct violated Tennessee Rules
of Professional Conduct 1.3 (diligence) and 8.4 (d) (misconduct).
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

ERIC JOHN MONTIERTH, BPR #031679
SHELBY COUNTY
On January 12, 2021, Eric John Montierth, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Mr. Montierth failed to timely file an appellate brief in two criminal cases. In both cases, the court
then entered an order directing him to file the brief within ten days. In both cases, Mr. Montierth failed to file
the brief or ask for an extension of time. Almost four months later, the court ordered Mr. Montierth to appear
and explain his conduct in both cases, which he did. The court later accepted the late-filed brief in each case.
Mr. Montierth’s conduct resulted in potential harm to his clients.
45

By these acts, Eric John Montierth has violated Rules of Professional Conduct Rule 1.3 (diligence), 3.2
(expediting litigation), 3.4(c) (fairness to opposing party and counsel) and 8.4(d) (prejudice to the
administration of justice) and is hereby Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

KEISHA MOSES RICHARDSON, BPR #026492
SHELBY

COUNTY

On October 23, 2020, Keisha Moses Richardson, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Ms. Richardson was convicted by a jury of Violation of an Order of Protection which was affirmed on
appeal. Ms. Richardson’s conduct reflected adversely upon her fitness as a lawyer and she failed to respond
to the disciplinary complaint against her.
By these acts, Keisha Moses Richardson has violated Rule of Professional Conduct 8.1(b) (disciplinary
matters) and 8.4(a)(b)(d)(g) (misconduct) and is hereby Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

C. LEANN SMITH, BPR #018899
DAVIDSON COUNTY
On October 21, 2020, C. LeAnn Smith, an attorney licensed to practice law in Tennessee, received a
Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
In a custody matter in which she was a party, Ms. Smith lied under oath in a deposition in response to
six questions about her use of alcohol in the presence of the child. The subject matter of Ms. Smith’s testimony
was relevant to the pending custody matter. In mitigation, Ms. Smith’s conduct was not done in the
representation of a client, and Ms. Smith admitted her conduct under oath in her trial testimony in the same
proceeding.

46

By these acts, C. LeAnn Smith has violated Rule of Professional Conduct 8.4(c) (conduct involving
dishonesty) and 8.4(d) (prejudice to the administration of justice) and is hereby Publicly Censured with the
condition that within sixty days, she schedule and complete an assessment with the Tennessee Lawyers
Assistance Program and follow any recommendation made by TLAP.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

CANDACE LENETTE WILLIAMSON, #028933
TENNESSEE ATTORNEY
On October 23, 2020, Candace Lenette Williamson of Grenada, Mississippi, an attorney licensed to
practice law in Tennessee, received a Public Censure from the Board of Professional Responsibility of the
Tennessee Supreme Court.
Ms. Williamson was paid a fee to represent a client but neglected to take any substantive legal action
on behalf of the client. Ms. Williamson deceived the client into believing that she had filed petitions in both
Mississippi and Tennessee, but no petitions were ever filed. Ms. Williamson thereafter abandoned the
representation and failed to respond to the disciplinary complaint against her.
By these acts, Candace Lenette Williamson has violated Rule of Professional Conduct 1.3 (diligence),
1.4 (communication), 1.5 (fees), 1.16 (terminating representation), 8.1(b) (disciplinary matters) and
8.4(a)(c)(d) (misconduct) and is hereby Publicly Censured for these violations.
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability
to practice law.

CHARLES GAMMONS WRIGHT, BPR #000915
HAMILTON COUNTY
On November 24, 2020, Charles Gammons Wright, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Supreme Court of Tennessee.
The Board of Professional Responsibility filed a Petition for Discipline against Mr. Wright pursuant to
Rule 9 of the Rules of the Supreme Court of Tennessee. A Hearing Panel found Mr. Wright negligently
47

disclosed client confidential information in an affidavit filed with his Motion to Withdraw from representation.
Mr. Wright was ordered to pay the costs of the disciplinary proceeding.
Charles Gammons Wright’s conduct violated Rules of Professional Conduct 1.6 (Confidentiality).
A public censure is a rebuke and warning to the attorney, but it does not affect the attorney’s ability to
practice law.

REINSTATEMENTS

BRADLEY MICHAEL CARTER, BPR #024093
WILLIAMSON COUNTY
By Order of the Tennessee Supreme Court entered February 10, 2021, Bradley Michael Carter was
reinstated to the active practice of law.
On October 9, 2020, Mr. Carter was suspended by the Supreme Court of Tennessee for two (2) years
with four (4) months active suspension. Mr. Carter filed a Petition for Reinstatement to the practice of law
pursuant to Tennessee Supreme Court Rule 9, Section 30.4(c) on January 5, 2021. The Board found the
Petition was satisfactory and submitted an Order of Reinstatement to the Court.

A.SAIS PHILLIPS FINNEY, BPR #028845
SHELBY COUNTY
By Order of the Tennessee Supreme Court entered November 6, 2020, the Tennessee law license of
A. Sais Phillips Finney of Memphis, Tennessee, was reinstated.
Ms. Finney was temporarily suspended from the practice of law by Order of the Supreme Court on
October 29, 2020, for failing to respond to the Board regarding complaints of misconduct. On October 30,
2020, Ms. Finney provided a response to the Board and filed a Petition for Dissolution of Temporary
Suspension. The Board filed an answer acknowledging responses from Ms. Finney were received by the
Board which the Court deemed sufficient for dissolution of the temporary suspension.

48

BOBBY GENE GRAY, BPR #011507
MCNAIRY COUNTY
By Order of the Tennessee Supreme Court entered March 23, 2021, Bobby Gene Gray was reinstated
to the active practice of law.
On January 7, 2021, Mr. Gray was suspended by the Supreme Court of Tennessee for three (3) years
with eight (8) months served as an active suspension, and the remainder on probation. Mr. Gray filed a Petition
for Reinstatement to the practice of law pursuant to Tennessee Supreme Court Rule 9, Section 30.4(c) on
January 28, 2021. The Board found the Petition was satisfactory and submitted an Order of Reinstatement to
the Court.

DAVID SCOTT PARSLEY, BPR #013606
DAVIDSON COUNTY
By Order of the Tennessee Supreme Court entered February 3, 2021, David Scott Parsley was reinstated to the
active practice of law.
On October 12, 2020, Mr. Parsley was suspended by the Supreme Court of Tennessee for one (1) year
with three (3) months active suspension. Mr. Parsley filed a Petition for Reinstatement to the practice of law
pursuant to Tennessee Supreme Court Rule 9, Section 30.4(c) on January 11, 2021. The Board found the
Petition was satisfactory and submitted an Order of Reinstatement to the Court.
The Board filed a Response on July 13, 2020, acknowledging the sufficiency of Mr. Holiday’s response
and no objection to his motion.

49

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