Introduction

In Disciplinary Counsel v. Taylor, Slip Opinion No. 2025-Ohio-4804 (Supreme Court of Ohio, Oct. 23, 2025), the court imposed a significant sanction on an Ohio attorney who brandished weapons and issued graphic threats against his former employer and “innocents” in the building where the employer’s law firm was located. The decision reinforces several core principles in Ohio attorney discipline:

• Threatening and weaponized conduct can violate Prof.Cond.R. 8.4(b) and 8.4(h) even when no criminal charges are filed (¶¶ 7–9).
• Failure to attend the disciplinary hearing is an aggravating factor and can warrant a longer period of actual suspension (¶ 11).
• Where a respondent hints at a behavioral-health explanation but provides no substantiated evidence under Gov.Bar R. V(13)(C)(7), the court will calibrate the sanction to protect the public, often increasing the actual time away from practice (¶¶ 12, 22–23).
• Reinstatement may be conditioned on an OLAP assessment, adherence to treatment, and a healthcare opinion confirming fitness to return (¶ 24).

The opinion sits within Ohio’s well-developed framework of sanctioning attorneys whose conduct threatens public safety and confidence in the profession, while also acknowledging the role of mental health in mitigation when supported by evidence. It is an important signal about the proof burdens for mental-health mitigation, the consequences of nonappearance, and the court’s willingness to depart upward from a board’s recommended sanction to ensure public protection.

Case Background and Issues

Respondent, Ronald Coleman Taylor Jr. (admitted in Ohio in 2008 and also licensed in Kentucky), engaged in two episodes on April 8, 2024: first, he appeared at his former law office in Cincinnati with a shaved head and “war paint,” retrieved a hatchet and a metal baseball bat, and issued threats, including a demand that his former employer “face him in a duel” (¶¶ 6–7). Later that day, he texted his former legal assistant a series of violent threats referencing taking a “scalp,” “drinking [blood],” and employing a Molotov cocktail at a mediation to harm “innocents” (¶ 8).

No criminal charges were filed (¶ 7). The Disciplinary Counsel filed charges in September 2024, alleging violations of:

• Prof.Cond.R. 8.4(b) — committing an illegal act that reflects adversely on the lawyer’s honesty or trustworthiness;
• Prof.Cond.R. 8.4(h) — engaging in other conduct that adversely reflects on the lawyer’s fitness to practice law (¶ 9).

The parties stipulated to facts and misconduct and proposed an 18-month suspension with one year stayed and conditions tied to health. Taylor, however, did not attend the disciplinary hearing and was unrepresented. Disciplinary Counsel, being the only person who had spoken with Taylor in the process, withdrew the jointly recommended sanction at hearing, leaving sanction to the panel’s discretion (¶ 3).

The panel found misconduct by clear and convincing evidence and recommended an 18-month suspension with one year stayed, plus OLAP and healthcare-based reinstatement conditions (¶ 4). The Board adopted those recommendations. The Supreme Court independently reviewed the record and modified the sanction upward by reducing the stay, increasing the actual suspension time (¶ 5).

Summary of the Opinion

The Supreme Court of Ohio adopted the Board’s findings that Taylor violated Prof.Cond.R. 8.4(b) and 8.4(h) through his threatening conduct and violent text messages (¶ 9). Applying Gov.Bar R. V(13), the Court found two aggravating factors — multiple offenses and failure to appear at the disciplinary hearing — and only minimal mitigation (a clean prior disciplinary record), noting the complete absence of substantiated mental-health evidence (¶¶ 11–12, 22–23).

Comparing sanction precedents, the Court concluded the Board’s recommended six months of actual suspension was insufficient to protect the public in light of the severity and premeditation of Taylor’s conduct and his nonappearance. It therefore imposed an 18‑month suspension with six months stayed, resulting in 12 months of actual suspension, and conditioned reinstatement on:

• Proof of an OLAP assessment and compliance with any treatment or counseling recommendations; and
• A report from a qualified healthcare professional attesting that Taylor can resume the competent, ethical, professional practice of law (¶ 24).

Costs were taxed to Taylor. No objections were filed (¶ 4).

Analysis

1) Precedents Cited and Their Influence

• Disciplinary Counsel v. O’Neill, 2004-Ohio-4704, ¶ 53: Cited for the bedrock principle that attorney discipline is protective, not punitive (¶ 10). This frames the entire sanction analysis and justifies extending the period of actual suspension when public safety and professional competence are at issue.
• Disciplinary Counsel v. Bricker, 2013-Ohio-3998, ¶ 21: Used to support application of Prof.Cond.R. 8.4(h) to threatening conduct that adversely reflects on fitness to practice (¶ 9). Bricker confirms that violent or terrorizing threats implicate a lawyer’s fitness irrespective of the context.
• Disciplinary Counsel v. Hoover, 2022-Ohio-769: Hoover involved a manic episode, threats with a shotgun, and felony conviction, followed by intensive treatment and significant mental-health mitigation under Gov.Bar R. V(13)(C)(7) (¶¶ 14–15). Sanction: a two-year suspension with credit for nearly 18 months under an interim felony suspension, plus treatment-based reinstatement conditions. Hoover demonstrates how documented mental-health mitigation can temper sanction severity while still protecting the public via treatment compliance.
• Disciplinary Counsel v. Haven, 2024-Ohio-5278: Haven involved a mental-health crisis with self-directed harm, a gun, OVI, and a standoff; there was some psychological evaluation but insufficient evidence to qualify for (C)(7) mental-health mitigation (¶¶ 16–17). Sanction: one-year suspension with stringent reinstatement conditions, including OLAP. Haven serves as a sanction benchmark when mental-health concerns are present but not adequately proved as mitigation.
• Disciplinary Counsel v. Bissell, 2024-Ohio-1974: A consent case involving road-rage threats, false claims of being a police officer, and a minimal criminal penalty (a disorderly conduct fine) (¶¶ 18–20). With numerous mitigating factors and cooperation, the sanction was a two-year suspension fully stayed. The Court distinguishes Taylor’s premeditated, weaponized threats and minimal mitigation as more egregious than Bissell (¶ 21).

These precedents supplied the sanctioning spectrum: Bissell (less severe conduct, robust mitigation, cooperated) to Hoover (severe conduct but proven mental-health mitigation) to Haven (serious conduct without sufficient mental-health proof). Taylor falls closer to Haven — a serious incident with no substantiated mitigation and aggravation from nonappearance — warranting approximately one year of actual suspension with robust reinstatement conditions (¶ 23).

2) Legal Reasoning

The Court’s legal reasoning proceeds in three steps: misconduct findings, aggravation/mitigation, and sanction calibration.

• Misconduct:
  • Prof.Cond.R. 8.4(b): Taylor committed an “illegal act” reflecting adversely on honesty or trustworthiness by threatening harm to his former employer (¶ 9). Importantly, the Court did not require a criminal charge or conviction; clear and convincing proof of the underlying illegal conduct sufficed. The threatening texts and weaponized appearance supplied that proof (¶¶ 6–9).
  • Prof.Cond.R. 8.4(h): Challenging someone to a duel, brandishing a hatchet and bat, and threatening to “firebomb” a building to harm “innocents” adversely reflects on fitness to practice law (¶ 9). Bricker confirms this application of 8.4(h).
• Aggravation and Mitigation under Gov.Bar R. V(13):
  • Aggravating factors: multiple offenses (on-site threats and later texts) (V(13)(B)(3)) and failure to attend the hearing, with last-minute notice to relator (V(13)(B)(5)) (¶ 11).
  • Mitigation: clean prior disciplinary record (V(13)(C)(1)) (¶ 12). Although Taylor entered stipulations, the Board found that cooperation tempered by nonappearance carried little weight (¶ 12).
  • Mental-health mitigation: None proved. The Court noted that although there had been “some discussion” of a possible mental disorder and the respondent had planned to present evidence, he did not appear to do so; thus, there was no (C)(7) mitigation (¶¶ 12, 23).
• Sanction Calibration:
  • Protective purpose: The Court emphasized that discipline protects the public, not punishes the lawyer (O’Neill; ¶ 10).
  • Comparative analysis: Taylor’s premeditation, weapon brandishing, and explicit threats to harm “innocents” make the conduct more egregious than Bissell and on par with the “range” of Hoover and Haven (¶ 23). Yet, unlike Hoover, Taylor presented no mental-health documentation.
  • Nonappearance as risk signal: Leaving the panel and Court without any information regarding mental status or treatment increased concern about the respondent’s readiness to safely practice and justified additional actual suspension time (¶¶ 5, 22–23).
  • Final sanction: 18 months with six months stayed — effectively 12 months actual — paired with condition-based reinstatement (OLAP assessment and compliance; healthcare professional opinion of fitness) (¶ 24). This mirrors Haven’s actual time while adding a longer overall term and similar safeguards.

3) Impact and Forward-Looking Significance

This decision clarifies and strengthens several practical rules in Ohio attorney discipline:

• Illegal acts under 8.4(b) do not require criminal charges or convictions. Clear and convincing evidence of threatening or menacing conduct is sufficient to establish a violation (¶ 9). Regulators can proceed on proofs of the act itself.
• Weaponized, terrorizing threats predictably trigger 8.4(h). Challenges to “duels,” brandishing weapons, and threats to “firebomb” buildings are archetypal fitness breaches (¶ 9). Bricker remains a sturdy anchor for 8.4(h).
• Nonappearance is sanction-aggravating and undermines mitigation. A respondent who fails to attend the hearing forfeits the chance to substantiate mental-health mitigation and invites a longer period of actual suspension (¶¶ 11–12, 22–23).
• Mental-health mitigation must be proven under Gov.Bar R. V(13)(C)(7). Mere assertions or “discussion” of a disorder is inadequate; reports, diagnoses, treatment records, and expert opinions matter. Without them, the Court will default to public protection over leniency (¶¶ 12, 23).
• OLAP and medical fitness opinions as reinstatement gatekeepers. The Court continues to rely on OLAP assessments and healthcare-professional opinions to ensure that a returning lawyer can practice competently, ethically, and safely (¶ 24).
• Board and party recommendations are not binding. Especially where respondent noncooperation skews the record, the Court may increase the actual suspension to calibrate risk and protection (¶ 5).

For practitioners and defense counsel, Taylor underscores the urgency of assembling a robust mitigation record when behavioral health is implicated: obtain a timely OLAP assessment, secure treating-provider or independent expert opinions, document treatment engagement, and attend the hearing. For regulators, it confirms the permissibility of proceeding on 8.4(b) and 8.4(h) in the absence of criminal proceedings and the propriety of seeking conditions that operationalize safe re-entry to practice.

Complex Concepts Simplified

• “Illegal act” under Prof.Cond.R. 8.4(b) without a conviction: The disciplinary process is separate from criminal court. The rule is violated if the lawyer’s conduct satisfies an illegal act, proven by clear and convincing evidence in the disciplinary record; no criminal case is required (¶ 9).
• Prof.Cond.R. 8.4(h) “fitness” catch-all: This provision covers conduct that, while not necessarily tied to honesty or trustworthiness, demonstrates the lawyer’s unfitness to practice — including violent or terrorizing threats (¶ 9).
• Aggravating and mitigating factors (Gov.Bar R. V(13)): The Court weighs aggravators (e.g., multiple offenses, nonappearance) against mitigators (e.g., no prior discipline, cooperation, proven mental-health disorders) to set sanctions (¶¶ 11–12).
• Stayed suspension vs. actual suspension: A stayed portion of a suspension is not served if the lawyer complies with conditions (often “no further misconduct” and costs). The “actual” portion must be served away from practice. Here: 18 months with six months stayed yields 12 months actual (¶ 24).
• OLAP assessment and treatment conditions: The Ohio Lawyers Assistance Program evaluates and supports lawyers with substance use and mental-health issues. Conditioning reinstatement on OLAP and medical clearance ensures the lawyer can safely and ethically return (¶ 24).
• Interim remedial suspension (Gov.Bar R. V(19)(B)): An emergency, protective suspension imposed upon substantial, credible evidence of a rule violation and a substantial threat of serious harm (¶ 1).

Conclusion

Disciplinary Counsel v. Taylor refines Ohio’s sanctioning jurisprudence for violent, threatening conduct by lawyers. The Court confirms that:

• Threats and weaponized behavior can establish violations of Prof.Cond.R. 8.4(b) and 8.4(h) without criminal charges, when proven by clear and convincing evidence (¶ 9).
• Nonappearance at the disciplinary hearing is an aggravator and can defeat otherwise available mitigation, justifying more actual suspension time (¶¶ 11–12, 22–23).
• Where mental-health issues are asserted but not proven under Gov.Bar R. V(13)(C)(7), the Court will err on the side of public protection, here imposing 12 months of actual suspension within an 18-month term and robust reinstatement safeguards (¶¶ 5, 23–24).

The decision’s principal contribution is to crystallize the sanctioning approach when behavioral-health mitigation is unsubstantiated and the respondent does not participate meaningfully in the process. By coupling a longer period of actual suspension with OLAP and medical-fitness conditions, the Court both protects the public and preserves a pathway for safe, ethical reentry into the profession once the respondent’s readiness is demonstrably established.

Key Takeaways

• Expect heightened actual suspension where violent threats are premeditated, weaponized, and unmitigated by competent mental-health evidence.
• Attend the hearing and present comprehensive mitigation if behavioral health is implicated; otherwise, Haven-level or greater actual suspension is likely.
• OLAP assessment and a healthcare professional’s fitness opinion are increasingly standard reinstatement conditions in threat-related cases.
• Stipulations to misconduct help but cannot substitute for proof of mitigation, especially when nonappearance leaves the record incomplete.