Ohio State Bar Association v. McCafferty

140 Ohio St. 3d 229, 2014-Ohio-3075 (2014) · Supreme Court of Ohio · July 17, 2014 · No. 2013-0939

Summary

The Supreme Court of Ohio held that Bridget Marie McCafferty violated several Ohio Rules of Professional Conduct and Ohio Code of Judicial Conduct provisions through felony convictions for making false statements to FBI agents. The court imposed an indefinite suspension from the practice of law without credit for her interim felony suspension, beginning after completion of her federal supervised release.

Court
Supreme Court of Ohio
Writing for the Court
O'Neill, J.; Pfeifer, J.; O'Donnell, J.; Kennedy, J.; O'Connor, C.J.; Lanzinger, J.; French, J.
Jurisdiction
Ohio
Decision date
July 17, 2014
Docket number
2013-0939
Procedural posture
Attorney-discipline proceeding arising from a certified report of the Board of Commissioners on Grievances and Discipline concerning respondent's felony convictions and related professional and judicial misconduct.
Standard of review
The Supreme Court of Ohio independently reviewed and adopted the board's findings of fact, conclusions of law, and recommended sanction.
Precedential value
published precedential opinion
Parties
Ohio State Bar Association v. Bridget Marie McCafferty
Disposition
other

Topics

criminal procedureprosecutorial misconductremedies

Practice areas

legal ethics and attorney disciplinejudicial disciplineprofessional responsibilitycriminal misconduct

Questions Presented

  1. Whether McCafferty's federal convictions and related conduct violated the cited Ohio Rules of Professional Conduct and Ohio Code of Judicial Conduct provisions.
  2. Whether the appropriate disciplinary sanction was disbarment, a fixed-term suspension, or an indefinite suspension without credit for the prior interim felony suspension.

Holdings

  1. McCafferty's conduct violated Prof.Cond.R. 8.4(b), (c), (d), and (h), and Jud.Cond.R. 1.1, 1.2, 1.3, and 2.4(B). Her federal convictions constituted conclusive evidence of the charged acts, and her false statements about attempts to influence her judicial conduct also constituted an abuse of the prestige of judicial office.
  2. An indefinite suspension from the practice of law, without credit for time served under the interim felony suspension, was appropriate. The interim suspension would continue until McCafferty completed all terms of federal supervised release and was discharged by the federal district court, after which the indefinite suspension would begin.

Key quotations

When a judge’s felonious conduct brings disrepute to the judicial system, the institution is irreparably harmed (¶ 16)
Thus, we determine that an indefinite suspension without credit for time served is the appropriate sanction for her misconduct. (¶ 25)
Her interim felony suspension continues until she completes all terms of her federal supervised release and has been discharged by the federal district court, and this indefinite suspension will begin at that time. (¶ 26)

Factual background

Bridget Marie McCafferty served as a Cuyahoga County Court of Common Pleas judge while the FBI investigated corruption involving county officials. During an interview, she made false statements about contacts with and possible influence by Frank Russo, James Dimora, and Steve Pumper concerning matters connected to her courtroom. She was convicted of four federal false-statement offenses and received imprisonment, supervised release, community service, and a fine. Her conduct also violated multiple Ohio Rules of Professional Conduct and Ohio Code of Judicial Conduct provisions.

Procedural history

McCafferty was convicted in federal court of four merged counts of making false statements to FBI agents. The Supreme Court of Ohio imposed an interim felony suspension, after which the Ohio State Bar Association filed a disciplinary complaint. A three-member hearing panel and the Board of Commissioners on Grievances and Discipline found multiple violations and recommended an indefinite suspension without credit for the interim suspension. The Supreme Court adopted those findings and recommendation.

Court Document

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