Public Reprimand for Practicing Law During Interim Suspension Amid Mental-Health Crisis: Columbus Bar Assn. v. Bryant

Introduction

In Columbus Bar Assn. v. Bryant (2025-Ohio-1879), the Supreme Court of Ohio confronted allegations of professional misconduct by attorney Kristin Jocele Bryant following a severe, involuntary psychiatric hospitalization. Admitted in 2006, Bryant suffered a bipolar manic episode and psychosis from late January to March 2023, during which her license was suspended on an interim basis. The Columbus Bar Association filed a five-count grievance in March 2024, alleging fifteen distinct violations of the Rules of Professional Conduct, including neglect of client matters, unauthorized practice during suspension, improper disclosure of confidential information, and misleading communications. After extensive stipulations, exhibits, and testimony, a Board of Professional Conduct panel dismissed most charges but found clear and convincing evidence that Bryant had practiced law in violation of Prof.Cond.R. 5.5(a) by identifying herself as counsel and contacting a former client during her interim suspension. The unanimous per curiam decision resolved the recommended sanction and reaffirmed both the strictures of regulation and the mitigated context of mental-health crisis.

Summary of the Judgment

The Supreme Court of Ohio adopted the Board’s findings and imposed a public reprimand—the least severe disciplinary sanction—for Bryant’s sole proven violation: practicing law during her interim suspension. The Court dismissed one additional alleged violation (Prof.Cond.R. 8.4(a)) and terminated the interim suspension to permit immediate application for reinstatement. Recognizing the absence of prior discipline, Bryant’s candid cooperation, her documented psychiatric treatment, and her ongoing contract with the Ohio Lawyers Assistance Program (OLAP), the Court conditioned her reinstatement on six months (and up to the full term) of continued compliance with her OLAP agreement and all medical-psychiatric recommendations.

Analysis

Precedents Cited

The Court’s analysis drew principally on two lines of authority. First, it applied Gov.Bar R. V(12)(G)–(I) regarding findings of misconduct and sanctions, and Gov.Bar R. V(19)–(24) governing interim suspensions and reinstatement procedures. Second, it compared this case to Cincinnati Bar Assn. v. Bucciere (2009-Ohio-1156), in which an attorney mistakenly practiced with inactive registration before two courts. In Bucciere, Ohio imposed a public reprimand for a single 5.5(a) violation, observing no client harm and an absence of dishonest motive. That background informed the Court’s conclusion that similar leniency was appropriate here, despite Bryant’s more acute health circumstances.

Legal Reasoning

The Court’s reasoning unfolded in three steps:

• Scope of Proven Misconduct: The panel dismissed all but two counts. One remaining count (Prof.Cond.R. 8.4(a)) was dropped for lack of clear and convincing proof. The only sustained charge was Prof.Cond.R. 5.5(a): Bryant’s voicemail calls on April 4 and 5, 2023, to Twin Valley Behavioral Healthcare, identifying herself as “attorney for A.S.,” occurred while her license was under interim suspension (Gov.Bar R. V(19)). By clear and convincing evidence, Bryant knowingly practiced law in violation of Ohio’s regulatory scheme.
• Sanction Framework: The Court weighed aggravating and mitigating factors under Gov.Bar R. V(13). There were no aggravators. Mitigators included absence of prior discipline, lack of dishonest motive, full cooperation, interim rehabilitation efforts, and Bryant’s voluntary OLAP contract. The Court noted that her incapacity during involuntary hospitalization—lack of communications, medications, and psychotic episodes—tempered culpability and limited client harm.
• Selection of Sanction: Given the isolated nature of the violation, its relationship to a mental-health crisis, and the precedential anchor in Bucciere, the Court concluded a public reprimand best served the objectives of attorney discipline: protection of the public, maintenance of confidence in the profession, and deterrence. To foster continued recovery and safeguard clients, reinstatement was conditioned on OLAP compliance and medical-psychiatric monitoring.

Impact

Columbus Bar Assn. v. Bryant establishes a nuanced precedent for cases involving mental-health crises intersecting with professional obligations. It affirms that:

• Interim suspension orders must be strictly observed—even during acute health emergencies.
• Mental-health episodes, while mitigating, do not excuse all regulatory duties; isolated rule violations still warrant discipline.
• Public reprimands remain a viable, rehabilitative sanction when misconduct is limited, non-fraudulent, and sufficiently explained by extraordinary health circumstances.
• Conditioning reinstatement on structured oversight (e.g., OLAP contracts) promotes recovery and client protection in the post-suspension phase.

Future disciplinary panels and the courts will likely cite this decision when balancing professional misconduct against documented medical crises, emphasizing both accountability and compassion.

Complex Concepts Simplified

Interim Suspension (Gov.Bar R. V(19)): A temporary halt to an attorney’s license, imposed without full hearing when immediate protection of the public is required.

Unauthorized Practice (Prof.Cond.R. 5.5(a)): Occurs whenever a lawyer knowingly performs services that constitute the practice of law while not authorized by the jurisdiction’s regulatory authority.

Clear and Convincing Evidence: A standard of proof requiring that the claim be highly probable or reasonably certain, a higher threshold than a “preponderance of the evidence” but lower than “beyond a reasonable doubt.”

Public Reprimand: The least severe formal sanction under Gov.Bar R. V(12)(I). It involves a written rebuke published in the Official Reports, without suspension or conditions beyond the discipline itself.

OLAP Contract: A voluntary agreement with the Ohio Lawyers Assistance Program to undergo treatment, counseling, and monitoring designed to address substance-use or mental-health issues and ensure fitness to practice.

Conclusion

Columbus Bar Assn. v. Bryant underscores the legal profession’s dual commitment to rigorous enforcement of practice rules and empathetic accommodation of extraordinary personal crises. While upholding the inviolability of interim suspension orders, the Supreme Court of Ohio recognized the weight of Bryant’s health emergencies, crediting her lack of intent, absence of client harm, and proactive rehabilitation. The resulting public reprimand, combined with conditional reinstatement and ongoing OLAP oversight, ensures both the integrity of Ohio’s bar and the well-being of an attorney grappling with serious mental-health challenges. As a precedent, it charts a path for balancing professional responsibility with compassion and draws clear guidelines for handling similarly sensitive disciplinary matters in the future.