Automatic Suspension and “Prior Discipline” for Attorney-Registration Noncompliance under Gov.Bar R. VI: The Supreme Court of Ohio’s 2025 Administrative Order

Citation: 11/04/2025 Administrative Actions, 2025-Ohio-4996

Court: Supreme Court of Ohio

Date: November 4, 2025 (orders issued November 3, 2025)

Introduction

In its November 2025 Administrative Actions, the Supreme Court of Ohio ordered the suspension of 288 attorneys for failing to comply with the biennial attorney-registration mandate under Gov.Bar R. VI for the 2025/2027 cycle. This action, though administrative rather than decisional in the traditional case-opinion sense, carries significant legal consequences, both immediate and prospective.

The Court’s order reiterates and operationalizes key features of Ohio’s attorney regulation framework: the automatic nature of suspension for registration noncompliance after notice, the broad scope of the practice limitations that attach upon suspension, the path to immediate reinstatement upon compliance, and—critically—the rule that such a suspension is treated as “prior discipline” for future sanction analysis under Gov.Bar R. V(17).

The parties implicated are not litigants but Ohio-admitted lawyers who did not register and pay the required fee by September 1, 2025, and who failed to cure within the 60-day grace period. Given that many attorneys can be reinstated immediately upon application and payment, the Court cautioned that the published list might not reflect current status at the time of reading. The Court provided the Registration and Continuing Legal Education Section’s contact number (614-387-9320) for real-time verification.

Summary of the Opinion

The Supreme Court of Ohio suspended, effective November 3, 2025, those attorneys who:

Failed to register and pay the biennial registration fee for 2025/2027 by September 1, 2025 (Gov.Bar R. VI(2)(A));
Failed to cure noncompliance within the 60-day late window (with late fee) following that deadline (Gov.Bar R. VI(10)(A)); and
Did not respond to the notice of apparent noncompliance by the date set therein (Gov.Bar R. VI(10)(B)).

The order imposes a comprehensive cease-and-desist from practicing law in any capacity for others in Ohio, forbids holding out as authorized to practice, and bars occupying roles in Ohio that require an attorney (including nonfederal judicial office and positions within the Ohio judicial system that must be held by lawyers). It specifically restricts appearances before any nonfederal court or agency in Ohio on behalf of others, while recognizing the ability of a person to appear for themself (pro se).

Reinstatement is available immediately upon application once five conditions are met: registration for all missed biennia, payment of all registration fees, payment of the reinstatement fee set by Gov.Bar R. VI(10)(D), filing of the designated reinstatement form, and reinstatement by the Registration and CLE Section. Until reinstated, the attorney’s status is “NOT IN GOOD STANDING.”

The order emphasizes that practitioners who ignore the suspension risk referral under Gov.Bar R. VII for unauthorized practice of law. It also declares that this administrative suspension will be treated as “prior discipline” if future sanctions under Gov.Bar R. V are imposed.

Analysis

Precedents and Authorities Cited

Although captioned as an administrative action rather than a conventional opinion, the Court’s order is anchored in and applies several controlling provisions of the Ohio Rules for the Government of the Bar:

Gov.Bar R. VI(2)(A) — Establishes the duty for attorneys admitted in Ohio to register for the biennium (here, 2025/2027) on or before September 1, 2025.
Gov.Bar R. VI(10)(A) — Creates a 60-day grace period after the deadline during which late registration is permitted upon payment of a late fee.
Gov.Bar R. VI(10)(B) — Provides that if an attorney fails to register and pay the required fees, the attorney shall be notified of apparent noncompliance and, absent proof of compliance by the date stated in the notice, “shall be suspended.” It also governs service by certified mail to the last address on file and makes such service effective.
Gov.Bar R. VI(10)(D) — Sets the reinstatement fee and contemplates reinstatement upon satisfaction of all enumerated conditions.
Gov.Bar R. V(17) — Directs that the registration suspension be considered “prior discipline” in any subsequent disciplinary proceeding where sanctions are determined.
Gov.Bar R. VII — Authorizes investigation and action against unauthorized practice of law; the order warns suspended attorneys that noncompliance may be referred under this rule.

These rules have long underpinned Ohio’s licensing and compliance regime. The present order applies them in a routine but consequential manner, consistent with prior biennial enforcement cycles. The cross-reference to Gov.Bar R. V(17) is particularly noteworthy because it signals the forward-looking disciplinary implications of what might otherwise be perceived as a purely administrative lapse.

Legal Reasoning and Application

The Court’s reasoning is straightforward and rule-driven:

Triggering Condition — The duty to register and pay by September 1, 2025, is mandatory. An attorney who does not comply enters a short, rule-based grace period (60 days) during which late registration is possible upon payment of an additional fee (Gov.Bar R. VI(10)(A)).
Notice and Automatic Suspension — If, after notice of apparent noncompliance, the attorney still fails to cure by the set date, suspension follows as a matter of course under Gov.Bar R. VI(10)(B). The rule makes the consequence mandatory and non-discretionary once the predicate facts are met. The Court expressly notes that service by certified mail to the last address on file constitutes effective service, which underscores the independent obligation to keep the Registration and CLE Section apprised of address changes.
Scope of Disability — The order catalogues the full suite of prohibitions that attach upon suspension:
- Cease-and-desist from practicing law in any form;
- No appearances on behalf of others before any nonfederal court or agency in Ohio;
- No counseling, advising, or preparation of legal instruments for others;
- No representation that the attorney is authorized to practice in Ohio;
- No holding nonfederal judicial office or occupying any position in Ohio that must be held by an attorney, including positions within the Ohio judicial system;
- Loss of all rights and privileges of a member in good standing and designation of status as “NOT IN GOOD STANDING.”
These conditions protect clients, courts, and the public by eliminating the risk of unlicensed legal services during the suspension period.
Reinstatement Mechanics — The Court permits immediate reinstatement upon compliance with five requirements: registering for all missed cycles, paying all registration fees, paying the reinstatement fee prescribed by Gov.Bar R. VI(10)(D), filing the designated reinstatement application, and receiving reinstatement from the Registration and CLE Section. The emphasis on “immediate upon application” reflects a policy preference for swift remediation once compliance is achieved, but reinstatement is not self-effectuating; it requires action by the administrative office.
Forward-Looking Disciplinary Consequences — The order declares that the registration suspension will count as “prior discipline” under Gov.Bar R. V(17) if any future sanction is imposed for professional misconduct. This elevates the compliance stakes by converting an administrative failure into a potential aggravator in later disciplinary analysis.
Unauthorized Practice Warning — The Court warns that continued practice during suspension may be referred under Gov.Bar R. VII for unauthorized practice of law. This deterrent is critical: practicing while suspended risks separate investigation and meaningful sanctions independent of the underlying registration issue.

Impact and Practical Consequences

The order’s legal and practical effects are broad and immediate:

For Attorneys — The suspension is effective as of November 3, 2025, and continues until the Registration and CLE Section formally reinstates the attorney. Practitioners must halt all legal services for others, update communications to remove any suggestion of Ohio authorization, and consider the possibility that federal courts or other jurisdictions may take note of their status. Although the order limits its prohibitions to nonfederal forums in Ohio, federal courts and other jurisdictions maintain their own admission and reciprocal-discipline protocols; attorneys should consult those bodies directly regarding any collateral consequences.
For Law Firms and Employers — Firms must ensure no suspended lawyer performs legal tasks for clients or occupies a role that must be held by an attorney. Implementing license-monitoring systems (e.g., automated reminders keyed to registration deadlines and grace periods) is a compliance best practice. Reassign client matters immediately where needed and document screening measures.
For Courts and Agencies — Clerks and tribunals may need to verify attorney status before permitting appearances, filings, or continued representation. The order’s breadth supports robust docket management and client protection by ensuring only authorized practitioners appear.
For Clients — Clients should verify their counsel’s current status (especially in November of a registration year) and, if necessary, seek substitute counsel to avoid delay or prejudice. The Court has made verification accessible via the Registration and CLE Section at 614-387-9320.
For Future Discipline — By designating these suspensions as “prior discipline,” the order increases the stakes of noncompliance. In any subsequent disciplinary proceeding under Gov.Bar R. V, a prior registration suspension can aggravate sanctions, encouraging consistent attention to licensure requirements.
Geographic Reach — The list features Ohio attorneys residing both in-state and out-of-state (and out-of-country). Admission in Ohio carries ongoing regulatory obligations regardless of residence. Attorneys “inactive” in practice but not formally designated inactive remain subject to registration rules.

Finally, the order’s service provisions—effective service by certified mail to the last address on file—highlight the administrative importance of updating addresses with the Registration and CLE Section. Failing to receive actual notice does not defeat effective service if the rule’s mailing requirement is met.

Complex Concepts Simplified

Biennium — A two-year registration period. Here, 2025/2027 refers to the period beginning 2025 through 2027 for which attorneys must register and pay by September 1, 2025.
Automatic Suspension — Once the rule’s conditions are satisfied (missed deadline, failed cure within 60 days after notice), the Court issues a suspension. No separate hearing is required because the rule makes the consequence mandatory after notice and noncompliance.
Scope of the Suspension — The suspended attorney cannot practice law for others in Ohio, cannot appear for others in Ohio’s nonfederal courts and agencies, cannot provide legal advice or prepare legal documents for others, and cannot hold positions that must be held by attorneys (including nonfederal judgeships and certain judicial system roles). The attorney’s status becomes “NOT IN GOOD STANDING.” The person may still represent themself (pro se).
Reinstatement — Not automatic. To return to practice, the attorney must (1) register for any missed cycles; (2) pay all overdue registration fees; (3) pay the reinstatement fee (Gov.Bar R. VI(10)(D)); (4) file the official reinstatement application; and (5) be reinstated by the Registration and CLE Section. Only after reinstatement does authorization resume.
Prior Discipline — Even though a registration suspension is administrative (not imposed after a misconduct hearing), the Court deems it “prior discipline” under Gov.Bar R. V(17). If the attorney later faces discipline for misconduct, this prior suspension can increase the severity of sanctions.
Unauthorized Practice of Law (UPL) — Practicing while suspended can trigger a separate investigation under Gov.Bar R. VII. UPL matters are distinct and can lead to additional penalties.
Effective Service — The order is served by certified mail to the last address on file with the Registration and CLE Section. Under Gov.Bar R. VI(10)(B), this constitutes effective service, even if the attorney did not update their address or did not actually receive the mailing.
Nonfederal vs. Federal Forums — The order expressly prohibits practice before nonfederal Ohio courts and agencies for others. Federal courts control their own bar admissions; attorneys should confirm any federal bar implications independently, as many federal courts require state good standing and may take reciprocal action.
Holding Out — “Holding out as authorized to practice” includes using signatures, business cards, websites, or social media that suggest active Ohio authorization. During suspension, those representations must be removed or modified.

Practical Guidance and Compliance Checklist

For attorneys aiming to cure suspension swiftly and avoid compounding risks:

Contact the Registration and CLE Section immediately (614-387-9320) to confirm status and obtain the reinstatement form.
Register for all missed biennia and pay all outstanding and reinstatement fees (as prescribed by Gov.Bar R. VI(10)(D)).
Cease all legal services for others in Ohio until formal reinstatement is confirmed.
Notify employers and, as appropriate, clients and courts to prevent prejudice or unauthorized practice.
Remove or update public representations (email signatures, websites, letterhead) that imply active Ohio authorization.
Establish calendaring alerts for future registration deadlines (e.g., multiple reminders in the 90/60/30 days pre-deadline window).
Keep the Registration and CLE Section updated on address changes to ensure notice is received.
If admitted in other jurisdictions or to federal courts, check those admission authorities for any reporting obligations or collateral consequences.

For law firms and legal employers:

Implement systematic license checks tied to known registration cycles.
Quarantine client work from any suspended attorney and reassign immediately.
Document compliance steps taken to prevent unauthorized practice within the organization.
Provide in-house training on what constitutes the “practice of law” to prevent inadvertent violations by suspended personnel.

Conclusion

The Supreme Court of Ohio’s 2025 Administrative Actions order is a robust enforcement of Gov.Bar R. VI’s biennial registration regime. It reaffirms that failure to register and pay by the deadline—followed by failure to cure within 60 days after notice—results in automatic suspension, broad practice prohibitions, and a “NOT IN GOOD STANDING” designation until reinstatement. Equally important, it clarifies that such a suspension is considered “prior discipline” under Gov.Bar R. V(17), an aggravating factor in any future sanction analysis.

While the order allows immediate reinstatement upon application and compliance, it also underscores due process (through notice) and effective service via certified mail to the attorney’s address of record. The message to the bar is clear: registration is not a formality; it is an enforceable licensing requirement with public-protection objectives, and lapses have both immediate operational consequences and potential long-term disciplinary implications.

For attorneys, firms, courts, and clients, the takeaways are practical and urgent—verify status, prioritize compliance, and implement systems that prevent administrative oversights from becoming professional and disciplinary liabilities.