Random Case-Assignment Manipulation and Undisclosed Conflicts Trigger Presumptive Actual Suspension for Judicial Dishonesty

I. Introduction

In Disciplinary Counsel v. Celebrezze, Slip Opinion No. 2026-Ohio-45 (Jan. 13, 2026), the Supreme Court of Ohio disciplined Leslie Ann Celebrezze, an Ohio attorney (admitted 1999) who served as a judge on the Cuyahoga County Court of Common Pleas, Domestic Relations Division, until her resignation on December 22, 2025. The case arose from a certified report by the Board of Professional Conduct.

The core allegations concerned two intersecting forms of misconduct: (1) manipulation of judge-assignment processes in a multi-judge domestic-relations division—particularly the rules requiring random assignment/reassignment after a judge’s recusal; and (2) repeated appointments (or attempted appointments) of a close personal friend and “love interest,” Mark Dottore, to lucrative court roles (receiver or mediator) without disclosure of the relationship, including approving substantial receiver fees. A further dimension involved dishonesty: Celebrezze made false statements during the disciplinary investigation minimizing or denying the nature of her relationship with Dottore.

The case therefore presented the Court with issues of: judicial integrity and impartiality (including conflicts and disclosure), compliance with the Superintendence Rules and local assignment rules, misuse of administrative authority, ex parte and disqualification concerns, and how dishonesty in the disciplinary process affects sanction selection.

II. Summary of the Opinion

The Court adopted the Board’s findings that Celebrezze committed multiple violations of the Code of Judicial Conduct and the Rules of Professional Conduct, including Jud.Cond.R. 1.2, 2.5, 2.9(A), and 2.11(A), and Prof.Cond.R. 8.1(a), 8.4(c), and 8.4(d). Celebrezze stipulated to all 15 charged rule violations.

As a sanction, the Court imposed a two-year suspension from the practice of law, with the second year stayed on the condition of no further misconduct, and taxed costs to Celebrezze. Because she had resigned from judicial office, the Court did not impose a judicial suspension without pay.

The opinion’s key sanctioning move is its explicit linkage of: (a) the presumptive need for an actual suspension when dishonesty is present, (b) the “special weight” of random-assignment rules in safeguarding public confidence, and (c) the compounding effect of undisclosed personal conflicts in appointments and fee approvals—together warranting a more serious sanction than a reprimand or a short, largely stayed suspension.

III. Analysis

A. Precedents Cited

The Court built its analysis on three clusters of authority: (1) cases and authorities emphasizing the institutional importance of random assignment, (2) sanctioning frameworks for dishonesty and mitigation, and (3) comparative judicial-discipline cases calibrating sanctions.

1. Random assignment as an institutional safeguard

• In re Disqualification of Celebrezze, 2023-Ohio-4383: The Court quoted its earlier disqualification decision for the proposition that random assignment protects against judge-shopping, equitably distributes cases, and—critically—maintains public confidence by ensuring assignments are impartial and not deliberately directed to a particular judge. In the disciplinary opinion, that principle becomes more than background: it is treated as a structural value whose violation magnifies sanction severity.
• United States v. Phillips, 59 F.Supp.2d 1178 (D.Utah 1999): Cited to underscore that random assignment “promot[es] fairness and impartiality” and reduces dangers of favoritism and bias. The Ohio Court used this federal district court articulation to reinforce “universal condemnation” of assignment manipulation as a cross-jurisdictional norm.

2. Underlying procedural rules invoked

• Sup.R. 36.011 commentary and Sup.R. 36.011: Referenced for the purposes of random assignment (avoid judge-shopping; equitable distribution; public confidence).
• Former Sup.R. 36.019(A), 150 Ohio St.3d C, CIX: The operative rule at the time: following a judge’s recusal, the administrative judge “shall randomly assign” the case among remaining eligible judges. The opinion notes the later amendment replacing “recusal” with “disqualification,” but applies the former language because it governed the misconduct.
• Cuyahoga C.P., Domestic Relations Div., Loc.R. 2(B)(2) (“Loc.R. 2(B)(2)”): The local analog reinforcing random reassignment obligations after recusal in domestic-relations cases.
• Sup.R. 4.01(C): Cited for the proposition that a recused judge lacks authority to select a successor—highlighting the impropriety in asking a recused judge to transfer a case directly.

3. Defining a receiver

• In re All Cases Against Sager Corp., 2012-Ohio-1444: Quoted for the definition of a receiver as “an indifferent person between the parties” appointed to preserve property/funds in litigation. This definition mattered because it sharpened the conflict problem: repeated selection of a close personal associate for a role that presupposes neutrality.

4. The mandamus/disqualification backdrop

• Abedrabbo v. Reali, 2023-Ohio-152: Referenced as the mandamus action in which the Court granted an alternative writ compelling rulings on pending motions. In the disciplinary narrative, that mandamus proceeding becomes leverage Celebrezze allegedly invoked when pressuring another judge to transfer a case.

5. The sanctioning framework and “presumptive actual suspension” for dishonesty

• Ohio State Bar Assn. v. Winkler, 2024-Ohio-3141: Cited for the general sanction methodology: consider violated duties, aggravating/mitigating factors (Gov.Bar R. V(13)), and comparable sanctions.
• Disciplinary Counsel v. Dann, 2012-Ohio-5337 and Disciplinary Counsel v. O'Neill, 2004-Ohio-4704: Used to situate judicial discipline’s public-protection purpose and the heightened harm caused by judges’ misconduct to public perception of the legal system.
• Disciplinary Counsel v. Fowerbaugh, 1995-Ohio-261: The key doctrinal anchor: when a lawyer engages in conduct involving dishonesty, fraud, deceit, or misrepresentation, the lawyer “will be actually suspended” for an appropriate period. The Court treated this as a presumptive baseline.
• Mahoning Cty. Bar Assn. v. Macala, 2024-Ohio-3158 and Disciplinary Counsel v. Markijohn, 2003-Ohio-4129: Provide the tempering principles: the presumption can be tempered for an isolated dishonest incident or where there is an “abundance of mitigating evidence.”

6. What qualifies as “abundance of mitigation” (and what does not)

• Columbus Bar Assn. v. Villarreal, 2024-Ohio-5165, Disciplinary Counsel v. Miller, 2024-Ohio-4939, and Disciplinary Counsel v. Moore, 2024-Ohio-5198: Cited as examples where significant mitigation (remorse, restitution, long unblemished careers, alcoholism in recovery, treatment for mental disorder, military service) justified tempering the presumptive suspension.
• Disciplinary Counsel v. Summers, 2012-Ohio-1144 and Disciplinary Counsel v. Agopian, 2006-Ohio-6510: Used to benchmark the volume and weight of character evidence in strong mitigation showings (roughly 40–50 letters).
• Disciplinary Counsel v. Goodman, 2024-Ohio-852: Supports skepticism toward character letters that do not specifically address the misconduct at issue.
• Toledo Bar Assn. v. Hickman, 2005-Ohio-6513: A closer comparator: seven letters and cooperation, but no “significant extenuating or unusual circumstances,” resulting in an actual suspension. The Court analogized Celebrezze’s sparse mitigation to Hickman.

7. Comparator cases for sanction calibration (six months to indefinite)

• Disciplinary Counsel v. Hale, 2014-Ohio-5053 and Disciplinary Counsel v. Goulding, 2020-Ohio-4588: Six-month outcomes (one actual; one fully stayed) tied to interference in single cases with fewer aggravators—distinguished because Celebrezze’s misconduct spanned multiple cases over years.
• Disciplinary Counsel v. Hunter, 2023-Ohio-4168 (and cited felony-conviction comparators Disciplinary Counsel v. Terry, 2016-Ohio-563, Disciplinary Counsel v. McAuliffe, 2009-Ohio-1151, Disciplinary Counsel v. Gallagher, 1998-Ohio-592): Felony conviction commonly warrants indefinite suspension or permanent disbarment; Celebrezze had no conviction, making indefinite suspension less fitting.
• Disciplinary Counsel v. Carr, 2022-Ohio-3633: The “unprecedented” misconduct case (over 100 incidents, systemic disregard for due process, repeated dishonesty) supporting indefinite suspension; used to show Celebrezze’s misconduct, though serious, did not reach Carr’s scale.
• Disciplinary Counsel v. Gaul, 2023-Ohio-4751: Actual one-year suspension for abusing judicial position to assist in overturning federal convictions and other misconduct (29 violations); cited for similarity in abusing the power of the office.
• Ohio State Bar Assn. v. Jacob, 2017-Ohio-2733: Two-year suspension with one year stayed for falsifying court records and soliciting prostitution; used as a dishonesty comparator involving record falsification and bypassing procedure.
• Disciplinary Counsel v. Medley, 2004-Ohio-6402: 18-month suspension with six months stayed for deciding issues without hearing both sides and for dishonest conduct; used as a “procedural disregard” comparator, though the Court found Celebrezze’s misconduct worse due to conflicts and assignment manipulation.

8. Conflicts/abuse-of-office comparators

• Disciplinary Counsel v. Kegley, 2025-Ohio-910, Disciplinary Counsel v. Elum, 2012-Ohio-4700, Disciplinary Counsel v. Hoague, 2000-Ohio-340, Disciplinary Counsel v. O'Diam, 2022-Ohio-1370, Disciplinary Counsel v. Lemons, 2022-Ohio-3625: Cited to show that judicial conflicts, personal entanglements, and misuse of office are sanctionable, and to contextualize Celebrezze’s conduct as part of a broader line of cases policing impartiality and the appearance of impartiality.
• Disciplinary Counsel v. Connor, 2004-Ohio-6902: Quoted to emphasize the Court’s commitment to use “the full measure of our disciplinary authority” to restore confidence.

9. Judicial ethics baseline

• Ohio State Bar Assn. v. McCafferty, 2014-Ohio-3075 and Mahoning Cty. Bar Assn. v. Franko, 168 Ohio St. 17 (1958): Cited for the enduring proposition that judges are held to the highest ethical standard.

B. Legal Reasoning

1. Findings of misconduct: a layered integrity breach

The opinion presents Celebrezze’s misconduct as a sustained pattern, not a set of isolated lapses:

• Assignment manipulation and administrative pressure: Over nearly a year, Celebrezze repeatedly violated random reassignment requirements in multiple divorce matters (notably Jardine v. Jardine, Maron v. Maron, Rennell v. Rennell, and attempted involvement in Abedrabbo v. Abedrabbo), including pressuring colleagues to transfer cases to her and directing nonrandom reassignment.
• False entry/record representation: In Maron v. Maron, she signed an entry falsely stating the case had been randomly reassigned to her by electronic judge roll. This fact was central to triggering the Court’s dishonesty presumption analysis.
• Conflict of interest: repeated Dottore appointments and nondisclosure: She often appointed or recommended Dottore as receiver/mediator and approved substantial receiver fees in the Jardine case, without notifying parties of the close personal relationship.
• Dishonesty during the disciplinary investigation: She made false statements minimizing or denying the depth of her relationship and emotional attachment to Dottore. Even though the board found no sexual relationship, the Court treated her misrepresentations as materially aggravating.

2. Why random assignment violations matter more than mere technical noncompliance

A central contribution of the opinion is its insistence that assignment rules are not housekeeping details. By quoting In re Disqualification of Celebrezze, 2023-Ohio-4383, and United States v. Phillips, the Court framed random assignment as a legitimacy mechanism: it reduces favoritism, deters judge-shopping, and signals impartiality. On that view, manipulating assignment processes is inherently public-facing misconduct because it corrodes institutional trust even if the underlying merits of the cases are unaffected.

3. Sanction methodology: dishonesty triggers a presumptive actual suspension

The Court organized its sanction analysis around the Fowerbaugh presumption: when dishonesty is involved, an actual suspension is the starting point. It then tested whether Celebrezze qualified for recognized tempering exceptions identified in Mahoning Cty. Bar Assn. v. Macala: (1) isolated dishonesty or (2) an abundance of mitigation. It found neither.

Two reasoning moves are notable:

• Pattern + dishonest motive defeats “isolated incident” framing: The Court emphasized that misconduct spanned multiple cases and years, and included false statements made with a “dishonest or selfish motive.”
• Mitigation must be qualitatively and quantitatively strong: Seven character letters—especially those not specifically engaging the misconduct—were treated as comparatively weak mitigation under Disciplinary Counsel v. Summers, Disciplinary Counsel v. Agopian, and Disciplinary Counsel v. Goodman. Cooperation (stipulations) helped but did not approach the “abundance” seen in Villarreal, Miller, or Moore.

4. Calibrating the length: why two years with one stayed

The opinion mapped a spectrum:

• Six months is too low: Disciplinary Counsel v. Hale and Disciplinary Counsel v. Goulding involved single-case interference; Celebrezze’s misconduct was multi-case and prolonged.
• Indefinite is too high: Disciplinary Counsel v. Hunter (felony conviction) and Disciplinary Counsel v. Carr (unprecedented volume and systemic abuses) represent a higher tier.
• Middle-tier analogs support an actual suspension: The Court found more resonance with Disciplinary Counsel v. Gaul, Ohio State Bar Assn. v. Jacob, and Disciplinary Counsel v. Medley, while concluding Celebrezze’s combination of (i) assignment manipulation, (ii) conflict-driven appointments/fee approvals, and (iii) dishonesty justified the board’s two-year recommendation (one year stayed), rather than the relator’s shorter proposal.

The Court’s stated justification was restorative: the sanction is meant to address the “incalculable harm” to public perception and to “enhance public confidence” in judicial integrity (citing Disciplinary Counsel v. Dann and Disciplinary Counsel v. O'Neill), using the Court’s “full measure” of disciplinary authority (citing Disciplinary Counsel v. Connor).

C. Impact

• Elevating assignment integrity to a sanction multiplier: The opinion signals that violations of random assignment/reassignment rules—especially by an administrative judge and across multiple cases—will be treated as particularly damaging to the judiciary’s legitimacy, increasing the likelihood of a longer actual suspension.
• Conflict + nondisclosure in appointments is framed as systemic, not personal: By foregrounding the receiver’s role as “indifferent” (In re All Cases Against Sager Corp.), the Court underscores that steering appointments to close associates without disclosure is incompatible with judicial neutrality, particularly where money (fees) is involved.
• Dishonesty in the disciplinary process materially worsens outcomes: The opinion confirms that false statements during the investigation are not peripheral; they are aggravating facts that activate the Fowerbaugh presumption and narrow pathways to a stayed sanction.
• Mitigation evidence must engage the misconduct: Character letters that do not specifically address the charged conduct may carry reduced weight (Disciplinary Counsel v. Goodman), encouraging more candid, issue-specific mitigation submissions.

IV. Complex Concepts Simplified

• Random assignment / reassignment: A system that distributes cases among judges by chance (often electronically) to prevent parties or insiders from steering cases to preferred judges. In multi-judge courts, rules like former Sup.R. 36.019(A) require random reassignment after a judge recuses.
• Administrative judge: A judge with additional managerial responsibilities (e.g., overseeing assignment mechanics). The opinion treats abuse of this role—pressuring colleagues, directing nonrandom transfers—as especially serious.
• Receiver: A court-appointed neutral who takes custody/management of property or funds in dispute. Because the receiver must be “indifferent,” repeated selection of a close personal associate without disclosure raises acute impartiality concerns.
• Affidavit of disqualification: A formal request, filed in the Supreme Court of Ohio in this context, asking that a judge be removed from a case because the judge’s impartiality might reasonably be questioned. In the Jardine matter, such an affidavit resulted in Celebrezze’s removal (In re Disqualification of Celebrezze, 2023-Ohio-4383).
• Ex parte communication (Jud.Cond.R. 2.9(A)): A communication about a case with one side (or someone connected to the case) without the other side’s participation or notice, generally prohibited because it undermines fairness.
• Stayed suspension: A sanction where part of the suspension is “held back” so long as conditions are met. Here, one year was stayed on “no further misconduct”; violation lifts the stay and triggers the full two years.
• Aggravating vs. mitigating factors (Gov.Bar R. V(13)): Aggravators increase sanction severity (pattern of misconduct, multiple offenses, dishonest motive, false statements); mitigators reduce it (no prior discipline, cooperation, reputation evidence).
• Fifth Amendment invocation in discipline: Celebrezze asserted the right against self-incrimination and limited testimony. The proceeding still proceeded on stipulations and exhibits; discipline can be imposed based on clear and convincing evidence even without broad respondent testimony.

V. Conclusion

Disciplinary Counsel v. Celebrezze reinforces three intertwined principles of Ohio judicial discipline: (1) manipulation of random case-assignment and reassignment procedures—especially by an administrative judge—strikes at the heart of judicial legitimacy; (2) undisclosed personal relationships tied to appointments and fee approvals create disqualifying impartiality concerns and erode confidence in neutrality; and (3) dishonesty during the disciplinary process activates a presumptive need for an actual suspension under Disciplinary Counsel v. Fowerbaugh, rarely overcome without truly substantial mitigation.

The two-year suspension with one year conditionally stayed thus functions as both punishment and institutional repair—marking assignment integrity and transparent impartiality as nonnegotiable pillars of Ohio’s judicial system.