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BOARD NOTES

published by the

Board of Professional Responsibility
of the
Supreme Court of Tennessee

Fall 2024

Inside:
2

Spotlight: Tennessee Supreme
Court Approves Adoption of the
“NextGen” Bar Examination

7

The Danger of Generative Artificial
Intelligence Hallucinations in Legal
Practice

20

Board of Professional
Responsibility’s 2024 Ethics
Workshop November 1

23

Board of Professional
Responsibility’s Trust Account
Workshop December 4

24

Board of Professional
Responsibility’s 43rd Annual
Report

37

Tennessee Lawyers’ Fund for Client
Protection 2024 Annual Report

39

Disciplinary Actions April –
September 2024

67

Tennessee Lawyers’ Fund for Client
Protection Payments

Greeting from Justice Jeffrey Bivins

Supreme Court Liaison, Board of Professional Responsibility
It is a privilege for me to return as the Tennessee Supreme Court’s
liaison to the Board of Professional Responsibility. Though several
years have passed since I last served in this role, one constant
remains: the unwavering dedication of the staff and board members
of the Tennessee Board of Professional Responsibility. Through
providing ethics opinions, responding to ethics inquires, conducting
ethics seminars, and publishing this newsletter, the Board serves as
a valuable resource for Tennessee lawyers, judges, and the public.
Their work is vital in upholding the integrity of our legal system.
I’d like to thank Justice Roger Page for his service as liaison to the
Board over the last year. His involvement with the Board is one of
the many contributions he made to Tennessee’s justice system during
his eight years on the Tennessee Supreme Court. We also
congratulate him on his well-deserved retirement from the Court.
The Board and I hope that this edition of Board Notes will provide
helpful insights to you as we all work together to advance justice in
Tennessee. Thank you for your continued dedication to our
profession and the public.

Tennessee Supreme Court Approves
Adoption of the “NextGen” Bar Examination
Lisa Perlen, Executive Director
Tennessee Board of Law Examiners

In April, 2024, the Tennessee Supreme Court approved adoption of the updated bar
examination, the “NextGen Bar Exam,” beginning with the July 2027 administration of the
examination. 1 This article will provide some history on the bar examination in Tennessee, the
Tennessee Supreme Court’s adoption of examination materials developed by the National
Conference of Bar Examiners (“NCBE”), the development of the NextGen Bar Exam, and what
adoption of the NextGen Bar Exam in Tennessee means.
The NCBE was established in 1931 with the goal of “increasing efficiency of the state bar
admissions boards.” The NCBE has long provided research, character and fitness investigation
services, and training and support to jurisdictions. In 1969, the NCBE established a committee to
study the bar examining process, including the “possibility of creating a uniform multiple-choice
bar examination that could help reduce the grading burden for jurisdictions.” 2 The NCBE Board
of Managers, in 1970, established a committee to begin development of a “six-hour multiplechoice bar examination” with input from bar examiners and law school deans and faculty on
content and drafting.3
The first Multistate Bar Examination (MBE), consisting of 200 multiple-choice questions
covering Contracts, Criminal Law, Evidence, Real Property, and Torts, was administered in 1972
to 4,955 examinees from 19 jurisdictions, including Tennessee. 4 In 1982, 10 years after the first
administration of the MBE, the NCBE completed a content validity study, with findings that were
“strongly supportive of the structure, format, and content of the MBE . . .”5 The content validity
The Supreme Court Press release can be found here: https://www.tncourts.gov/press/2024/04/22/tennesseesupreme-court-adopts-updated-bar-examination.
2
“NCBE Testing Milestones,” https://nextgenbarexam.ncbex.org/wp-content/uploads/NCBE-Testing-ProgramTimeline.pdf.
3
Id.
4
The Bar Examiner print edition, Fall 2022 (Vol. 91, No. 3), pp. 7–12. The article can be found online at
https://thebarexaminer.ncbex.org/article/fall-2022/celebrating-50-years-mbe/.
5
Id.
1

2

study had been completed every ten years. By 1997, 52 U.S. jurisdictions were using the MBE as
part of their state bar examination.
Over the years, the subjects tested on the MBE changed, the process of scoring the MBE
evolved, and the question development process progressed to include pretesting of items, all to
adapt to the changing landscape of standardized testing. Pretesting MBE items by actual bar
examinees is a critical component of test development as it allows the psychometricians (the
scientists who design, develop, study, analyze, and validate assessments such as those used for the
bar examination) to determine if the pretested item is an appropriate measure of performance of
entry-level lawyers. 6
In addition to the MBE, the NCBE developed the Multistate Essay Examination (“MEE”),
first administered in six jurisdictions in 1988, and the Multistate Performance Test (MPT), first
used by four jurisdictions in 1997.7
Tennessee continued to use the MBE with 12 locally developed essay questions until 2011,
when one MPT question was added to the Tennessee bar examination in place of three of the local
essay questions. At the same time, Tennessee began scaling the written components of the
examination to the MBE score to establish a single score. 8
In April 2018, the Tennessee Supreme Court adopted the Uniform Bar Examination
(“UBE”), joining 31 other jurisdictions in administering the MBE, MPT, and MEE so that the
resulting score could be transferred to other jurisdictions. The first UBE administration in
Tennessee was in February 2019. At the same time, the Board of Law Examiners developed the
Tennessee Law Course for all new admittees, including those admitted by examination, comity, or
transferred UBE score, to provide a course of study in Tennessee-specific law and practice.
Adoption of the UBE and the Tennessee Law Course provide the necessary balance to ensure that

Beth E. Donahue, “Recent Changes in NCBE’s Multiple-Choice Examination Programs,” 77(3) The Bar
Examiner print edition, 25–30 (August 2008).
7
For the current examination, the MEE consists of 6 essay questions given in a 3-hour period and answered based
on generally accepted fundamental legal principles. The MPT consists of a File and a Library. The File contains the
instructions for the task the examinee must complete and factual information about the case, both relevant and not
relevant. The Library contains legal authorities, again relevant and not relevant. Cases may be real, modified, or
created for the examination. Examinees are given 2 MPT items in a 3-hour period.
8
For more on score scaling, please see Rosemary Resehtar, The Bar Examiner print edition, Summer 2023 (Vol. 92,
No. 2), pp. 35–36. The article can be found online at https://thebarexaminer.ncbex.org/article/summer-2023/thetesting-column-assessment-scales-what-they-are-and-what-goes-into-them/.
6

3

members of the public are represented by qualified attorneys.9 As of the end of 2023, 1,453 UBE
scores have been transferred to or from Tennessee. 10
In 2018, with many professions changing their professional examination models, the NCBE
Board of Trustees established the Testing Task Force to undertake a multi-year study “to ensure
that the bar examination continues to test the knowledge, skills, and abilities required for
competent entry-level legal practice in the 21st century.” The Testing Task Force engaged in
listening sessions with key stakeholders and practice analysis and, using the information compiled
from the listening sessions and practice analysis, made recommendations regarding exam content
and test design. The research was “undertaken to identify the legal knowledge and skills entrylevel attorneys are expected to have or learn within the first three years of practice, and to determine
whether, how, and when those identified competencies should be assessed on a bar examination.”11
Ultimately, the Testing Task Force recommended a modified bar examination with integrated
question sets that will test a broad range of foundational lawyering skills and that will balance the
skills and knowledge needed in litigation and transactional legal practice.
Since the Report of the Testing Task Force was released in April 2021, the NCBE has been
actively engaged in developing the NextGen Bar Exam, in conjunction with law school faculty,
bar examiners, practicing attorneys, and other professionals. Foundational Concepts and Principles
and Foundational Skills have been published, with preliminary Content Scope Outlines published
in early 2022. Foundational concepts and principles include civil procedure, contract law,
evidence, torts, business associations, constitutional law, real property and, beginning in July 2028,
family law. Foundational lawyering skills have been identified as legal research, legal writing,
issue spotting and analysis, investigation and evaluation, client counseling and advising,
negotiation and dispute resolution, client relationship, and management. Links to the Content
Scope

and

the

preliminary

outlines

can

be

found

at

https://nextgenbarexam.ncbex.org/reports/content-scope/.
To date, the NCBE has conducted pilot testing and field testing, focused on development of

The Supreme Court Press release can be found here: https://tncourts.gov/news/2018/04/18/tennessee-adoptsuniform-bar-exam.
10
https://thebarexaminer.ncbex.org/statistics/. Note that all applicants for admission must meet the character and
fitness standard found in Tenn. Sup. Ct. R. 7, § 6.01, which includes a background investigation.
11
“Foreword of the Testing Task Force Chair,” https://nextgenbarexam.ncbex.org/reports/final-report-of-the-ttf/.
The full report of the Testing Task Force was released in April 2021.
9

4

new question formats, exam delivery, grading rubrics, and initial performance statistics, as well as
operational constructs. From this research, the NextGen Bar Exam has been developed as a
computer-based, in-person administration, given over 1.5 days in three-hour segments with a lunch
break between the two segments on day one.
The exam will employ a mix of multiple-choice and other question types that can be
machine scored, and constructed-response questions that will be graded by local graders, as MEE
and MPT items are graded currently. Approximately 40% of the exam time will consist of standalone multiple-choice questions with four to six answer options and one or more correct answers.
The NextGen Bar Exam will include use of “Integrated Questions Sets” which use a common fact
scenario and, in some instances, legal resources and/or supplemental documents, as the basis for a
mix of multiple-choice and short answer questions, and may be focused on foundational skills as
well as doctrinal law. The integrated question sets will make up almost 25% of the exam content.
The balance of the NextGen Bar Exam will be devoted to performance tasks similar to the 90minute MPT items used with the current examination. Sample questions can be found at
https://nextgenbarexam.ncbex.org/nextgen-sample-questions/.
In late October 2024, in collaboration with jurisdictions across the country, the NCBE will
conduct prototype testing, a large-scale administration of the full length, 9-hour NextGen Bar
Exam to examinees who recently completed the July 2024 examination. 12 The prototype
examinees are first time or re-examination applicants, and may or may not have passed the July
2024 exam. 13 Testing will be conducted under actual bar exam testing conditions. The data
collected from the prototype test will continue to be used to generate overall performance data, as
well as other measures. The performance data will be used by jurisdictions to support standard
setting i.e., establishing the score an examinee must attain to be successful on the NextGen Bar
Exam in the jurisdiction.
The first administration of the NextGen Bar Exam will be in July 2026. The NCBE, in
partnership with AccessLex, will produce study aids for the NextGen Bar Exam prior to the first
administration. Tennessee’s first administration of the NextGen Bar Exam will be in July 2027.
The current bar exam consisting of the MBE, MPT, and MEE will be discontinued for all
Some jurisdictions have been designated to provide extended time testing for examinees who were given extra
time to take the test due to a disability in compliance with the ADA.
13
Tennessee Bar Examination results will be released on October 11, 2024. The prototype volunteers have already
been selected.
12

5

jurisdictions after the February 2028 examination.
Since 1972, the NCBE has provided Tennessee with statistically reliable exam materials
that are valid in the context of testing entry-level lawyers. Every ten years since the first
administration of the MBE the NCBE has conducted content validity studies, a hallmark of
professional licensing examinations. Additionally, the NCBE continues to pre-test every item on
the examination to validate that performance on the item is of the appropriate rigor to measure
competency of entry-level lawyers. By adopting the NextGen Bar Exam, Tennessee will continue
to offer a reliable licensing exam that consistently and validly measures competence of entry-level
lawyers, that protects the public and the system of justice, and that allows examinees to earn a
portable examination score to be used for admission in multiple jurisdictions.
For

more

information

on

the

https://nextgenbarexam.ncbex.org/.

6

NextGen

Bar

Exam,

please

visit,

The Danger of Generative Artificial Intelligence Hallucinations in Legal
Practice
Steven J. Christopher 1

The integration of artificial intelligence tools into law practice is resulting in significant changes
in the provision of legal services. While all new technologies can alter the nature of legal services,
legal commentators have noted that artificial intelligence is in the process of creating changes in the
legal industry that are revolutionary. 2
On July 29, 2024, the American Bar Association’s Standing Committee on Ethics and
Professional Responsibility (hereinafter, the “Committee”) published Formal Ethics Opinion 512 to
provide guidance about the ethical issues that may arise in the use of Generative Artificial Intelligence
(hereinafter, “GAI”). 3 The ethical implications of GAI technology in law practice has also been
recently addressed by a number of state bar authorities and other legal commentators. 4
GAI is a subset of artificial intelligence that creates new content based upon patterns from
existing data sets using generative models. GAI applications used in legal practice principally involve
use of a Large Language Model (hereinafter, “LLM”). 5 An LLM provides a basis for natural language
processing tasks through employment of a deep learning algorithm using a public or proprietary
dataset. 6

Deputy Chief Disciplinary Counsel of Investigations at the Tennessee Board of Professional Responsibility of the Supreme
Court of Tennessee.
2
Julie Sobowale, How Artificial Intelligence Is Transforming the Legal Profession, ABA JOURNAL (April 1, 2016).
3
ABA Formal Op. 512 (July 29, 2024). Some of the principal ethical issues identified by the Committee in the context of
GAI tools include competence, communication, confidentiality, managerial obligations, and candor to the tribunal.
4
See, e.g., Florida Bar Ethics Op. 24-1, January 19, 2024; D.C. BAR ETHICS OP. 388; Cheryl Miller; California Bar Adopts
First-of-Its-Kind
Guidance
on
AI
for
Attorneys,
Law.Com
(Nov.
16,
2023),
available
at
https://www.law.com/therecorder/2023/11/16/california-bar-adopts-first-of-its-kind-guidance-on-ai-for-attorneys/.
5
Maura R. Grossman, et al., The GPT Judge: Justice in a Generative AI World, 23 DUKE L.& TECH. REV. 1, at 7,11
(December 1, 2023).
1

6

Id.

7

The overriding conclusion reached by the Committee and other legal commentators is that GAI
technology can be a significant asset to law practice when used correctly, while acknowledging that
application of GAI tools raises potential ethical concerns. 7 Like most emerging technologies, GAI can
potentially improve the provision of legal services but must be evaluated in light of the lawyers’ ethical
obligations.
This article will focus upon one of the problems identified by the Committee and other legal
authorities in the use of GAI technology in the legal field: the danger of an attorney’s reliance on case
citations and other legal authorities generated through a GAI LLM based tool that appear authentic but
are fictitious. This phenomenon is referred to as a “GAI hallucination.” As the purpose of this article
is to identify one of the potential problems involved in the application of GAI technology, the potential
functional uses of GAI technology in law practice will not be discussed herein. The limited scope of
the article should not be construed to imply a conclusion contrary to the Committee or other legal
commentators that GAI technology has the propensity to improve the provision of legal services if used
in a manner consistent with an attorney’s ethical obligations.
GAI hallucinations arise out of the inherent central purpose of LLM based GAI tools to draw
upon an existing dataset to produce new content. 8 GAI products are not intended to accurately evaluate
the veracity or accuracy of content of the information in the dataset, but instead to generate new data
through interface with the existing dataset. Due to this proclivity of LLM based GAI data generation,
results may arise that appear to be accurate but are entirely fictitious.

7
8

Id.
Id. at 10.

8

Lawyers Sanctioned for GAI Hallucinations
Lawyers have recently been sanctioned for reliance upon fictitious legal authorities cited in
court pleadings that were revealed to be GAI hallucinations. This conduct has been the subject of
significant media exposure. 9 This article will address two representative cases, Roberto Mata v.
Avianca, Inc., and Minhe Park v. David Dennis Kim. 10 While these two cases involved courts’ analysis
pursuant to Rule 11 of the Federal Rules of Civil Procedure (hereinafter, Rule 11”) 11 rather than a
jurisdiction’s ethical rules, conduct involving the use of GAI hallucinations will be considered within
the context of Tennessee’s ethical rules. 12
In Mata, the plaintiff originally filed suit in New York state court on February 2, 2022, asserting
personal injury claims. 13 Defense counsel removed the action to the United States District Court for
the Southern District of New York (hereinafter, the “Southern District”). 14 Following removal, defense
counsel moved for dismissal on January 13, 2023, alleging that the plaintiff’s claims were time barred.

See, e.g., Benjamin, Weiser Here’s What Happens When Your Lawyer Uses ChatGPT, NEW YORK TIMES, May 27, 2023;
Matt Novak, Lawyer Uses ChatGPT in Federal Court and it Goes Horribly Wrong, FORBES, May 27, 2023; Sara Merken,
Lawyer who cited cases concocted by AI asks Judge to Spare Sanctions, REUTERS, June 8, 2023.
10
For additional cases relating to findings that non existent cases have been used using a GAI tool, see Isatou Dukuray v.
Experian Information Solutions, 23 Civ. 9043 (AT)(GS), 2024 WL 3812259 (S.D.N.Y. July 26, 2024)(pro se litigant
cautioned but not sanctioned for use of fictitious cases obtained through GAI tool); Karen Iovino v. Michael Stapleton
Associates, LTD., Civil Action No. 5:21-cv-00064, 2024 WL 352170 (W.D. Va. July 24, 2024)(show cause order issued
against attorneys for consideration of sanctions due to use of fictitious cases obtained through GAI tool); Molly Kruse v.
Jonathan R. Karlen, 692 S.W.3d 43 (Mo. Ct. App. 2024)(pro se litigant’s appeal dismissed and sanctions imposed for
frivolous appeal due, in part, to citation of fictitious cases obtained through GAI tool).
11
Rule 11 provides, in pertinent part relevant to the GAI hallucinations, that by inclusion of a legal authority in a pleading
or other paper filed with the court, an attorney certifies that to the best of the person’s knowledge, information and belief,
formed after an inquiry reasonable under the circumstances, the legal contention is warranted by existing law or by a
nonfrivolous argument for extending, modifying, or reversing existing law. FED. R. CIV. P. 11(b)(2). Rule 11 permits the
imposition of sanctions for noncompliance. FED. R. CIV. P. 11(c)-(d).
12
While a number of ethical rules are applicable to the conduct described in these two opinions, research did not reveal any
public disciplinary action yet taken against an attorney in Tennessee or any other jurisdiction for use of GAI hallucinations.
13
678 F. Supp. 3d 443 (S.D.N.Y 2023).
14
Id.
9

9

Plaintiff’s counsel filed a response to the motion to dismiss on March 1, 2023. 15 The response
included citation to a number of appellate court decisions. 16 Defense counsel filed a reply on March
15, 2023, which noted that defense counsel was unable to locate eight of the cases cited by plaintiff’s
counsel. 17 Presiding Judge Peter Kevin Castel was likewise unable to locate the cases through
independent search. 18
After being notified that the cases could not be located, plaintiff’s counsel failed to take proper
action to withdraw or amend the pleading. 19 Judge Castel entered an order on April 11, 2023 requiring
plaintiff’s counsel to file an annexation with affixed copies of the cases. 20 Plaintiff’s counsel delayed
in responding to this directive and subsequently made misrepresentations to the Court when requesting
additional time to do so. 21
On May 25, 2023, Judge Castel issued a show cause order to consider Rule 11 sanctions.
Through the show cause proceeding, it was revealed that Plaintiff’s counsel had relied upon a GAI
chatbot to locate the eight cases at issue. 22 Judge Castel made factual findings that the cases were
entirely fictitious. 23 Judge Castel imposed $5,000 in monetary sanctions against counsel and additional
nonpecuniary sanctions pursuant to Rule 11, due to the failure of counsel to confirm the validity of the
fictitious cases, as well as the delay in responding to the Court’s directive to file the annexation and
counsel’s misrepresentations to the Court. 24

Id. at 450.
Id.
17
Id.
18
Id. at 678 F. Supp. 3d at 451.
19
Id. at 450
20
Id. at 450.
21
Id. at 452.
22
See id. at 460-461.
23
Id.
24
Id. at 466.
15
16

10

Minhe Park v. David Dennis Kim was a medical malpractice action originally filed in the United
States District Court for the Eastern District of New York. 25 On appeal, the Second Circuit upheld the
dismissal of the suit due to plaintiff’s failure to comply with the Trial Court’s discovery orders. 26
In review of a brief filed by plaintiff’s counsel during the pendency of the appeal, the Second
Circuit was unable to locate one of the cases cited therein. 27 Following inquiry with plaintiff’s counsel,
the Second Circuit discovered that the case was nonexistent and had been obtained through utilization
of a GAI tool. 28
In its subsequent opinion upholding the dismissal, the Second Circuit concluded that plaintiff’s
counsel’s conduct fell within the scope of Rule 11. 29 The opinion particularly noted that “the duties
imposed by Rule 11 require that attorneys read and thereby confirm the existence and validity of the
legal authorities upon which they rely,” and that there was “no other way to ensure that the arguments
made based upon those authorities are warranted by existing law or otherwise legally tenable.” 30 The
Second Circuit declined to impose monetary sanctions, but in accordance with its local rules, referred
plaintiff’s counsel to the Second Circuit’s Grievance Panel for further investigation, and for
consideration of subsequent review by its Committee on Admissions and Grievances. 31
Ethical Rules Implicated by the Use of GAI Hallucinations
A number of ethical rules are potentially implicated through the citation of fictitious cases
obtained through GAI hallucinations. The rules discussed below are not intended to be exhaustive.
The use of GAI hallucinations has been analyzed by legal commentators principally in the connection

91 F.4th 610 (2nd Cir. 2024).
Id. at 91 F.4th 610.
27
Id. at 614
28
Id.
29
Id. at 614-615
30
Id at 615.
31
Id. at 616.
25
26

11

of conduct before a tribunal, 32 and some of the rules discussed herein are only applicable in this context
(e.g. candor before the tribunal).

However, the use of fictitious cases obtained through GAI

hallucinations has broader ethical application. Consider the circumstance of an attorney who provides
legal advice to a client using a GAI hallucination, or an attorney who asserts a legal position based
upon a GAI hallucination in discussion with opposing counsel in a contract negotiation.
1. Competent Representation
A foundational error that can result in the citation of GAI hallucinations in a legal proceeding
involves an attorney’s obligation to provide competent representation pursuant to RPC 1.1. For any
technology tools that are used in connection with an attorney’s practice, the attorney must develop
sufficient requisite knowledge of the technology to confirm that they will be able to use the tool in a
manner consistent with their ethical responsibilities. 33
As recognized by the Committee in its formal ethics opinion, Comment [8] of Rule 1.1 of the
American Bar Association Model Rules of Professional Conduct (hereinafter the “Model Rules”),
adopted in 2012, confirms that an attorney’s cognizance of the “benefits and risks associated” with any
technologies used in their practice falls within the scope of their obligation to provide competent
representation. 34 As artificial intelligence technology is rapidly evolving and attorneys may not be
aware of the nature of artificial intelligence technology relative to older technologies, there may be a

A “tribunal” is defined as a court (including a special master, referee, judicial commissioner, or other similar judicial
officer presiding over a court proceeding), an arbitrator in a binding arbitration proceeding, or a legislative body,
administrative agency, or other body acting in an adjudicative capacity. TENN. SUP. CT. R. 8, 1.0(m). The Tennessee Rules
of Professional Conduct, codified at Rule 8 of the Tennessee Supreme Court Rules, will be cited as RPC _._.
33
ABA FORMAL OP. 512.
34
Tennessee has adopted Model Rule 1.1, Comment [8], codified at RPC 1.1, Comment [8]. The comment is also found in
New York’s ethical rules and is thereby applicable to the conduct of counsel in both Mata and Kim.
32

12

heightened need for attorneys to invest time in complying with their obligations defined at Comment
[8]. 35
The Board of Professional Responsibility of the Supreme Court of Tennessee (hereinafter, the
“Board’s”) Formal Ethics Opinion 2015-F-159 is instructive in the proper methodology for interface
with new technologies generally. This opinion was published in response to the rise of “cloud
computing” (i.e. technology allowing a lawyer to store date using a remote server in the custody of a
third-party). 36 Citing RPC 1.1 as well as other ethical rules, the opinion favorably cited recently
promulgated formal ethics opinions in other state jurisdictions generally permitting cloud computing,
while cautioning attorneys of the potential ethics risks.
Consistent with the overriding premise of Tennessee’s Formal Ethics Opinion 2015-F-159,
attorneys should be potentially receptive to GAI technology, particularly as its tools become more
prevelant in law practice. This receptivity should be balanced by a reasonable concern and analysis of
any potential ethical problems that could arise. 37 Engagement of this task may require consultation with
in-house or outside IT specialists where an attorney lacks requisite technological understanding.
The opinions in Mata and Kim appear to possibly reflect a misunderstanding of GAI LLM based
technology, and thereby implicate the obligations defined at Comment [8] of RPC 1.1. Consider the
following statements of counsel regarding the GAI tool at issue:
He was “operating under the false perception that this website [i.e., ChatGPT] could not
possibly be fabricating cases on its own.” (Tr. at 31.) He stated, “I just was not thinking
that the case could be fabricated, so I was not looking at it from that point of view.” (Tr. at
35.) “My reaction was, ChatGPT is finding that case somewhere. Maybe it's unpublished.
Maybe it was appealed. Maybe access is difficult to get. I just never thought it could be
made up.” 38
ABA FORMAL OP. 512. For state bar authorities addressing this issue, see, e.g. STATE BAR OF MICHIGAN FORMAL OP. JI155 (October 27, 2023); D.C. BAR ETHICS OP. 388 (April 2024).
36
TENN. FORMAL ETHICS OP. 2015-F-159.
37
Cassandra R. Hewlings, Future of Louisiana’s Ethics and Professionalism Rules: As Technology Changes, Will Ethics
Stay the Same, LA. BAR JOURNAL (June/July 2016).
38
678 F. Supp at 451.
35

13

Counsel in Mata further referred to the GAI chatbot tool as a “website,” further suggesting a
lack of understanding of the very nature of the technology being employed. 39 Counsel similarly stated
that they considered the GAI tool to be a “super search engine” that could locate and identify on point
legal authorities.” 40 A basic understanding of the nature of GAI technology would have resulted in
counsel understanding the distinction between an online reporting service such as WESTLAW or
LEXIS, and a GAI chatbot tool, and would have resulted in the cite checking of the cases obtained
through GAI application prior to inclusion in the court record.
The need for understanding the nature of GAI tools is apparent from review of the text of one
of the fictitious cases cited by counsel in Mata, which was affixed as an attachment to the opinion.41
Upon casual inspection, the case appears to be a genuine federal appellate court decision. It contains a
case caption. It’s pagination and overall form reflects what attorneys are accustomed to when
reviewing court decisions on WESTLAW, LEXIS, and similar online legal research services. The case
purports to have been adjudicated in the United States Court of Appeals for the Eleventh Circuit and
includes a docket number from the purported trial court. Not surprisingly, given the nature of the GAI
tool employed, the case was directly on point for the holding that counsel was seeking. If the GAI tool
was assumed to be an online reporter akin to WESTLAW or LEXIS, it is understandable why the case
would be presumed to be authentic.
2. Managerial Obligations
Attorneys with managerial and supervisory obligations are required to create and maintain
protocols ensuring compliance with RPC 1.1, Comment [8]. RPC 5.1 imposes a duty on attorneys with
managerial authority over a firm to create and maintain protocols ensuring compliance with the firm’s

Id.
678 F. Supp. at 456.
41
678 F. Supp.3d at 467.
39
40

14

ethical responsibilities. 42 Likewise, RPC 5.1 requires partners in a law firm, and a lawyer who
individually or together with other lawyers possesses comparable managerial authority in a law firm,
to make reasonable efforts to ensure that the firm has in effect measures giving reasonable assurance
that all lawyers in the firm conform to the Rules of Professional Conduct. 43 These obligations require
lawyers with supervisory authority over other lawyers to make reasonable efforts to ensure that the
other lawyers comply with their ethical obligations. 44 Lawyers with managerial or supervisory
authority in a firm are vicariously subject to disciplinary action if they order specified conduct, ratify
it, or fail to take reasonable remedial action. 45 Such vicarious disciplinary action may also arise out of
analogous conduct by non-lawyers acting under the lawyers’ supervisory authority. 46
These managerial obligations are inclusive of any technologies employed by the firm to carry
out legal services. Attorneys with managerial and supervisory authority are required by RPC 5.1 to
create and implement protocols regarding firm technology and place restrictions on unapproved
technology, including the use of GAI tools.
The creation and execution of such protocols is particularly crucial in the context of firm
research technology, given the propensity of firms to grant relative autonomy to attorneys in their

The applicability of Model Rule 5.1, adopted in Tennessee at RPC 5.1, in the context of the use of GAI tools, was
recognized by the Committee in it formal ethics opinion as well as by other legal authorities. See also D.C. FORMAL OP.
388.
43
RPC 5.1(a). A “firm” is very broadly defined to include any lawyers in a “law partnership, professional corporation, sole
proprietorship or other association authorized to practice law; or lawyers employed in a legal services organization or the
legal department of a corporation, government agency, or other organization.” RPC 1.0(c); RPC 1.0, Comments [2]-[4].
Comment [2] to RPC 1.0 confirms that regardless of how attorneys define themselves in an association, if they “present
themselves to the public in a way that suggests that they are a firm or conduct themselves as a firm, they will be regarded
as a firm for purposes of the Rules of Professional Conduct.” Consequently, if an attorney with managerial authority has
any doubt about whether their legal association is a firm, they should make analysis pursuant to RPC 1.0(e) and its comments
and then proceed with application of RPC 1.1, Comment [8].
44
RPC 5.1(b).
45
RPC 5.1(c).
46
RPC 5.3(c).
42

15

research practices. Attorneys are typically provided with online research tools, such as access to a
WESTLAW or LEXIS plan subscription, and conventional reporting services. However, attorneys
impliedly or expressly are also granted autonomy to use any publicly available search engines and other
available online tools whether free or through subscription to conduct research and may even be
encouraged to use such tools to prevent accrual of unnecessary charges through a subscription service.
Particularly given this logistic, an attorney’s managerial authority requires the provision of guidance
and instruction in circumscribing the parameters of appropriate legal research.
3. Meritorious Claims and Contentions
Attorneys who breach their obligations defined at RPC 1.1, Comment [8] and proceed to cite
fictitious legal authorities in a proceeding before a tribunal may be found to have violated additional
ethical rules. RPC 3.1 prohibits an attorney from making a factual or legal assertion unless, following
reasonable inquiry, the lawyer has a basis in law and fact for doing so that is not frivolous. In Mata,
the Court concluded that counsel’s failure to cite check or otherwise make further inquiry of the
fictitious legal authorities breached the analogous due diligence obligation defined at Rule 11. 47
Within the context of the due diligence required for compliance with RPC 3.1, attorneys using
GAI based technology should take particular care to make further inquiry when a legal authority is
located that is directly on point, where no other legal authority is located with the same holding. The
absence of any other authority, standing alone, should raise concerns about the validity of the case at
issue.
Attorneys have particularly broad potential exposure for disciplinary action for violation of RPC
3.1 relative to the two additional rules discussed below (RPC 3.3(a)(1)(knowing misrepresentation to

47

678 F. Supp. 3d. at 450.

16

a tribunal) and RPC 3.4(c)(knowing violation of an obligation of the rules of a tribunal)). Violation of
RPC 3.3(a)(1) and RPC 3.4(c) requires knowing conduct by the attorney. 48 In contrast, a violation of
RPC 3.1 may arise where the attorney is not aware of the fictitious nature of the cited legal authority,
but where a disciplinary authority concludes that the attorney was negligent in their failure to engage
in their RPC 3.1 required due diligence. 49
4. Candor Before a Tribunal
The use of fictitious cases in a written pleading filed with a tribunal, or recitation of such case
in open court, may constitute a violation of RPC 3.3(a)(1), which prohibits a lawyer from
knowingly making a false statement of fact or law to a tribunal. 50 The rule encompasses both verbal
and written misrepresentations. The rule likewise includes not only inclusion of fictitious legal
authorities in a written paper filed with the Court, but also assertion of these legal authorities when
appearing before the court at a hearing or trial. The rule additionally encompasses any activity
conducted in connection with the tribunal’s authority. 51 On this basis, the rule would be inclusive of
statements made asserting the validity of a fictitious case in communication with opposing counsel
during discovery.

The limited applicability of RPC 3.3(a)(1) and RPC 3.4(c) to knowing, as opposed to negligent conduct, is confirmed in
the language of each respective rule. However, it should be noted that “knowing” conduct may be inferred from the
surrounding circumstances. RPC1.0(f)(“knowingly” denotes actual awareness of the fact in question. A person’s
knowledge may be inferred from circumstances).
49
The Board uses the ABA Standards for Imposing Lawyer Sanctions to determine what level of sanction is applicable to
an attorney’s conduct. TENN. SUP. CT. R. 9, §§ 15.1(c)(d); 15.4(a). The ABA Standards require that, at a minimum, an
attorney’s conduct must be negligent for disciplinary action to be imposed. ABA Standards 3.0 (“The least culpable mental
state is negligence. Negligence occurs when a lawyer lacks awareness of a substantial risk that circumstances exist or that
a result will follow which failure is a deviation from the standard of care that a reasonable lawyer would exercise in the
situation”). STANDARDS FOR IMPOSING LAWYER SANCTIONS PT. II THEORETICAL FRAMEWORK (1992).
50
See also RPC 3.3, Comment [4]: “Legal argument based on a knowingly false representation of law constitutes dishonesty
toward the tribunal.”
51
RPC 3.3, Comment [1].
48

17

5. Knowing Violation of an Obligation Under the Rules of a Tribunal
A number of courts have entered standing orders in response to the growing phenomenon of
attorneys citing fictitious cases obtained through GAI hallucinations in court proceedings. 52
While the substance of these orders varies, they generally require disclosure of the use of any
GAI tool in connection with a court filing, as well as certification of the validity of any legal authority
obtained through the GAI tool. 53 For example, Judge Brantley Starr of the United States District Court
for the Northern District of Texas imposed a standing order on May 30, 2023 in light of the Mata case
requiring attorneys and pro se litigants to file a certificate indicating whether GAI tools were used to
prepare court filings. 54 A similar order was entered on June 6, 2023 by Judge Micahel M. Baylson in
the United States District Court for the Eastern District of Pennsylvania. 55 Judge Baylson’s order
encompasses any AI tool inclusive of both GAI and general AI. 56
Any citation to a case obtained through GAI technology, or other use of a GAI tool in
contravention of these standing orders would potentially evidence a violation of RPC 3.4(c), which
prohibits an attorney from knowingly disobeying an obligation under the rules of a tribunal. Attorneys
should take particular care to review any standing orders entered in courts where they are counsel of
record. Additionally, legal commentators have noted that the scope and application of some of the
standing orders is not self-evident. 57 For example, legal commentators have argued that it may be

Maura R. Grossman, et al., Is Disclosure and Certification of the Use of Generative AI Really Necessary? WESTLAW
LAWPRACTICE INDEX, 107 JUDICATURE 68 (2023).
53
David Horrigan, Generative AI: A Legal Ethics Roadway and Reference Guide, LEGAL TECH NEWS, August 1, 2024,
available at https://www.law.com/author/profile/david-horrigan/;
52

Id. The order may be accessed at https://www.txnd.uscourts.gov/judge/judge-brantley-starr.
Standing Order Re: Artificial Intelligence (“AI”) Cases Assigned to Judge Baylson (E.D. Pa. 2023). The order may be
accessed
at
https://www.paed.uscourts.gov/documents/standord/Standing%20Order%CC20Re%CC20Artificial
%CC20Intelligence%206.6.pdf.
56
Id.
54
55

57

Supra note 52.
18

unclear which specific GAI tools fall within the scope of particular standing orders. Consequently,
attorneys should err on the side of caution in disclosure of any AI tools to avoid potential
noncompliance.
Further Inquiry
If you have questions about the content of this article, you may contact the author at
schristopher@tbpr.org or (615) 361-7500, extension 203. Questions about the article may also be
directed to the Board’s Ethics Counsel, Laura Chastain, at lchastain@tbpr.org, or (615) 361-7500,
extension 212.

19

Board of Professional Responsibility
2024 Ethics Workshop
The Board of Professional Responsibility is excited to present our 2024 Ethics
Workshop as a hybrid event, offering both in person and virtual attendance options.
In person attendance will be at Belmont University Law School’s Randall and
Sadie Baskins Center in the Anne Lowry Russell Appellate Courtroom. All others will
attend via livestream. Each attendee has the opportunity to earn 6.5 hours of dual CLE
credit.
The workshop will be held on Friday, November 1 and tickets are $100.
Registration for remote attendance ends Wednesday, October 30. In person attendance is
limited due to space and currently there is a waitlist.
For more information and to register, please visit the ethics workshop webpage or
contact Melissa Boyd at the Tennessee Board of Professional Responsibility, at
mboyd@tbpr.org or (615) 915-5124.
8:00 – 8:15

8:15 – 9:15
1.0 (dual)

9:15 – 9:20
9:20 – 10:20
1.0 (dual)

Registration
Presentation
Regulating Trust Funds: Can We Do a Better Job of
Preventing Theft?
Very few lawyers steal, but when they do, they steal big, and
they make headlines that can cast a shadow on the entire
profession. This session will begin by exploring the
mechanics of stealing client funds, including how some
noteworthy lawyers (Alex Murdaugh, Tom Girardi, etc.) have
not only taken millions from their clients but also evaded
notice by those clients, their law partners, the courts, and
professional regulators. We will then discuss ways the
profession may be able to “plug the leaks,” examining
individual efforts from various jurisdictions that are
experimenting with tightened ethics rules, state bar
administrative efforts, and statutory schemes that reach
beyond lawyer regulation.
5 Minute Break
Threats, Safeguarding the Justice System, and Lawyers as
Instruments of Justice
Chief Justice Kirby will explore lawyers’ ethical obligations
as to threats from inside and outside the justice system.
20

Speaker

Michael Virzi

Chief Justice
Holly Kirby

10:20 – 10:25

10:25 – 11:55
1.5 (dual)

11:55 – 1:00

1:00 – 2:00
1.0 (dual)

2:00 – 2:05
2:05 – 2:20
.15 (dual)

2:20 – 3:05
.45 (dual)
3:05 – 3:10

5 Minute Break
The New Frontier: Navigating AI and Deep Fakes in the
Legal Landscape
In an era where artificial intelligence and deep fakes are
increasingly sophisticated, the legal community faces new
challenges and opportunities. This session will equip judges
and attorneys with the knowledge to understand and identify
AI-generated content and deep fakes, exploring their
implications in legal contexts. We will cover the latest
advancements in AI technology, methods for detecting
fabricated evidence, and the ethical considerations
surrounding the use of AI in the courtroom. Attendees will
leave with practical strategies to confidently address these
emerging issues, ensuring justice is upheld in an age of digital
deception.
Lunch (on your own)
Murder Most Foul!
th
2024 marks the 100 anniversary of a brutal thrill-killing of a
boy by Nathan Leopold and Richard Loeb, the first major
‘Crime of the Century’ in America. In this one-hour ethics
presentation learn how their famed attorney was able to
represent the pair notwithstanding a disqualifying conflict of
interest. This session focuses on both the ethical and
constitutional guidelines governing lawyers who represent
those charged with murder, mayhem, and other assorted
offenses and provides guidance to those who have a client who
wants to harm others or themselves. A refresher on the
attorney-client privilege is included, as well as a summary of
recent national ethics issues.
5 Minute Break
Tennessee Lawyers’ Fund of Client Protection
A brief overview of the agency that provides reimbursement
to clients for losses caused by dishonest conduct committed
by attorneys practicing law in Tennessee.
Recent Developments in Lawyers’ Assistance Programs
This program will provide updates on mental health
challenges in the legal profession, TLAP’s confidential
assistance behind the scenes, and best practices in generating
and monitoring fitness to support practicing lawyers referred
to TLAP in the disciplinary system.
5 Minute Break

21

Mark
Lanterman

Jim Grogan

Sandy Garrett

Buddy
Stockwell

3:10 – 4:10
1.0 (dual)

Lawyers’ Use and Application of Technology: Is AI Really
that Revolutionary?
With the explosion of Artificial Intelligence (AI) integration
in many applications and gadgets that we use every day, it’s
easy to get lost in the sea of lofty promises for AI. This session
will explore practical applications of AI in the real world in
legal-specific technology. For many attorneys, there are more
important practical issues in the use and dangers of technology
in the practice of law. This session will discuss a lawyer’s
everyday use of technology and news gadgets (that may or
may not use AI).

22

Bill Ramsey

Board of Professional Responsibility
Trust Account Workshop
The Tennessee Board of Professional Responsibility will offer a three hour
workshop in trust account management from 9:00 AM to 12:30 PM on Wednesday,
December 4, at the Nashville School of Law located at 4013 Armory Oaks Drive,
Nashville, Tennessee, 37204. Registration for remote attendees ends December 2.
The fee to attend the workshop is $50. The workshop will be led by Steven
Christopher, Deputy Chief Disciplinary Counsel of the Board’s Investigations Section,
and Doug Bergeron, Disciplinary Counsel in Litigation.
The workshop will cover the Rules of Professional Conduct and Tennessee Supreme
Court Rules governing lawyer trust accounts, tips for avoiding overdrafts, best practices
for recordkeeping, and an overview of a lawyer’s ethical obligations regarding client fees.
Suggestions will also be provided for problems commonly encountered by Tennessee
lawyers in connection with trust account management. The workshop is open to both
attorneys and non-attorney staff.
For more information and to enroll, please visit the trust account workshop
webpage or contact Kelly Heflin at the Tennessee Board of Professional Responsibility,
at kheflin@tbpr.org or (615) 695-0940.

23

Board of Professional Responsibility
43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
Board of Professional Responsibility
Organization and Composition
The Tennessee Supreme Court regulates and supervises the practice of law in Tennessee
pursuant to Tennessee Supreme Court Rule 9. The Court appoints twelve members to the Board of
Professional Responsibility (the Board) to effectuate Tenn. Sup. Ct. R. 9 and the Court’s disciplinary
enforcement.
The Board consists of nine (9) attorneys and three (3) public (non-attorney) members who serve
three-year terms and geographically represent the entire state. In 2023-2024, Board members
volunteered 1,081 hours and received no compensation for their service. Members of the Board
include:
Jennifer S. Hagerman (Chair)
R. Culver Schmid (Vice-Chair)
Richard Briggs (Lay Member)
Ginger Wilson Buchanan
Jimmy Dunn
Stacey B. Edmonson
Charles K. Grant
Dr. Carol Johnson-Dean (Lay Member)
Jim Maddux (Lay Member)
Barbara Medley
Kirk Moore
Jonathan Steen
The Court appoints a Chief Disciplinary Counsel who reports to the Board. The Board also
employs attorneys as Disciplinary Counsel and support staff to assist with attorney registration;
consumer assistance; investigation and litigation. A staff directory is attached as Exhibit A.
District Committee Members
The Tennessee Supreme Court appoints attorneys to serve as district committee members from
each disciplinary district in the state. In 2023-2024, 197 attorneys assisted the Court and the Board as
district committee members reviewing Disciplinary Counsel’s recommendations on investigative files
and sitting on hearing panels conducting formal disciplinary charges. Of the 197 members, 140 reported
volunteering 2,259 hours in 2023-2024 for which they received no compensation for their services. A
roster of current district committee members is attached as Exhibit B.

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
Tennessee Attorney Information
The Board of Professional Responsibility provides an easy-to-use online registration system
that allows lawyers to fulfill their annual registration requirements. Public registration information is
displayed on the Board’s website to allow the judiciary, lawyers and the public to access licensing,
registration and contact information about lawyers.

Active Attorneys by Disciplinary District: 24,281*

Disciplinary District 1: 1,044 Active TN attorneys
Disciplinary District 2: 2,644 Active TN attorneys
Disciplinary District 3: 1,615 Active TN attorneys
Disciplinary District 4: 1,426 Active TN attorneys
Disciplinary District 5: 6,192 Active TN attorneys
Disciplinary District 6: 2,623 Active TN attorneys
Disciplinary District 7: 507 Active TN attorneys
Disciplinary District 8: 280 Active TN attorneys
Disciplinary District 9: 3,393 Active TN attorneys
*4,557 Out of State Active TN attorneys

Active Attorney Statistics:


Years Licensed:

<5 yrs:
6-15 yrs:
16-25 yrs:
26-35 yrs:
36-45 yrs:
46+ yrs:

17%
28%
22%
16%
10%
7%

●

Age:

21-29 yrs:
30-39 yrs:
40-49 yrs:
50-59 yrs:
60-69 yrs:
70+ yrs:

5%
20%
25%
22%
16%
12%

---

Gender:

Male:
Female:
Unreported:

61%
38%
1%

●

In-state Attorneys:
Out-of-state Attorneys:

81%
19%

●

25

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
Inactive Attorneys
Pursuant to Tennessee Supreme Court Rule 9, Section 10.3, inactive attorneys include
attorneys serving as justice, judge or magistrate of a court of the United States of America or
who serve in any federal office in which the attorney is prohibited by federal law from engaging
in the practice of law; retired attorneys; attorneys on temporary duty with the armed forces;
faculty members of Tennessee law schools who do not practice law; and attorneys not engaged
in the practice of law in Tennessee. In 2023-2024, 6,188 attorneys on inactive status were
registered with the Board of Professional Responsibility.
 Non-disciplinary/Administrative Suspensions:
Pursuant to Supreme Court Rules, the Supreme Court suspends attorneys who fail to
pay their annual fee (Tenn. Sup. Ct. R. 9 § 10.6); fail to complete annual continuing legal
education requirements (Tenn. Sup. Ct. R. 21 § 7); fail to comply with Interest on Lawyers
Trust Account requirements (Tenn. Sup. Ct. R. 43 § 15); fail to pay the Tennessee professional
privilege tax (Tenn. Sup. Ct. R. 9 § 26); or default on student loans (Tenn. Sup. Ct. R. 9 § 37).
No attorney suspended pursuant to these Rules may resume practice until reinstated by Order
of the Supreme Court. Attorneys were administratively suspended during fiscal year 20232024 as follows:

Non-payment of Annual Fee:
Continuing Legal Education non-compliance:
Interest on Lawyer’s Trust Accounts non-compliance:
Professional Privilege Tax non-compliance:
Default on a Student Loan:
Total:

26

219
145
137
60
0
561

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
Assistance, Investigation and Prosecution
 Trust Account Overdraft Notifications
Pursuant to Tennessee Supreme Court Rule 9, Section 35.1(b), financial institutions report to
the Board whenever any properly payable instrument is presented against an attorney trust account
containing insufficient funds. After receiving notification of an overdraft, Board Staff request financial
information and explanation from the attorney.
Total Notifications

83

Actions Taken
Referred to Investigations
Resolved without Investigation
In Progress

---

14
58
11

Consumer Assistance Program (CAP) and Investigation

Non-frivolous complaints against attorneys submitted by clients, lawyers, judges and the public
are referred to the Board’s Consumer Assistance Program (CAP) for assistance or opened and assigned
to Disciplinary Counsel for investigation. CAP answers questions, provides information, informally
mediates disputes, and refers matters to Disciplinary Counsel for investigation.
Disciplinary Counsel investigate complaints against attorneys alleging unethical conduct. After
investigation, Disciplinary Counsel recommend dismissal of the complaint if there is insufficient proof
of a violation of the Rules of Professional Conduct. If the investigated complaint reflects a violation
of the Rules of Professional Conduct, Disciplinary Counsel recommend diversion, private informal
admonition, private reprimand, public censure, or the filing of formal disciplinary charges. A district
committee member reviews and approves or disapproves Disciplinary Counsel’s recommendation for
dismissal, diversion, and private informal admonition. The Board of Professional Responsibility
reviews and approves or disapproves Disciplinary Counsel’s recommendation for private reprimand,
public censure, and the filing of formal disciplinary charges.

27

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
A. Complaints Received/Previously Active
Requests for Investigations
Requests for Assistance

2,367
1,292

Total:

3,659

B. Complaints Disposition
Administratively Dismissed
Transferred to Investigations
Transferred to CAP
Duplicates/Deceased/Other

1,371
802
1,424
14

Total:

3,611

C. Nature of Complaints

28

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
D. Investigative Caseload:
Investigations Opened
Pending Investigations from previous fiscal year
Total:

819
518
1,337

E. Investigative Disposition:
Investigative Dismissals
Diversion
Private Informal Admonition
Private Reprimand
Informal Public Censure
Transferred to Litigation
Placed on Retired - Disability Status
Other 71:

521
51
36
11
41
100
18
11

Total:

789

• Formal Disciplinary Proceedings:
After the Board of Professional Responsibility authorizes Disciplinary Counsel to file formal
disciplinary charges (i.e., a petition for discipline) against an attorney, the matter is assigned to three
district committee members who constitute a hearing panel. The Hearing Panel sets the disciplinary
proceeding for a hearing which is open to the public unless a protective order has been entered. The
Tennessee Rules of Evidence and Rules of Civil Procedure apply unless Tennessee Supreme Court
Rule 9 provides otherwise.
The Board of Professional Responsibility must prove an attorney’s ethical misconduct by a
preponderance of the evidence. Hearing Panels may recommend dismissal, public censure, suspension
or disbarment.

71

Abated by death; complaint withdrawn; duplicate file.

29

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
A. Formal Disciplinary Caseload
Formal cases filed during Fiscal Year:
Formal cases pending at beginning of Fiscal Year:

62
81

Total formal proceedings:

143

Public hearings conducted in Fiscal Year:

34

B. Formal Disciplinary Proceedings Disposition:

72

Dismissals:
Public Censures:
Suspensions:
Permanent Disbarments:
Transfer to Disability Inactive:
Temporary Suspensions:
Reinstatements:
Other 72:

4
4
15
8
6
11
14
11

Total:

73

Abated by death; voluntary non-suited; denied; withdrawn; nonserious crime.
30

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024

Resolution of Formal Disciplinary Proceedings
15

14
11

11

8
6
4

Dismissals

4

Public Censures Suspensions

Permanent
Disbarments

31

Transfer to
Disability
Inactive

Temporary Reinstatements
Suspensions

Other

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
 Education and Information:
The Board issues Formal Ethics Opinions and staff respond to informal ethics questions by
phone and internet. Disciplinary Counsel present continuing legal education seminars and workshops,
publish Board Notes, a bi-annual newsletter, and update the Board’s website with rule changes,
disciplinary decisions and news for attorneys, judges and the public.
A. Ethics Opinions:
i.

Informal Opinions
Ethics Counsel and Disciplinary Counsel responded to a total of 2,016 phone
and internet inquiries from attorneys seeking ethical guidance. 73

ii.

Formal Opinions
2023-F-169: Departing lawyers and their law firms have an ethical duty to
protect client interests when a lawyer leaves a law firm. The departure of a
lawyer who represents a client or is responsible for the law firm’s delivery of
legal services currently on a matter is information that may affect the status of a
client’s matter and require the client to make a decision regarding the
representation as set forth in RPC 1.4. A departing lawyer and the law firm have
an ethical duty to inform the client of the lawyer’s departure. Because a client
has the right to select counsel of the client’s choice, the fact that the lawyer is
leaving and where the lawyer will ultimately practice is information that will aid
the client in determining whether to stay with the law firm, leave with the lawyer
or seek legal representation elsewhere. Notice should be given to the client by
the departing lawyer, the law firm, or preferably, jointly by the law firm and the
lawyer.
2023-F-170: In light of changes in the Rules, opinions from other jurisdictions,
the Tennessee Supreme Court’s revision of the lawyer advertising rules, and the
evolution in the use of credit cards, the Board of Professional Responsibility
vacates Formal Ethics Opinions 82-F-28 and 82-F-28(a) and updates guidelines
for a lawyer’s acceptance of credit card payments and the use of payment
processing services. A lawyer may accept credit cards or payment processing
services, such as PayPal, Venmo or other like payment processing services, from
a client for payment of fees, including unearned fees (commonly referred to as

73

Tennessee attorneys may submit ethics inquiries to the Board by calling 615-361-7500, ext. 212, or via the Board’s
website at www.tbpr.org.
32

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
retainer fees), so long as the lawyer ensures compliance with the applicable
Tennessee Rules of Professional Conduct regarding client confidentiality, how
credit card transaction fees will be treated, and the security of client trust funds.
B. Continuing Legal Education (CLE) Presentations:
Between July 1, 2023, and June 30, 2024, Disciplinary Counsel presented thirty-two
(32) CLE seminars, attended by approximately 1,841 attorneys.
C. Board Notes:
In 2023-2024, the Board emailed both Fall and Spring issues of Board Notes, the
Board’s semi-annual newsletter to all attorneys and judges and published it on the Board’s
website.
D. Workshops:
a. The Board of Professional Responsibility hosted its annual Ethics Workshop on November
2, 2023, with 803 attorneys attending both virtually and in person. This year’s Ethics
Workshop is scheduled for November 1, 2024.
b. The Board of Professional Responsibility has offered two trust account workshops in
2023/2024, with 354 attorneys attending both virtually and in person. The next trust account
workshop will be held Wednesday, December 4, 2024. Tickets will go on sale at the end of
September.
E. Tennessee’s Proactive Management-Based Regulation (Voluntary Self-Assessment):
Tennessee’s Proactive Management-Based Regulation (PMBR) program is an
interactive law office management self-assessment course. The ten self-assessments are
designed to mitigate risk, elevate competence, and enhance the quality of legal services
delivered to clients. The goal of the program is to prevent problems within a law firm before
they arise, enabling attorneys to spend more time on cases. Attorneys receive 3 Dual CLE
Credits after completion of the course. The ten self-assessments are as follows:
1.
2.
3.
4.

Developing Competent Practices
Communicating in an Effective, Timely, Professional Manner
Ensuring That Confidentiality Requirements Are Met
Avoiding Conflicts of Interest
33

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
5. Retaining and Managing Secure Files
6. Managing the Law Firm/Legal Entity and Staff
7. Charging Appropriate Fees and Making Appropriate Disbursements
8. Ensuring the Use of Reliable Trust Account Practices
9. Access To Justice and Client Development
10. Promoting Wellness
Since the implementation of the course in August 2019, 1,460 Tennessee attorneys have
completed the self-assessment, with 236 completing the course in 2023-2024.
Access the Tennessee PMBR program by following this link: http://tbpr.prolearn.io.

34

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024

Board of Professional Responsibility
Staff Directory
Name
Doug Bergeron
Melissa Boyd
Julie Brown
Laura Chastain
Steve Christopher
Jesús Del Campo
Stephanie Dobis
Dana Dunn
Eric Fuller
Sandy Garrett
Reynold Gaulden, Jr.
Elizabeth Gray
Kelly Heflin
McKenzie Hollars
Maureen Hughes
Katherine Jennings
Molly Liens
Carol Marsh
Jim W. Milam
Heather Piper
Nicholas Price
Tony Pros
Liz Radford
Beverly Rooks
Beverly Sharpe
Pennye Sisk
Eileen Burkhalter Smith
Candis Stigall
Tiffany Tant-Shafer
Logan Thornton
Suzie Thurber
Cheri Weaver
Lani White
Russ Willis

Title
Disciplinary Counsel
Executive Assistant
Administrative Payables Clerk
Ethics Counsel
Deputy Chief Disciplinary Counsel - Investigations
Legal Assistant - Litigation
Lead Legal Assistant
Assistant Director
Disciplinary Counsel
Chief Disciplinary Counsel
Registration Assistant II
Administrative Assistant-Registration/ Scanning
Legal Assistant - Investigations
CAP Legal Assistant
Disciplinary Counsel
Executive Secretary
Registration Manager
Receptionist
Disciplinary Counsel
Disciplinary Counsel
CAP Legal Assistant (Intake)
Network Administrator
Legal Assistant – Investigations and Litigation
Lead Legal Assistant – Investigations
Director of Consumer Assistance Program
Paralegal
Disciplinary Counsel
Case Manager
Disciplinary Counsel
Support Technician
Administrative Receivables Clerk
CAP Paralegal
Registration Assistant II
Deputy Chief Disciplinary Counsel - Litigation

Extension
247
204
215
212
203
249
240
209
243
211
244
202
242
255
234
206
220
200
245
246
257
205
238
233
226
248
210
229
235
207
241
208
227
236
Exhibit A

35

43rd Annual Discipline Report
Fiscal Year July 1, 2023 – June 30, 2024
District Committee Member Roster
District First Name

Last Name

District First Name

Last Name

District First Name

Last Name

1

Dan E.

Armstrong

4

Blake J.

Fitzpatrick

6

David R.

O'Neil

1

Jeremy D.

Ball

4

Michael R.

Giaimo

6

James Y.

Ross, Sr.

1

Melissia

Ball

4

Theodore W.

Goodman

6

Raymond

Runyon

1

Guy W.

Blackwell

4

Mary Beth

Hagan

6

Michael L.

Russell

1

Jeffrey A.

Cobble

4

Moody Wesley

Hall, IV

6

Margaret F.

Sagi

1

McKenna L. (Ms.) Cox

4

Trisha L.

Henegar

6

M. Stuart

Saylor

1

Erwin (Lynn)

Dougherty

4

W. Garrett

Honea

6

Rodger D.

Waynick

1

Andrew E.

Farmer

4

Rachel M.

Moses

6

Beverly

White

1

Jeffery S.

Greene

4

Daniel

Rader, IV

6

Timothy

Wills

1

Scott D.

Hall

4

Thomas S.

Santel

7

Andy

Anderson

1

William B.

Harper

4

Ginger Bobo

Shofner

7

Sara E.

Barnett

1

William B.

Marsh

4

Donna S.

Simpson

7

Shaun

Brown

1

Cecil

Mills

4

Cecilia W.

Spivy

7

Lisa

Houston

1

Nikki C.

Pierce

4

Megan K.

Trott

7

Robert A.

Jowers

1

William O.

Shults

4

Willie F.

Wallace, III

7

Lisa

Miller

1

Barry

Staubus

5

Elaina

Al-Nimri

7

(William) Josh

Morrow

1

Jeffrey L.

Stern

5

Taylor J.

Askew

7

Ryan K.

Porter

1

Denise S.

Terry

5

Kevin E.

Baltz

7

Michelle

Pugh

2

Robyn J.

Askew

5

Adam

Barber

7

Vincent

Seiler

2

Maha (Ms.)

Ayesh

5

Keene W.

Bartley

7

Terica

Smith

2

Edward U.

Babb

5

Robert E.

Boston

7

Neil

Thompson

2

Heidi

Barcus

5

Jad A.

Duncan

7

Joe

VanDyke

2

Amanda M.

Busby

5

Jeff H.

Gibson

8

Dean

Dedmon

2

Loretta G.

Cravens

5

Matthew

Harris

8

Rachele D.

Gibson

2

Nicholas W.

Diegel

5

William J.

Haynes

8

Stephen L.

Hughes

2

Shannon (Ms.)

Egle

5

Candi R.

Henry

8

Will Taylor

Hughes

2

Steve

Erdely

5

Adam

Hill

8

Jeff

Lay

2

Matthew A.

Grossman

5

Lucas

Jerkins

8

Julie W.

Palmer

2

Lisa J.

Hall

5

John D.

Kitch

8

David A.

Stowers

2

Josh

Hedrick

5

Raymond

Leathers

8

Joseph E.

Tubbs

2

Howard B.

Jackson

5

Russell B.

Morgan

8

Allison S.

Whitledge

2

Michael S

Kelley

5

Anthony (Tony)

Orlandi

9

Jeremy G.

Alpert

2

Michael J.

King

5

Julie

Peak

9

Bryce W.

Ashby

2

Gregory C.

Logue

5

Brant

Phillips

9

Taurus M.

Bailey

2

Mary Elizabeth

Maddox

5

Lee (Mr.)

Pope

9

Lucie K.

Brackin

2

Chris

McCarty

5

Daniel H.

Puryear

9

William R.

Bradley, Jr.

2

Carl P.

McDonald

5

Kristina A.

Reliford

9

Christopher S.

Campbell

2

Ben

Mullins

5

Rita

Roberts-Turner

9

S. Keenan

Carter

2

James F.

Parker

5

Peter C.

Robison

9

Kevin E.

Childress

2

P. Edward

Pratt

5

Michael J.

Sandler, Sr.

9

Brian

Coleman

2

Wayne A.

Ritchie, II

5

W. Stuart

Scott

9

David M.

Cook

2

W. Edward

Shipe

5

Siew-Ling (Sue)

Shea

9

Anne B.

Davis

2

Russell E.

Stair

5

Liz

Sitgreaves

9

Amber D.

Floyd

2

Garrett P.

Swartwood

5

Jeffrey

Spark

9

Malcolm B.

Futhey, III

2

Lynn

Tarpy

5

M. Clark

Spoden

9

Nicole

Grida

2

Brian

Wanamaker

5

Taylor C. (Mr.)

Sutherland

9

Greg

Grisham

2

Shelly

Wilson

5

Luther

Wright, Jr.

9

Jonathan C.

Hancock

3

Peter

Alliman

6

Casey

Ashworth

9

Jennifer S.

Harrison

3

Ariel

Anthony

6

Evan P.

Baddour

9

Rebecca

Hinds

3

Larry

Cash

6

Richard

Boehms

9

Lauren

Holloway

3

Sam D.

Elliott

6

Jessica N.

Borne

9

Earl W.

Houston, II

3

Rachel

Fisher-Queen

6

David

Christensen

9

Robbin (Ms.)

Hutton

3

Jeffrey

Maddux

6

C. Diane

Crosier

9

Adam

Johnson

3

Doris

Matthews

6

Marci McClellan

Curry

9

Tressa V.

Johnson

3

Laurie Harrod

McNulty

6

Thomas B.

Dean

9

E. Patrick (Pat)

Lancaster

3

Jennifer A.

Mitchell

6

Hilary

Duke

9

Zachary

Moore

3

Lance W.

Pope

6

James L.

Elkins

9

Will

Perry

3

Leah B.

Sauceman

6

Mary Katharine

Evins

9

Steve

Ragland

3

Carmen (Ms.)

Ware

6

Jennifer F.

Franks

9

Marc

Reisman

3

Ronald D.

Wells

6

David R.

Grimmett

9

Holly J.

Renken

3

Elizabeth L

Williams

6

Cameron R.

Hoffmeyer

9

Zayid

Saleem

4

William "Howie"

Acuff

6

Patricia

Holder

9

Robert L.J.

Spence, Jr.

4

Philip Duane

Burnett

6

Eric

Larsen

9

Emmett L.

Whitwell

36

Exhibit B

Tennessee Lawyers’ Fund for Client Protection
Annual Report
Fiscal Year July 1, 2023 – June 30, 2024
Tennessee Lawyers' Fund for Client Protection
Organization and Composition
The Tennessee Supreme Court has established the Tennessee Lawyers' Fund for Client
Protection to reimburse claimants for losses caused by any dishonest conduct committed by lawyers
practicing in this state. The purpose of the Tennessee Lawyers' Fund for Client Protection, as set forth
in Tennessee Supreme Court Rule 25, is to promote public confidence in the administration of justice
and the integrity of the legal profession as a whole by reimbursing losses caused by the rare instances
of dishonest conduct of lawyers practicing in this state. The Court appoints a nine-member board to
manage Tennessee Lawyers Fund for Client Protection. The Board consists of six lawyers and three
nonlawyers who geographically represent the state. In 2023-2024, Board members volunteered 154
hours and received no compensation for their service. Current members of the Board include:
Stacy E. Roettger – Knoxville (Chair)
Christen Blackburn – Nashville (Vice-Chair)
Pamela Z. Clary – Memphis (Lay Member)
Ellie Kittrell – Knoxville (Lay Member)
Amanda Morse – Knoxville
Junaid Odubeko – Nashville
Michelle Sellers – Jackson, TN (Lay Member)
Telesa Taylor – Memphis, TN
Tennessee Lawyers' Fund for Client Protection is assisted by staff at the Board of Professional
Responsibility.
Fund Resources
The Fund does not receive any government money or tax dollars. The Fund consists of $10
annual payments from attorneys pursuant to Tenn. Sup. Ct. R. 9 § 10.2(c) and Tenn. Sup. Ct. R. 25 §
2. The fund also receives unidentified trust funds from lawyer IOLTA accounts if after 12 months, the
lawyer determines that ascertaining the ownership or securing the return of the funds will not succeed,
pursuant to Tenn. Sup. Ct. R. 8, RPC 1.15(f).

37

Eligible Claims
Pursuant to Tenn. Sup. Ct. R. 25 §§ 1 and 12, claims must be filed within three (3) years of the
date that a loss occurred or reasonably should have been discovered, but in no event later than five (5)
years from the date of the loss. The loss must be caused by dishonest conduct committed by lawyers
practicing in Tennessee. Tenn. Sup. Ct. R. 25 sets out procedures for filing and processing claims. All
claimants must file a complaint with the Board of Professional Responsibility for consideration of their
claim.
Tenn. Sup. Ct. R. 25 § 13 provides:

Claim Limits

No payment shall exceed the sum of $100,000 for loss sustained by any one
claimant nor the aggregate sum of $400,00 with respect to losses caused by any one
lawyer or former lawyer unless otherwise determined by the Board and approved
by the Court. No payment shall exceed $400,000 per transaction regardless of the
number of persons aggrieved or the amount of loss in such transaction, unless
otherwise determined by the Board and approved by the Court. No payment shall
exceed ten percent of the assets of the Fund at the time it is made, unless otherwise
determined by the Board and approved by the Court. Where joint liability of
wrongdoers exists, the Board has discretion to allocate payments as it deems
appropriate within these limits. Payments may be in lump sum or installments as
the Board may determine.
Resolution of Claims Filed
1.
2.
3.
4.

New Claims Filed:
Claims Paid:
Claims Dismissed:
Claims Pending at
beginning of Fiscal Year:

22
99
20

totaling $142,295.37

11

Fiscal Year 2023/2024 Claims Paid by Attorney
Attorney
County/State Awards
Reimbursed
Andy Allman
Sumner
88
$79,494.41
Matthew Dunn
Williamson
1
$4,995.00
A. Sais Finney
Shelby
1
$8,335.00
Robert Golder
Shelby
1
$2,500.00
David Harris
Davidson
1
$1,500.00
James Hickman
Sevier
1
$11,975.00
Jason McLellan
Shelby
2
$9,000.00
Eric Montierth
Roane
1
$3,500.00
Brian Rickman
Shelby
2
$16,495.96
Kevin Teets
Montgomery
1
$4,500.00

38

Disciplinary and Licensure Actions
(April 2024 – September 2024)
PERMANENT DISBARMENTS
ROBERT ALLEN DOLL, III, BPR #022764
DAVIDSON COUNTY
Effective June 20, 2024, the Supreme Court of Tennessee ordered Robert Allen Doll, III, be
permanently disbarred from the practice of law in a unanimous opinion and pay court costs.
On May 31, 2017, the Tennessee Supreme Court suspended Robert Allen Doll, III from the
practice of law pursuant to Tennessee Supreme Court Rule 9, Section 22.3, based upon his conviction
for two (2) counts of subornation of aggravated perjury in violation of T.C.A §39-16-705, and one (1)
count of criminal simulation in violation of T.C.A. §39-14-115(a)(1)(c) in the Circuit Court of
Williamson County, Tennessee, in State of Tennessee v. Robert Allen Doll, III. The disciplinary
conduct was referred to a Hearing Panel for a formal disciplinary hearing at which the sole issue to be
determined was the extent of final discipline. The Panel determined the misconduct by Mr. Doll
warranted disbarment. Mr. Doll appealed the judgment of the Panel to the Circuit Court, which affirmed
the Panel’s judgment. Thereafter, Mr. Doll appealed the judgment of the Trial Court to the Supreme
Court, which affirmed the Trial Court’s decision.
Mr. Doll must comply with the requirements of Tennessee Supreme Court Rule 9, Section 28,
regarding the obligations and responsibilities of disbarred attorneys.
CHRISTOPHER SHAWN ROBERTS, BPR #033510
ROANE COUNTY
Effective June 10, 2024, the Supreme Court of Tennessee permanently disbarred Christopher
Shawn Roberts from the practice of law and ordered him to close his law firm IOLTA account, pay
restitution to his former client, and pay all costs incurred to the Board of Professional Responsibility.
Following a final hearing upon the disciplinary petition, the Hearing Panel found, by a
preponderance of evidence, that Mr. Roberts committed disciplinary misconduct and should be
permanently disbarred. Mr. Roberts, in two matters, charged an unreasonable fee, failed to diligently
represent a client, failed to provide competent representation, failed to turn over client materials upon

39

termination of representation, failed to reasonably communicate with his client, knowingly violated
court orders, concealing documents meant for others, advised his client to lie to a court officer, provided
false information to the court, and engaged in conduct involving dishonesty, deceit, misrepresentations.
The Hearing Panel found Mr. Roberts has knowingly violated Tennessee Rules of Professional
Conduct: 1.1 (competence), 1.2(a) and (d) (scope of representation), 1.3 (diligence), 1.4
(communication), 1.5 (fees), 1.16 (Declining or terminating representation), 3.2 (expediting litigation),
3.3(a) (candor toward the tribunal), 3.4(c) (fairness to opposing party and counsel), 4.1(a) (truthfulness
in statements to others), and 8.4(a)(c)(d) (misconduct).
SUSPENSIONS
GARY LEE ANDERSON, BPR #004515
KNOX COUNTY
Effective July 2, 2024, the Supreme Court of Tennessee suspended Gary Lee Anderson from
the practice of law pursuant to Tenn. Sup. Ct. R. 9, § 12.2, for five (5) years, followed by a period of
indefinite suspension until he has made restitution to former client Charles Nelson in the amount of
$1,370.00.
A Petition for Discipline containing three (3) complaints was filed by the Board alleging Mr.
Anderson failed to reasonably communicate with his clients regarding the status of their cases; failed
to act in a diligent manner and expedite the clients’ litigation; failed to communicate with clients
reasonably; failed to obtain informed consent from actual client following payment from a family
member, failed to respond to requests for information from disciplinary counsel; charged an
unreasonable fee, failed to delineate and/or specify any limitations on the scope of his representation;
non-refundable fee without the client executing a written agreement; accepted client referrals from a
non-registered intermediary organization; and failed to take reasonable steps to protect the clients’
interest after terminating the representation.
The Hearing Panel found that Mr. Anderson knowingly violated Tennessee Rules of
Professional Conduct: 1.1 (competence), 1.2 (scope of representation), 1.3 (diligence), 1.4
(communication), 1.5 (fees), 1.8 (conflict of interest: current clients: specific Rules), 8.1(b) (bar
admission and disciplinary matters), and 8.4 (a), (c), and (d) (misconduct).
40

Mr. Anderson must comply with the requirements of Tennessee Supreme Court Rule 9, §§ 28
and 30.4, regarding the obligations and responsibilities of suspended attorneys and the procedure for
reinstatement.
JASON RUSSELL BUCKLEY, BPR #026795
TENNESSEE LAWYER
By Order of Reciprocal Discipline entered by the Supreme Court of Tennessee on August 8,
2024, Jason Russell Buckley received a one (1) year suspension retroactive to September 7, 2023. Mr.
Buckley was suspended by the Supreme Judicial Court for the State of Maine for one (1) year by Order
on Motions for Sanctions M. Bar R. 21 entered September 7, 2023, for requesting continuing legal
education credit for attending on June 16 and June 17, 2022, live webcast seminars occurring
simultaneously in violation of Maine Rules of Professional Conduct 8.4(c) (Misconduct) and Maine
Bar Rule 5(a), (f)(1).
On April 8, 2024, the Supreme Court entered a Notice of Reciprocal Discipline directing Mr.
Buckley to inform the Court, within thirty (30) days of receipt of the Notice, why the discipline imposed
by the Supreme Judicial Court for the State of Maine should not be imposed in Tennessee. On May 6,
2024, Mr. Buckley filed a timely response with the Court, and the Board filed a reply on June 12, 2024,
as ordered. Upon due consideration of the respective arguments, the Supreme Court entered its Order
of Reciprocal Discipline.
Mr. Buckley 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.
JONATHAN WILLIAM DOOLAN, BPR #024397
KNOX COUNTY
Effective June 28, 2024, the Supreme Court of Tennessee suspended Jonathan William Doolan
from the practice of law for nine (9) months, with one (1) month being as an active suspension pursuant
to Tennessee Supreme Court Rule 9, Section 12.2, and the remainder served on probation with
conditions, including contacting with the Tennessee Lawyers Assistance Program and compliance with
any recommendations.
41

A Petition for Discipline containing two complaints was filed by the Board alleging Mr. Doolan
failed to reasonably communicate with his clients regarding the status of their case, failed to act in a
diligent manner and expedite the clients’ litigation, failed to timely respond to discovery requests, failed
to communicate with clients, failed to properly withdraw from representation, failed to work within the
scope of his representation, failed to take reasonable steps to protect the client’s interest after
terminating the representation, and failed to comply with requests for information from Disciplinary
Counsel.
Mr. Doolan executed a Conditional Guilty Plea acknowledging his conduct violated Tennessee
Rules of Professional Conduct 1.2 (scope of representation); 1.3 (diligence); 1.4 (communication); 1.16
(declining or terminating representation); 3.2 (expediting litigation); 3.4 (fairness to opposing party and
counsel); and 8.1 (bar admission and disciplinary matters).
Mr. Doolan 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.
LARRY E. FITZGERALD, BPR #010953
SHELBY COUNTY
Effective August 14, 2024, the Supreme Court of Tennessee suspended Larry E. Fitzgerald from
the practice of law for four (4) years, with the first two (2) years to be served as an active suspension,
pursuant to Tennessee Supreme Court Rule 9, Section 12.2, and the remainder to be served on
probationary suspension.
In disciplinary matters arising from twelve (12) separate complaints, Mr. Fitzgerald failed to
communicate reasonably with his clients, failed to diligently perform work necessary to the
representation, failed to properly maintain client funds in his IOLTA trust account, failed to keep
accurate accounting of funds kept in trust, failed to return unearned client fees, failed to properly
conclude representation of clients, and failed to respond to requests for information from the Board of
Professional Responsibility.
Mr. Fitzgerald executed a Conditional Guilty Plea acknowledging his conduct violated
Tennessee Rules of Professional Conduct 1.3 (diligence), 1.4 (communications), 1.5 (fees), 1.15
(safekeeping property and funds), 1.16 (terminating representation), and 8.1(b) (disciplinary matters).

42

Mr. Fitzerald 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.
GRACE INGRID GARDINER, BPR #023269
TENNESSEE LAWYER
Effective September 16, 2024, Grace Ingrid Gardiner of Tampa, Florida, was temporarily
suspended by Order of Reciprocal Discipline entered by the Supreme Court of Tennessee on September
16, 2024. Ms. Gardiner was temporarily suspended from the practice of law by Order of the Supreme
Court of Minnesota entered June 20, 2024. On August 15, 2024, the Supreme Court of Tennessee
entered a Notice of Reciprocal Discipline directing Ms. Gardiner to demonstrate to the Court, within
thirty (30) days of receipt of the Notice, why the discipline imposed by the Supreme Court of Minnesota
should not be imposed by the Supreme Court of Tennessee. Ms. Gardiner filed a response on
September 13, 2024, acknowledging no grounds specified in Tenn. Sup. Ct. R. 9, Section 25.4 existed.
Thereafter, the Supreme Court imposed reciprocal discipline consistent with the terms and conditions
imposed by the Supreme Court of Minnesota.
Ms. Gardiner must comply with the requirements of Tennessee Supreme Court Rule 9, Sections
28 and 30.4, regarding the obligations and responsibilities of suspended attorneys. Ms. Gardiner must
pay the Court’s costs and expenses within ninety (90) days of the entry of the order.
LORING EDWIN JUSTICE, BPR #019446
KNOX COUNTY
Effective June 12, 2024, the Supreme Court of Tennessee unanimously held in a majority
opinion, with one Justice writing a concurring opinion, that Loring Edwin Justice committed
professional misconduct for which the sanction is a suspension of his law license for three (3) years
pursuant to Tenn. Sup. Ct. R. 9, § 12.2.
After a hearing upon the disciplinary petition, a Hearing Panel determined by a preponderance
of the evidence that Mr. Justice made statements about a judge in court pleadings that were either false
or that no reasonable attorney would believe were true, that the statements were made to disrupt a
judicial proceeding, that they caused unnecessary delay and needlessly increased litigation costs, and
43

that they undermined public confidence in the administration of justice. The Hearing Panel concluded
the above conduct by Mr. Justice was in violation of RPC 3.5(e) (disrupting a tribunal), RPC 8.2(a)(1)
(judicial and legal officials), and RPC 8.4(a) and 8.4(d) (misconduct). On appeal, the trial court
affirmed the findings of the Hearing Panel as to the ethical violations but reversed the Hearing Panel’s
imposition of a three (3) year suspension and increased the sanction to disbarment.
The trial court’s judgment was affirmed in part and reversed in part by the Supreme Court,
resulting in affirmation of the findings by the Hearing Panel and the trial court regarding each ethical
violation found, and the reversal of the trial court’s order of disbarment and reinstatement of the
Hearing Panel’s three (3) year suspension. The Court ordered Mr. Justice to obtain an additional six
(6) hours of CLE pertaining to ethics instruction and pay the costs of his disciplinary proceeding as
conditions precedent to reinstatement of his license.
TEMPORARY SUSPENSIONS
AMANDA HOWELL CASTILLO, BPR #037519
MAURY COUNTY
On July 26, 2024, the Supreme Court of Tennessee temporarily suspended Amanda Howell
Castillo from the practice of law for failing to respond to the Board of Professional Responsibility
concerning one (1) complaint of misconduct. 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 failure
to respond to a complaint of misconduct.
Ms. Castillo is immediately precluded from accepting any new cases, and she must cease
representing existing clients by August 25, 2024. After August 25, 2024, Ms. Castillo shall not use any
indicia of lawyer, legal assistant, or law clerk nor maintain a presence wherein the practice of law is
conducted. Ms. Castillo must notify all clients being represented in pending matters, as well as cocounsel and opposing counsel, of the Supreme Court’s Order suspending her law license, and she is
required to deliver to all clients any papers or property to which they are entitled.
Ms. Castillo 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.

44

This suspension remains in effect until dissolution or modification by the Supreme Court. Ms.
Castillo may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.
MICKIE SMITH DAUGHERTY, BPR #022746
DAVIDSON COUNTY
On August 20, 2024, the Supreme Court of Tennessee temporarily suspended Mickie Smith
Daugherty from the practice of law upon finding that Ms. Daugherty failed to respond to the Board of
Professional Responsibility concerning one (1) complaint of misconduct, misappropriated funds, 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 failure
to respond to a complaint of misconduct, misappropriation of funds and property, or posing a threat of
substantial harm to the public.
Ms. Daugherty is immediately precluded from accepting any new cases, and she must cease
representing existing clients by September 19, 2024. After September 19, 2024, Ms. Daugherty shall
not use any indicia of lawyer, legal assistant, or law clerk nor maintain a presence wherein the practice
of law is conducted. Ms. Daugherty 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,
and is required to deliver to all clients any papers or property to which they are entitled.
Ms. Daugherty 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.
Daugherty may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.
JONATHAN WILLIAM DOOLAN, BPR #024397
KNOX COUNTY
On September 19, 2024, the Supreme Court of Tennessee temporarily suspended Jonathan
William Doolan from the practice of law upon finding that Mr. Doolan failed to comply with a
45

Tennessee Lawyers Assistance Program monitoring agreement. 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 substantial non-compliance with a Tennessee Lawyers Assistance Program monitoring
agreement and poses a threat of substantial harm to the public.
Mr. Doolan is immediately precluded from accepting any new cases, and he must cease
representing existing clients by October 19, 2024. After October 19, 2024, Mr. Doolan shall not use
any indicia of lawyer, legal assistant, or law clerk nor maintain a presence where the practice of law is
conducted.
Mr. Doolan 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. Mr. Doolan is required
to deliver to all clients any papers or property to which they are entitled.
Mr. Doolan 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. Mr.
Doolan may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.
ARTHUR C. GRISHAM, JR., BPR #001071
HAMILTON COUNTY
On April 29, 2024, the Supreme Court of Tennessee temporarily suspended Arthur C. Grisham,
Jr., from the practice of law upon finding that Mr. Grisham failed to respond to the Board of
Professional Responsibility concerning one (1) complaint of misconduct. 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 failure to respond to a complaint of misconduct.
Mr. Grisham is immediately precluded from accepting any new cases, and he must cease
representing existing clients by May 29, 2024. After May 29, 2024, Mr. Grisham shall not use any
indicia of lawyer, legal assistant, or law clerk nor maintain a presence wherein the practice of law is
conducted. Mr. Grisham must notify all clients being represented in pending matters, as well as co-

46

counsel and opposing counsel, of the Supreme Court’s Order suspending his law license, and he is
required to deliver to all clients any papers or property to which they are entitled.
Mr. Grisham 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. Mr.
Grisham may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.
JAMES PATRICK HENRY, BPR #033761
KNOX COUNTY
On May 6, 2024, the Supreme Court of Tennessee temporarily suspended James Patrick Henry
from the practice of law upon finding that Mr. Henry failed to respond to the Board of Professional
Responsibility concerning six (6) complaints of misconduct. 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 failure to respond.
Mr. Henry is immediately precluded from accepting any new cases, and he must cease
representing existing clients by June 5, 2024. After June 5, 2024, Mr. Henry shall not use any indicia
of lawyer, legal assistant, or law clerk nor maintain a presence where the practice of law is conducted.
Mr. Henry 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. Mr. Henry is required
to deliver to all clients any papers or property to which they are entitled.
Mr. Henry 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. Mr.
Henry may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.

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STEVEN MICHAEL HODGEN, BPR #025456
HAMILTON COUNTY
On May 31, 2024, the Supreme Court of Tennessee temporarily suspended Steven Michael
Hodgen from the practice of law upon finding Mr. Hodgen failed to respond to the Board of
Professional Responsibility concerning one (1) complaint of misconduct. 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 failure to respond to a complaint of misconduct.
Mr. Hodgen is immediately precluded from accepting any new cases, and he must cease
representing existing clients by June 30, 2024. After June 30, 2024, Mr. Hodgen shall not use any
indicia of lawyer, legal assistant, or law clerk nor maintain a presence wherein the practice of law is
conducted. Mr. Hodgen must notify all clients being represented in pending matters, as well as cocounsel and opposing counsel, of the Supreme Court’s Order suspending his law license, and he is
required to deliver to all clients any papers or property to which they are entitled.
Mr. Hodgen 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. Mr.
Hodgen may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.
JOEL DAVID RAGLAND, BPR #012222
MONTGOMERY COUNTY
On April 12, 2024, the Supreme Court of Tennessee temporarily suspended Joel David Ragland
from the practice of law upon finding Mr. Ragland misappropriated funds for his personal use 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 where the attorney
misappropriates funds for his personal use or poses a threat of substantial harm to the public.
Mr. Ragland is immediately precluded from accepting any new cases, and he must cease
representing existing clients by May 12, 2024. After May 12, 2024, Mr. Ragland shall not engage in
the practice of law; use any indicia of lawyer, legal assistant, or law clerk; or maintain a presence
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wherein the practice of law is conducted. Mr. Ragland 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. Ragland 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. Mr.
Ragland may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.
FRANCIS XAVIER SANTORE, JR., BPR # 011315
GREENE COUNTY
On September 26, 2024, the Supreme Court of Tennessee temporarily suspended Francis Xavier
Santore, Jr. from the practice of law upon finding that Mr. Santore poses a threat of substantial harm to
the public. The Supreme Court further ordered Mr. Santore to undergo examination by a qualified
medical or mental health expert to assess his capacity and fitness to 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. Section 27.4 of Supreme Court Rule 9 provides for the evaluation of an attorney by a qualified
medical or mental health expert, to determine the attorney’s capacity to continue to practice law, in
cases where the mental or physical health of an attorney is called into question.
Mr. Santore 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. Mr. Santore 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. Mr. Santore is required to deliver to all clients any papers or property to which they are entitled.
Mr. Santore is suspended from the practice of law effective immediately and must immediately
cease representing clients. Mr. Santore shall not use any indicia of lawyer, legal assistant, or law clerk
nor maintain a presence where the practice of law is conducted.

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This suspension remains in effect until dissolution or modification by the Supreme Court. Mr.
Santore may for good cause request dissolution or modification of the suspension by petition to the
Supreme Court, but no hearing on such a petition may be held until Mr. Santore complies with all
requirements of the Order of Suspension.
MELANIE BETH SHADA, BPR #022279
CUMBERLAND COUNTY
On April 25, 2024, the Supreme Court of Tennessee temporarily suspended Melanie Beth Shada
from the practice of law upon finding that Ms. Shada failed to respond to the Board of Professional
Responsibility concerning a complaint of misconduct. Section 12.3 of Supreme Court Rule 9 provides
for the immediate temporary suspension of an attorney’s license to practice law in cases of an attorney’s
failure to respond to a complaint of misconduct.
Ms. Shada is immediately precluded from accepting any new cases, and she must cease
representing existing clients by May 25, 2024. After May 25, 2024, Ms. Shada shall not use any indicia
of lawyer, legal assistant, or law clerk nor maintain a presence wherein the practice of law is conducted.
Ms. Shada 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, and is required to deliver
to all clients any papers or property to which they are entitled.
Ms. Shada 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.
Shada may, for good cause, request dissolution or modification of the suspension by petition to the
Supreme Court.

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PUBLIC CENSURES
JOHNNIE DANIEL BOND, JR., BPR #022444
WASHINGTON D.C.
On July 1, 2024, Johnnie Daniel Bond, Jr., an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Mr. Bond’s law license was administratively suspended due to his failure to pay his annual fee
and do his IOLTA reporting. Mr. Bond admits he received notice of the suspension from the Board
but states that he did not read the correspondence. Mr. Bond was engaged in the active practice of law
for seven months while his law license was suspended, including filing pleadings, appearing in court,
and entering agreed orders. During the suspension, Mr. Bond’s website advertised that he had law
offices in Memphis and Nashville, Tennessee.
By these acts, Johnnie D. Bond, Jr., is in violation of Rules of Professional Conduct 5.5
(unauthorized practice of law) and 7.1 (communication concerning a lawyer’s services) 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.
JAY NELSON CHAMNESS, BPR #016027
WILLIAMSON COUNTY
On April 17, 2024, Jay Nelson Chamness, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Mr. Chamness represented a plaintiff asserting employment discrimination in a case filed in the
United States District Court for the Middle District of Tennessee. Over the course of 11 months, Mr.
Chamness made at least four false statements to opposing counsel about personal circumstances for
which he needed extensions of time. In the last instance, Mr. Chamness asked to reschedule depositions
because his mother had died, and he prepared a draft “Motion for Extension of Discovery Deadline” in
which he stated he needed the extension because his mother had died. Mr. Chamness sent this motion

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to opposing counsel for approval. Opposing counsel hired a private investigator who discovered that
Mr. Chamness’s mother had not died. Mr. Chamness then admitted his conduct to opposing counsel.
By these acts, Jay Nelson Chamness has violated Rules of Professional Conduct 4.1
(truthfulness in statements to others), 8.4(c) (conduct involving dishonesty) and 8.4(a) (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.
MARK STEVEN GRAHAM, BPR #011505
KNOX COUNTY
On January 30, 2024, Mark Steven Graham, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Mr. Graham’s law license is currently suspended. He filed a pro se lawsuit and identified
himself in the pleading as a “lawyer” and “member of the Bar of the State of Tennessee.” Mr. Graham
also signed the pleading by using his name, “Esq.,” and his Board of Professional Responsibility
licensure number, along with the designation that he was pro se.
By these acts, Mark Steven Graham, has violated Rules of Professional Conduct 7.1
(communications concerning a lawyer’s services), 3.4 (fairness to opposing party), and 8.4(g) (failure
to comply with court order) 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.
SHERYL D. GUINN, BPR #025420
DAVIDSON COUNTY
On July 22, 2024, Sheryl D. Guinn, an attorney licensed to practice law in Tennessee, received
a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme Court.
Ms. Guinn filed a healthcare liability lawsuit against a psychiatrist who treated her client. Ms.
Guinn did not believe there was a good faith basis to file the lawsuit and so informed her client, but the
client insisted that she wanted to file the lawsuit. Ms. Guinn charged the client a $3,000 retainer to file
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the lawsuit. The defendants were successful in moving to dismiss the lawsuit, and sanctions were
awarded against Ms. Guinn.
By these acts, Sheryl D. Guinn has violated Rules of Professional Conduct 1.1 (competence),
1.5 (fees), 3.1 (meritorious claims and contentions), 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.
DAVID LYNN HAMBLEN, BPR #010234
OBION COUNTY
On April 23, 2024, David Lynn Hamblen, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Mr. Hamblen represented the mother of a child in a custody matter in which an order had been
entered granting the mother supervised visitation. The parties and their counsels were discussing
entering an agreed order giving the mother unsupervised visitation, but prior to any agreement on that
issue, Mr. Hamblen’s client called him and said she was having a problem arranging for her visitation
to be supervised on a particular day. Mr. Hamblen then instructed his client to go ahead with
unsupervised visitation. Opposing counsel filed a motion for contempt, and Mr. Hamblen told opposing
counsel that he had instructed his client not to comply with the existing court order, and that he knew
no order had been entered relieving her of the supervised visitation.
By these acts, David Lynn Hamblen has violated Rules of Professional Conduct 3.4 (fairness to
opposing party) and 8.4(d) (prejudice to the administration of justice) 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.

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MARVIN DON HIMMELBERG, #015199
DAVIDSON COUNTY
On July 16, 2024, Marvin Don Himmelberg, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
In defending a juvenile client against criminal charges, Mr. Himmelberg failed to appear for the
client’s arraignment hearing, thereby jeopardizing the client’s plea deal. Mr. Himmelberg also failed to
refund any part of the client’s fee.
By these acts, Mr. Himmelberg has violated Rules of Professional Conduct RPC 1.3 (diligence),
1.4 (communication), and 1.5 (fees) 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.
COLLEEN ANN HYDER, BPR #029571
MONTGOMERY COUNTY
On July 19, 2024, the Supreme Court of Tennessee released an opinion affirming the decision
of the Montgomery County Chancery Court imposing a public censure on Colleen Ann Hyder pursuant
to Tenn. Sup. Ct. R. 9, Section 12.4. The trial court affirmed the findings of the Board of Professional
Responsibility disciplinary Hearing Panel finding Ms. Hyder had committed professional misconduct
by representing clients in court and at a mediation for a week after she knew her license was summarily
suspended under Tenn. Sup. Ct. R. 9, Section 26, for failure to pay the professional privilege tax. The
Supreme Court affirmed the judgment of the Chancery Court that public censure was the appropriate
disciplinary sanction for violating Tennessee Rule of Professional Conduct 5.5(a) (Unauthorized
Practice of Law).
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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SHAHEEN ILTAF IMAMI, BPR #040047
HAMILTON COUNTY
By Order of Reciprocal Discipline entered by the Supreme Court of Tennessee on August 6,
2024, Shaheen Iltaf Imami received a public censure with conditions. On April 10, 2024, the Attorney
Disciplinary Board for the State of Michigan imposed a public reprimand on Shaheen Iltaf Imami
conditioned upon successful completion of the (i) State Bar of Michigan’s (SBM) “Lawyer Trust
Accounts Seminar: Management Principles & Recordkeeping Resources,” and (ii) successful
completion of SBM’s “Tips and Tools for a Successful Practice” seminar, with proof of said completion
being provided to the Grievance Administrator. Mr. Imami failed to preserve complete records of
account funds for a period of five years; failed to promptly deliver funds owed to his client or third
party; failed to promptly render a full accounting; failed to hold property of clients or third parties
separate from his own funds; failed to deposit all client or third party funds in an appropriate IOLTA
or non-IOLTA account, and/or failed to appropriately safeguard other property; engaged in conduct
prejudicial to the administration of justice; and engaged in conduct exposing the legal profession to
obloquy, contempt, censure, or reproach in violation of the Michigan Rules of Professional Conduct
1.15(b)(2) and (3), 1.15 (d) and 8.4(c) (Misconduct) and Michigan Court Rules 9.104(1) and (2).
On May 8, 2024, the Supreme Court of Tennessee entered a Notice of Reciprocal Discipline
directing Mr. Imami to inform the Court, within thirty (30) days of receipt of the Notice, why the
discipline imposed by the Attorney Disciplinary Board for the State of Michigan should not be imposed
by the Court. On June 7, 2024, Mr. Imami filed a timely response with the Court, and the Board filed
a reply on August 1, 2024, as ordered. Upon due consideration of the respective arguments, the
Supreme Court entered its Order of Reciprocal Discipline.
A public censure is a rebuke and warning to the attorney, but it does not affect the attorney’s
present ability to practice law.
*Originally posted August 6, 2024. Revised and posted August 9, 2024.

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LINDSEY LEIGH LAWRENCE, #032697
WILSON COUNTY
On July 22, 2024, Lindsey Leigh Lawrence, 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 clients in a civil proceeding, Ms. Lawrence failed to file a reply to a
counterclaim in compliance with applicable rules of court and failed to respond to written discovery,
resulting in entry of a default judgment and dismissal of her clients’ claims. Ms. Lawrence also failed
to keep her clients advised of the status of their case or respond to requests for information. In a second
matter where Ms. Lawrence was appointed as conservator over the estate of an adult ward, Ms.
Lawrence failed to pay the ward’s ongoing expenses, resulting in her removal as conservator by the
Court.
By these acts, Ms. Lawrence has violated Rule of Professional Conduct 1.3 (diligence), 1.4
(communication), 3.2 (expediting litigation) 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.
MARCUS ALLEN LIPHAM, #036403
MADISON COUNTY
On April 10, 2024, Marcus Allen Lipham, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Mr. Lipham filed a lawsuit on behalf of a client that lacked any meritorious basis in fact or law.
Mr. Lipham subsequently failed to file a response to the defense counsel’s motion to dismiss or seek
leave to amend the original complaint, and then agreed to the dismissal of the lawsuit with prejudice
without his client’s informed consent. Mr. Lipham also failed to respond to a motion for sanctions filed
by defense counsel or notify his client of the motion hearing. An order imposing sanctions against both
Mr. Lipham and his client was entered by the Court.

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By these acts, Mr. Lipham has violated Rules of Professional Conduct 1.1 (competence), 1.2(a)
(scope of representation), 1.3 (diligence), 1.4 (communication), 1.5(c) (fees), and 3.1 (meritorious
claims) 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.
KATHRYN NAN MACERI, BPR #030797
SHELBY COUNTY
On July 15, 2024, Kathryn Nan Maceri, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Ms. Maceri represented a client in seeking the renewal of a work permit for immigration court.
Ms. Maceri failed to provide her client with competent and diligent representation. Additionally, Ms.
Maceri failed to communicate with her client and breached her responsibilities regarding nonlawyer
assistants when her legal assistant provided her client with an altered work permit. As a result, the work
permit was unable to be used and her client had to hire a new attorney to assist him in the renewal of
the work permit.
By these acts, Ms. Maceri has violated Rules of Professional Conduct 1.3 (diligence), 1.4
(communication), and 5.3 (responsibilities regarding nonlawyer assistants) 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.
KELVIN ARTHUR MASSEY, BPR #011059
SHELBY COUNTY
On April 23, 2024, Kelvin Arthur Massey, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Supreme Court of Tennessee and was ordered to pay the costs and
fees of the Board of Professional Responsibility.
While under active suspension from the practice of law, Mr. Massey engaged in unauthorized
practice by providing legal advice, drafting legal documents, providing legal services, and holding out
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to the public that he was an attorney licensed to practice law in Tennessee. By this conduct, Mr. Massey
violated Rules of Professional Conduct 3.4(c) (fairness to opposing party and counsel), 5.5(b)(2)
(unauthorized practice of law), and 8.4(g) (misconduct involving failing to comply with a final court
order).
A Public Censure is a rebuke and warning to the attorney, but it does not affect the attorney’s
ability to practice law.
LYNDA W. PATTERSON, BPR #014424
OVERTON COUNTY
On April 10, 2024, Lynda W. Patterson, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Ms. Patterson was hired to seek damages against former residential tenants of her client. Ms.
Patterson negotiated an agreed judgment with the former residential tenants for which she prepared an
agreed order. Both sets of parties signed the agreed order, and Ms. Patterson mailed it to the judge for
entry. The order, however, was never entered by the court. Ms. Patterson’s client contacted her two
times about the status of the order, and she did not respond. Ms. Patterson then discovered the order
had not been entered, and so, fourteen months after the tenants had entered the proposed agreed order,
Ms. Patterson proceeded with a default judgment against the former tenants.
By these acts, Lynda W. Patterson is in violation of Rules of Professional Conduct 1.3
(diligence), 3.2 (expediting litigation) 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.
JUSTIN GREY WOODWARD, #026709
FAIRFAX COUNTY, VIRGINIA
On July 22, 2024, Justin Grey Woodward, an attorney licensed to practice law in Tennessee and
Virginia, received a Public Censure from the Board of Professional Responsibility of the Tennessee
Supreme Court.
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Mr. Woodward represented a client in pursuing a contract dispute. Mr. Woodward failed to
take prompt action after filing the lawsuit, resulting in a significant delay in the proceedings. Mr.
Woodward also failed to keep his client updated regarding the status of the proceedings or respond to
his client’s requests for information.
By these acts, Justin Grey Woodward has violated Rules of Professional Conduct 1.3
(diligence), 1.4 (communication), 1.16(a) (declining or terminating representation), and 3.2 (expediting
litigation) 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.
JONATHAN LEE YOUNG, BPR #020345
OVERTON COUNTY
On July 3, 2024, Jonathan Lee Young, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Supreme Court of Tennessee.
Mr. Young represented a client in an emergency conservatorship petition. Mr. Young, during
the representation, signed another attorney’s name, “with permission”, to an order without
authorization from said attorney and then presented said order to the presiding judge ex parte and
obtained the judge’s signature. The order named an attorney ad litem to the conservatorship case, and
Mr. Young, after obtaining the judge’s signature, failed to then file the pleading with the clerk of the
court and failed to advise the guardian ad litem or the newly appointed attorney ad litem of the court
order. Mr. Young, in the same case, also filed pleadings with incomplete information and multiple
documents with improper notarizations.
Mr. Young executed a Conditional Guilty Plea acknowledging that his conduct violated
Tennessee Rules of Professional Conduct 1.3 (diligence); 3.3(a) (candor toward the tribunal); and
3.5(b) (impartiality and decorum of the tribunal).
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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JOSEPH TIMOTHY ZANGER, #022600
SUMNER COUNTY
On July 17, 2024, Joseph Timothy Zanger, an attorney licensed to practice law in Tennessee,
received a Public Censure from the Board of Professional Responsibility of the Tennessee Supreme
Court.
Mr. Zanger made several procedural errors in handling an adoption case for one client and failed
to obtain entry of a Qualified Domestic Relations Order (QDRO) for over three (3) years for another
client.
By these acts, Mr. Zanger has violated Rule of Professional Conduct 1.1 (competence), 1.3
(diligence), 1.4 (communication), 1.16 (declining or terminating representation) and 3.2 (expediting
litigation) 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.
REINSTATEMENTS
MATTHEW DAVID BAROCAS, BPR #031962
KNOX COUNTY
By Order of the Tennessee Supreme Court entered May 14, 2024, Matthew David Barocas was
reinstated to the active practice of law conditioned upon his continuing compliance with the terms and
conditions of the Order of Enforcement entered January 18, 2024.
On January 18, 2024, Mr. Barocas was suspended by the Supreme Court of Tennessee for one
(1) year with three (3) months to be served as an active suspension. Mr. Barocas filed a Petition for
Reinstatement pursuant to Tennessee Supreme Court Rule 9, Section 30.4(c), on April 17, 2024. The
Board found the Petition was satisfactory and submitted an Order of Reinstatement to the Court.

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JAY NELSON CHAMNESS, BPR #016027
WILLIAMSON COUNTY
By Order of the Tennessee Supreme Court entered April 29, 2024, the law license of Jay Nelson
Chamness was transferred from inactive status to active status.
On December 8, 2024, the Supreme Court entered an Order of Removal from Disability Inactive
Status, requiring Mr. Chamness to remain on inactive status pending resolution of a pending
disciplinary matter. On April 17, 2024, Mr. Chamness resolved his pending disciplinary matter, and
the Supreme Court entered an Order of Reinstatement to Active Status, reinstating Mr. Chamness to
active status effective April 17, 2024.
JAMES THOMAS DUBOIS, JR., BPR #013777
MAURY COUNTY
By Order of the Tennessee Supreme Court entered April 10, 2024, the law license of James
Thomas Dubois, Jr. was reinstated to the active practice of law pursuant to Section 27.7 of Tennessee
Supreme Court Rule 9.
On February 13, 2023, Mr. Dubois was placed on disability inactive status. Mr. Dubois filed a
Petition for Transfer to Active Status on March 14, 2024, demonstrating he no longer suffers from a
disability. The Board found the Petition was satisfactory and submitted an Order of Reinstatement to
the Court. Pursuant to the Order of the Tennessee Supreme Court, Mr. Dubois is immediately eligible
to practice law in the state of Tennessee.
ARTHUR C. GRISHAM, JR., BPR #001071
HAMILTON COUNTY
By Order of the Tennessee Supreme Court entered August 15, 2024, Arthur C. Grisham, Jr.,
was reinstated to the active practice of law.
On April 29, 2024, Arthur C. Grisham was temporarily suspended by the Supreme Court of
Tennessee for failing to respond to the Board of Professional Responsibility concerning a complaint of
misconduct. Thereafter, Mr. Grisham provided a response to the Board and filed pleadings seeking to
dissolve the temporary suspension. The matter was referred by the Supreme Court to a Board Panel for

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a hearing on the merits. The matter was heard July 19, 2024, and Panel entered its report on August 12,
2024, recommending the temporary suspension be dissolved.
The Supreme Court adopted the recommendation of the Board Panel and reinstated Mr.
Grisham’s license to practice law in the state of Tennessee.
R.W. HARDISON aka RANDY WAYNE HARDISON, BPR #009479
WILLIAMSON COUNTY
By Order of the Tennessee Supreme Court entered April 4, 2024, Randy Wayne Hardison was
reinstated to the active practice of law.
On April 17, 2019, Randy Wayne Hardison was suspended by the Supreme Court of Tennessee
for five (5) years retroactive to his August 29, 2017, temporary suspension. On October 12, 2023, Mr.
Hardison filed a Petition for Reinstatement to the practice of law pursuant to Tennessee Supreme Court
Rule 9, Section 30.4(d). After a final hearing on the merits, the Hearing Panel recommended Mr.
Hardison’s license to practice law be reinstated. The Panel determined specifically that Mr. Hardison
had demonstrated by clear and convincing evidence he had the moral qualifications, competency, and
learning in law required for admission to practice in this state, and his resumption of the practice of law
within the state would not be detrimental to the integrity and standing of the bar or the administration
of justice, or subversive to the public interest.
Accordingly, the Board of Professional Responsibility shall cause notice of this reinstatement
to be published as required by Tennessee Supreme Court Rule 9, Section, 28.11.
MATTHEW LEE HARRIS, BPR #030176
COFFEE COUNTY
By Order of the Tennessee Supreme Court entered May 22, 2024, Matthew Lee Harris was
reinstated to the active practice of law.
On April 17, 2024, Mr. Harris was temporarily suspended by the Supreme Court of Tennessee
for substantial noncompliance with a Tennessee Lawyer Assistance Program (TLAP) monitoring
agreement. Mr. Harris filed a Petition for Reinstatement to the practice of law pursuant to Tennessee
Supreme Court Rule 9, Section 30.4(c) on May 16, 2024, demonstrating he was currently in substantial

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compliance with the monitoring agreement. The Board found the Petition was satisfactory and
submitted an Order of Reinstatement to the Court.
KENT THOMAS JONES, BPR #020158
HAMILTON COUNTY
By Order of the Tennessee Supreme Court entered June 28, 2024, Kent Thomas Jones was
reinstated to the active practice of law.
On February 26, 2024, Mr. Jones was suspended by the Supreme Court of Tennessee for ninety
(90) days. Mr. Jones filed a Petition for Reinstatement to the practice of law pursuant to Tennessee
Supreme Court Rule 9, Section 30.4(c), on June 5, 2024. The Board found the Petition was satisfactory
and submitted an Order of Reinstatement to the Court.
As a condition of reinstatement, Mr. Jones is to complete satisfaction of his payment of costs
by making two (2) payments of $1,150.50 to the Board of Professional Responsibility. The first
payment is to be received by the Board no later than thirty (30) days from the date of this Order, and
the second payment is to be received by the Board no later than sixty (60) days from the date of this
Order.
JUDITH-ANNE ROSS ST. CLAIR, BPR #034024
COFFEE COUNTY
By Order of the Tennessee Supreme Court entered June 24, 2024, Judith-Anne Ross St. Clair
was reinstated to the active practice of law with conditions.
On July 20, 2018, Ms. Clair was suspended by the Supreme Court of Tennessee for three (3)
years with six (6) months active suspension and the remainder on probation. Ms. St. Clair filed a
Petition for Reinstatement to the practice of law pursuant to Tennessee Supreme Court Rule 9, Section
30.4(d), on October 17, 2023. The matter was tried before a Hearing Panel, and on April 24, 2024, the
Panel recommended Ms. St. Clair be reinstated to the practice of law with conditions.
Ms. St. Clair’s reinstatement to the active practice of law is conditioned upon engagement of a
practice monitor, continued compliance with her TLAP monitoring agreement, attendance at the next
two Camp TLAP events, continued engagement with her therapist for one year, and completion of

63

fifteen hours of Continuing Legal Education, including at least three hours of legal ethics, as long as
she remains licensed.
DISABILITY INACTIVE
RICHARD ALAN GORDON, BPR #012321
SHELBY COUNTY
By Order of the Tennessee Supreme Court entered May 31, 2024, the law license of Richard
Alan Gordon was transferred to disability inactive status pursuant to Section 27.1 of Tennessee
Supreme Court Rule 9.
Mr. Gordon cannot practice law while on disability inactive status. He may return to the
practice of law after reinstatement by the Tennessee Supreme Court upon showing that his disability
has been removed in accordance with Tennessee Supreme Court Rule 9, Section 27.7.
KEITH ALLEN POPE, BPR # 014146
KNOX COUNTY
By Order of the Tennessee Supreme Court entered July 15, 2024, the law license of Keith Allen
Pope was transferred to disability inactive status pursuant to Section 27.4 of Tennessee Supreme Court
Rule 9.
Mr. Pope cannot practice law while on disability inactive status and shall comply with the
requirements of Tennessee Supreme Court Rule 9, Section 28, regarding the obligations and
responsibilities of attorneys transferred to disability inactive status. He may return to the practice of
law after reinstatement by the Tennessee Supreme Court upon showing by clear and convincing
evidence that the disability has been removed and he is fit to resume the practice of law in accordance
with Tennessee Supreme Court Rule 9, Section 27.7.

64

HOWARD GRAHAM SWAFFORD, JR., BPR #006150
MARION COUNTY
By Order of the Tennessee Supreme Court entered August 5, 2024, the law license of Howard
Graham Swafford, Jr., was transferred to disability inactive status pursuant to Section 27.3 of Tennessee
Supreme Court Rule 9.
Mr. Swafford cannot practice law while on disability inactive status and shall comply with the
requirements of Tennessee Supreme Court Rule 9, Section 28, regarding the obligations and
responsibilities of attorneys transferred to disability inactive status. Mr. Swafford may return to the
practice of law after reinstatement by the Tennessee Supreme Court upon showing that his disability
has been removed in accordance with Tennessee Supreme Court Rule 9, Section 27.7.
JACK RANDAL TOMBLIN, BPR #023151
SHELBY COUNTY
By Order of the Tennessee Supreme Court entered April 18, 2024, the law license of Jack
Randal Tomblin was transferred to disability inactive status pursuant to Section 27.3 of Tennessee
Supreme Court Rule 9.
Mr. Tomblin cannot practice law while on disability inactive status and shall comply with the
requirements of Tennessee Supreme Court Rule 9, Section 28 regarding the obligations and
responsibilities of attorneys transferred to disability inactive status. He may return to the practice of
law after reinstatement by the Tennessee Supreme Court upon showing that his disability has been
removed in accordance with Tennessee Supreme Court Rule 9, Section 27.7.
WALTER FRANCIS WILLIAMS, BPR #005929
HAMILTON COUNTY
By Order of the Tennessee Supreme Court entered September 13, 2024, the law license of
Walter Francis Williams was transferred to disability inactive status pursuant to Section 27.4 of
Tennessee Supreme Court Rule 9.
Mr. Williams cannot practice law while on disability inactive status and shall comply with the
requirements of Tennessee Supreme Court Rule 9, Section 28, regarding the obligations and

65

responsibilities of attorneys transferred to disability inactive status. Mr. Williams may return to the
practice of law after reinstatement by the Tennessee Supreme Court upon showing that his disability
has been removed in accordance with Tennessee Supreme Court Rule 9, Section 27.7.
ANDREW NICHOLAS WILSON, BPR #025760
SEVIER COUNTY
By Order of the Tennessee Supreme Court entered September 26, 2024, the law license of
Andrew Nicholas Wilson was transferred to disability inactive status pursuant to Section 27.4 of
Tennessee Supreme Court Rule 9.
Mr. Wilson cannot practice law while on disability inactive status and shall comply with the
requirements of Tennessee Supreme Court Rule 9, Section 28, regarding the obligations and
responsibilities of attorneys transferred to disability inactive status. Mr. Wilson may return to the
practice of law after reinstatement by the Tennessee Supreme Court upon showing by clear and
convincing evidence that his disability has been removed in accordance with Tennessee Supreme Court
Rule 9, Section 27.7, and that he is fit to resume the practice of law.

66

FUND PAYMENTS
KEVIN CARMACK ANGEL BPR #019950
ANDERSON COUNTY
On September 5, 2024, the Tennessee Lawyers’ Fund for Client Protection (Lawyers’ Fund)
paid a claim filed against Kevin Carmack Angel, in the amount of $39,585.54.
Lawyers’ Fund, financed by Tennessee lawyers and judges, was established by the Tennessee
Supreme Court to reimburse individuals for losses caused by the rare instances of dishonest conduct by
attorneys. The Tennessee Supreme Court appoints a Lawyers’ Fund Board, consisting of six lawyers
and three non-attorney members, who serve without compensation in considering and paying claims
pursuant to Tennessee Supreme Court Rule 25.
Mr. Angel is required to reimburse Lawyers’ Fund for the amount paid to any claimant pursuant
to Tennessee Supreme Court Rule 25 Section 16 and/or the Order of Enforcement entered by the
Supreme Court of Tennessee.
MATTHEW DAVID DUNN, JR. BPR #030759
WILLIAMSON COUNTY
On June 20, 2024, the Tennessee Lawyers’ Fund for Client Protection (Lawyers’ Fund) paid a
claim filed against Matthew David Dunn, in the amount of $4,995.00.
Lawyers’ Fund, financed by Tennessee lawyers and judges, was established by the Tennessee
Supreme Court to reimburse individuals for losses caused by the rare instances of dishonest conduct by
attorneys. The Tennessee Supreme Court appoints a Lawyers’ Fund Board, consisting of six lawyers
and three non-attorney members, who serve without compensation in considering and paying claims
pursuant to Tennessee Supreme Court Rule 25.
Mr. Dunn is required to reimburse Lawyers’ Fund for the amount paid to any claimant pursuant
to Tennessee Supreme Court Rule 25 Section 16 and/or the Order of Enforcement entered by the
Supreme Court of Tennessee.

67

ERIC JOHN MONTIERTH BPR #031679
ROANE COUNTY
On October 2, 2024, the Tennessee Lawyers’ Fund for Client Protection (Lawyers’ Fund) paid
a claim filed against Eric John Montierth, in the amount of $4,700.00.
Lawyers’ Fund, financed by Tennessee lawyers and judges, was established by the Tennessee
Supreme Court to reimburse individuals for losses caused by the rare instances of dishonest conduct by
attorneys. The Tennessee Supreme Court appoints a Lawyers’ Fund Board, consisting of six lawyers
and three non-attorney members, who serve without compensation in considering and paying claims
pursuant to Tennessee Supreme Court Rule 25.
Mr. Montierth is required to reimburse Lawyers’ Fund for the amount paid to any claimant
pursuant to Tennessee Supreme Court Rule 25 Section 16 and/or the Order of Enforcement entered by
the Supreme Court of Tennessee.

68

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