Category: Duty of Competence

Georgia Supreme Court Suspends Lawyer for Two Years for Neglect of Client Matter

Georgia Supreme Court Suspends Lawyer for Two Years for Neglect of Client Matter

In the Matter of Ramon David Sammons, Jr., No. S26Y0848 (Ga. Aug. 11, 2026) (per curiam)

Disposition: 24-month suspension, with conditions on reinstatement.

A Georgia lawyer was suspended for two years for abandoning a client whose case he took. He will need to show that his mental health issues, including depression, have been treated before he can be reinstated. The court found some degree of mitigation because the lawyer notified the disciplinary authorities of the violation. In Georgia, the Supreme Court reviews the findings of a Special Master who is retained to hear evidence and make factual and credibility findings. in this case the Supreme Court accepted the findings of the Special Master.

Procedural posture: Third time before the Court. (1) First remand: Court vacated a default judgment because Sammons wasn’t actually in default when it entered. (2) Second remand: Special Master recommended accepting Sammons’s petition for voluntary discipline (public reprimand), but the Court rejected it without prejudice because his claimed mitigation (depression/anxiety since age 18, therapy, medication) wasn’t supported by any evidence in the record. (3) This decision: on second remand, a new Special Master granted summary judgment to the State Bar and recommended a 24-month suspension; Sammons filed no exceptions.

Underlying misconduct (Rules 1.2(a), 1.3, 1.4): Retained in 2017 on contingency to pursue a personal injury claim for an elderly dementia patient (through her daughter) against a nursing home. Sammons received the medical records, told the daughter he’d completed the demand letter — then went silent. He ignored her repeated calls and emails for roughly six months, including one flagging that the statute of limitations was about to run, and never responded. The limitations period expired and the claim died. (An unauthorized-practice count under Rule 5.5(a) was dismissed without prejudice earlier in the proceedings and isn’t at issue here.)

The Defense: The lawyer defended on the ground that he had untreated mental illness. The lawyer failed to prove up that defense with proper medical testimony, however. The lawyer did participate in the process, but that was insufficient to avoid discipline.

Mental state finding: Initial disregard deemed negligent, but the Special Master found Sammons’s later, more serious conduct — continued silence, failure to correct his bar-registration address (which caused the original service/default problem), and general avoidance — was “knowing,” inferred from the circumstances under Rule 1.0(o).

Aggravating factors (ABA Std. 9.22): dishonest/selfish motive (abandoning the case to avoid admitting the missed deadline); a two-year pattern of misconduct; multiple rule violations; bad-faith obstruction of the disciplinary process itself (ignoring orders, the grievance, and the Bar’s investigation notice; baseless denials of his own emails); vulnerability of the client/victim; his substantial experience practicing law; and no restitution or effort to rectify the harm.

Mitigation: The Special Master didn’t disbelieve his mental-health claims, but his failure to submit any corroborating evidence (despite being ordered to and given the opportunity) sharply undercut their weight — this is what moved the case from “likely reprimand” to suspension/disbarment territory. The only real credit given: no prior discipline, and some acceptance of responsibility via the voluntary-discipline petition.

Sanction analysis: Applying ABA Standard 4.4 (duty of diligence), the Court agreed the harm (destroying the client’s claim by abandonment) would typically warrant disbarment absent mitigation — citing In the Matter of Bell and In the Matter of Starling. But because Sammons’s mitigation, though poorly supported, wasn’t disbelieved and his record was otherwise clean, the Court followed the Special Master’s recommendation and imposed suspension rather than disbarment, citing comparable cases (Whiteside – 3 months; Golub – 12 months; Jaconetti – 36 months with conditions; Bagwell – 24 months with conditions, closely analogous on facts).

Reinstatement conditions: Petition to the Review Board must include a licensed psychologist/psychiatrist’s written certification of competency to practice; if reinstated, Sammons must undergo a Law Practice Management Program evaluation and implement its recommendations within six months, with proof submitted to the Bar’s General Counsel.

If you run into trouble, call an experienced attorney to discuss what to do next. There are often pathways to curing the problem or mitigating the discipline if you act promptly and appropriately. Counsel is the way to go here. We can often help if you don’t wait too long to contact us.

ARDC Review Board Recommends Suspension of Immigration Lawyer

ARDC Review Board Recommends Suspension of Immigration Lawyer

Given the government’s focus on immigration enforcement, lawyers in the immigration area should expect to see more disciplinary enforcement. What would draw the interest of the disciplinary authorities are cases where the lawyer neglected immigration cases or took funds from clients and did not complete the work. The ARDC review board recommended a two-year suspension of an attorney. This decision is from the Review Board. It is a recommendation. The Review Board reviews recommendations of the ARDC Hearing Board. The Illinois Supreme Court has the final say on all disciplinary matters.

Summary: In re Mahdis Azimi — ARDC Review Board Report (Feb. 2026)

Background

Mahdis Azimi, an Illinois immigration attorney admitted in 2015, faced a ten-count disciplinary complaint arising from misconduct in ten client matters between September 2021 and October 2023. She operated a solo practice while simultaneously holding a full-time administrative position at Loyola University School of Law.

Misconduct Found

The Hearing Board found violations across all ten counts, including:

  • Failing to file immigration petitions in seven matters
  • Making false representations to clients in multiple cases (claiming filings had been made when they had not)
  • Ignoring client communications
  • Failing to refund unearned fees in six cases
  • Failing to surrender client files in four cases
  • Depositing client funds into her operating account rather than a trust account
  • Failing to comply with the Administrator’s subpoena for four client files
  • Making a false statement during a sworn statement to the Administrator
  • Providing false testimony at the disciplinary hearing itself

Key Aggravating Factors

  • Prior discipline for nearly identical misconduct (90-day suspension in 2022), with the current misconduct beginning while that prior case was pending
  • A persistent pattern of dishonesty, not attributable to her mental health diagnoses (ADHD, PTSD, anxiety, depression) per the Administrator’s unrebutted psychiatric expert, Dr. Rone
  • Failure to accept full responsibility
  • Lack of credibility as a witness on key issues
  • No restitution made; no trust account ever opened

Mental Health

Azimi raised mental health as a mitigating factor. Dr. Rone acknowledged her diagnoses could explain disorganization but concluded the pattern of dishonesty was not a symptom of those conditions. Dr. Rone recommended years of dialectical behavioral therapy and found Azimi’s current treatment inadequate and her prognosis for ethical practice poor absent significant intervention. Azimi presented no rebuttal expert, having been barred from doing so after missing disclosure deadlines.

Procedural Rulings Affirmed

The Review Board upheld the Hearing Board Chair’s rulings barring Azimi’s expert witness (due to non-compliance with disclosure deadlines), allowing Dr. Rone’s testimony, and permitting the Administrator’s closing argument on lack of remorse. No due process violation was found.

One Exception — Count VII

The Review Board found the Administrator failed to prove Azimi cashed the client money orders at issue in Count VII, and therefore vacated the Rule 1.15(a) (misuse of funds) finding on that count only. All six other violations in Count VII were affirmed.

Sanction

  • Hearing Board recommended: 3-year suspension, UFO
  • Review Board recommended: 2-year suspension, UFO (until further order of court)

The Review Board found a three-year suspension unnecessarily long, but agreed a UFO provision was essential given Azimi’s recidivism, dishonesty pattern, and the psychiatric expert’s conclusion that she remains unfit to practice. To seek reinstatement, she must affirmatively demonstrate rehabilitation, ethical fitness, restitution, and that her mental health treatment has been effective.

Comment: in the immigration area, the client may be vulnerable to deportation. Few of these clients will have the ability to file a legal malpractice lawsuit if they have been deported. For that reason, disciplinary authorities will view these cases as good targets for enforcement. Please keep this in mind if you do this type of work.

No Matter How Bad It Is, Always Participate In the Disciplinary Process

No Matter How Bad It Is, Always Participate In the Disciplinary Process

The Georgia Supreme Court accepted a Special Master’s recommendation to disbar a lawyer, William Joseph Cloud. The court noted that the lawyer failed to respond to disciplinary complaints arising from two client matters. Cloud, who had been administratively suspended in 2021 for failing to pay bar dues, was deemed to have admitted all factual allegations because he defaulted in the disciplinary proceedings.

Facts: In one matter a tattoo‑business client paid Cloud $2,500 to pursue litigation; after Cloud became ineligible to practice he failed to notify the court or client, ignored discovery, and the client suffered a default judgment and paid a $500 sanction before hiring new counsel. In the other matter a client entrusted Cloud $12,000 to redeem property sold at tax sale; Cloud never used or returned the funds and the client lost the opportunity to reclaim the property.

Rule violations and harm: The court found (by default) multiple ethics breaches, including abandonment of client matters, failures to communicate, mishandling and conversion of client funds, practicing while ineligible, and dishonesty. The misconduct caused actual harm — monetary loss and litigational prejudice — and was deemed knowing rather than merely negligent.

The court cited certain aggravating factors: conversion of client funds, pattern of neglect, multiple offenses, and substantial experience in practice. The only mitigating factor was a clean disciplinary record prior to these matters.

The Georgia Supreme Court accepted the Special Master’s recommendation and ordered Cloud disbarred.

Comments: Always participate in the process. Acknowledge that you made a mistake, even if you are going to face a severe sanction. Then you can at least apply for reinstatement or get on with your life in another trade or business. We can often help you resolve a matter, even an awful one, if you participate, say are sorry and try to make it right.

Iowa Supreme Court Reprimands Attorney For Missed Deadlines

Iowa Supreme Court Reprimands Attorney For Missed Deadlines

The Iowa Supreme Court has reprimanded an attorney for missing deadlines in appellate matters. The court chose to reprimand rather than suspend because no clients were harmed or prejudiced by the missed deadlines. The cite is Iowa Supreme Court Attorney Disciplinary Board v. Anderson, No. 24-1894. Missing deadlines is a violation of professional rules and can lead to discipline. The court upheld findings that the lawyer violated Rules 1.3, 3.2 and 8.4(d).

Lawyer Referred to Grievance Panel for Nonexistent Citation

Lawyer Referred to Grievance Panel for Nonexistent Citation

Park v. Kim, No. 22-2057, was decided by the Second Circuit Court of Appeals on January 30, 2024. The Court, citing Rule 37 and Rule 41(b), affirmed the dismissal of Plaintiff’s lawsuit for failure to comply with discovery and other obligations. The court also sanctioned the attorney for the plaintiff for using Chat-GPT to prepare portions of one of the briefs. The AI tool generated a fake case which was cited in the brief. The Court held that the failure to check citations violated Rule 11.

“All counsel that appear before this Court are bound to exercise professional judgment and responsibility, and to comply with the Federal Rules of Civil Procedure. Among other obligations, Rule 11 provides that by presenting a submission to the court, an attorney “certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances . . . the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law.” Fed. R. Civ. P. 11(b)(2); see also N.Y. R. Pro. Conduct 3.3(a) (McKinney 2023) (“A lawyer shall not knowingly: (1) make a false statement of . . . law to a tribunal.”). “Rule 11 imposes a duty on attorneys to certify that they have conducted a reasonable inquiry and have determined that any papers filed with the court are well grounded in fact, [and] legally tenable.” Cooter & Gell v. Hartmarx Corp., 496 U.S. 384, 393 (1990). “Under Rule 11, a court may sanction an attorney for, among other things, misrepresenting facts or making frivolous legal arguments.” Muhammad v. Walmart Stores E., L.P., 732 F.3d 104, 108 (2d Cir. 2013) (per curiam).

At the very least, the duties imposed by Rule 11 require that attorneys read, and thereby confirm the existence and validity of, the legal authorities on which they rely. Indeed, we can think of no other way to ensure that the arguments made based on those authorities are “warranted by existing law,” Fed. R. Civ. P. 11(b)(2), or otherwise “legally tenable.” Cooter & Gell, 496 U.S. at 393. As a District Judge of this Circuit recently held when presented with non-existent precedent generated by ChatGPT: “A fake opinion is not `existing law’ and citation to a fake opinion does not provide a non-frivolous ground for extending, modifying, or reversing existing law, or for establishing new law. An attempt to persuade a court or oppose an adversary by relying on fake opinions is an abuse of the adversary system.” Mata v. Avianca, Inc., No. 22CV01461(PKC), 2023 WL 4114965, at *12 (S.D.N.Y. June 22, 2023).

Attorney Lee states that “it is important to recognize that ChatGPT represents a significant technological advancement,” and argues that “[i]t would be prudent for the court to advise legal professionals to exercise caution when utilizing this new technology.” Response at 2. Indeed, several courts have recently proposed or enacted local rules or orders specifically addressing the use of artificial intelligence tools before the court.[3] But such a rule is not necessary to inform a licensed attorney, who is a member of the bar of this Court, that she must ensure that her submissions to the Court are accurate.

Attorney Lee’s submission of a brief relying on non-existent authority reveals that she failed to determine that the argument she made was “legally tenable.” Cooter & Gell, 496 U.S. at 393. The brief presents a false statement of law to this Court, and it appears that Attorney Lee made no inquiry, much less the reasonable inquiry required by Rule 11 and long-standing precedent, into the validity of the arguments she presented. We therefore REFER Attorney Lee to the Court’s Grievance Panel pursuant to Local Rule 46.2 for further investigation, and for consideration of a referral to the Committee on Admissions and Grievances. See 2d Cir. R. 46.2.

We further ORDER Attorney Lee to provide a copy of this ruling to Plaintiff-Appellant Park — translated into Korean if necessary to permit Park to understand it — within twenty-one days, and to file a certification on the docket in this case attesting that she has done so.”

Comment: it saddens me that this trend of sloppy work and citing fake cases has continued. If you cannot complete your work on time and ask an AI tool to practice law, you can expect discipline.

Ed Clinton, Jr.

www.clintonlaw.net

Florida Issues Proposed Advisory Opinion 24-1 on Lawyer use of AI

Florida Issues Proposed Advisory Opinion 24-1 on Lawyer use of AI

Florida has issued a proposed guideline on the use of AI in the legal field. The guidelines are solid and practical. This is not a final opinion.

Part I – The lawyer has a duty of confidentiality and a duty to understand the technology:

A lawyer’s first responsibility when using generative AI should be the protection of the confidentiality of the client’s information as required by Rule 4-1.6 of the Rules Regulating The Florida Bar. The ethical duty of confidentiality is broad in its scope and applies to all information learned during a client’s representation, regardless of its source. Rule 4-1.6, Comment. Absent the client’s informed consent or an exception permitting disclosure, a lawyer may not reveal the information. In practice, the most common exception is found in subdivision (c)(1), which permits disclosure to the extent reasonably necessary to “serve the client’s interest unless it is information the client specifically requires not to be disclosed[.]” Rule 4-1.6(c)(1). Nonetheless, it is recommended that a lawyer obtain the affected client’s informed consent prior to utilizing a third-party generative AI program if the utilization would involve the disclosure of any confidential information.

Rule 4-1.6(e) also requires a lawyer to “make reasonable efforts to prevent the inadvertent or unauthorized disclosure of, or unauthorized access to, information relating to the client’s representation.” Further, a lawyer’s duty of competence requires “an understanding of the benefits and risks associated with the use of technology[.]” Rule 4-1.1, Comment.

When using a third-party generative AI program, lawyers must sufficiently understand the technology to satisfy their ethical obligations. For generative AI, this specifically includes knowledge of whether the program is “self-learning.” A generative AI that is “self-learning” continues to develop its responses as it receives additional inputs and adds those inputs to its existing parameters. Neeley, supra n. 2. Use of a “self-learning” generative AI raises the possibility that a client’s information may be stored within the program and revealed in response to future inquiries by third parties.

The opinion explains that the lawyer should understand the AI company’s policies regarding confidentiality and its policies on data retention. Does the provider disclose information to third parties? Does the provider sell your search history to other advertisers?

Part II – A lawyer also has a duty to verify the accuracy of any work product or text created by the AI software.

While Rule 4-5.3(a) defines a nonlawyer assistant as a “a person,” many of the standards applicable to nonlawyer assistants provide useful guidance for a lawyer’s use of generative AI.

First, just as a lawyer must make reasonable efforts to ensure that a law firm has policies to reasonably assure that the conduct of a nonlawyer assistant is compatible with the lawyer’s own professional obligations, a lawyer must do the same for generative AI. Lawyers who rely on generative AI for research, drafting, communication, and client intake risk many of the same perils as those who have relied on inexperienced or overconfident nonlawyer assistants.

Second, a lawyer must always review the work product of a generative AI just as the lawyer must do so for the work of nonlawyer assistants such as paralegals. Lawyers are ultimately responsible for the work product that they create regardless of whether that work product was originally drafted or researched by a nonlawyer or generative AI.

Functionally, this means a lawyer must verify the accuracy and sufficiency of all research performed by generative AI. The failure to do so can lead to violations of the lawyer’s duties of competence (Rule 4-1.1), avoidance of frivolous claims and contentions (Rule 4-3.1), candor to the tribunal (Rule 4-3.3), and truthfulness to others (Rule 4-4.1), in addition to sanctions that may be imposed by a tribunal against the lawyer and the lawyer’s client.

Third, these duties apply to nonlawyers “both within and outside of the law firm.” ABA Comm. on Ethics and Prof’l Responsibility, Formal Op. 498 (2021); see Fla. Ethics Op. 07-2. The fact that a generative AI is managed and operated by a third-party does not obviate the need to ensure that its actions are consistent with the lawyer’s own professional and ethical obligations.

Further, a lawyer should carefully consider what functions may ethically be delegated to generative AI. Existing ethics opinions have identified tasks that a lawyer may or may not delegate to nonlawyer assistants and are instructive. First and foremost, a lawyer may not delegate to generative AI any act that could constitute the practice of law such as the negotiation of claims or any other function that requires a lawyer’s personal judgment and participation.

Comments: AI is going to challenge the legal profession in ways we cannot fully understand. Just remember (a) don’t divulge confidences and (b) monitor any outputs from the AI to make sure that those outputs are factually true and based on existing caselaw.

What Should You Do If Your Device Is Hacked?

A few years ago there were bar association advisory opinions on whether lawyers could use email or cloud computing. Now almost everyone uses at least a smartphone with cloud computing capability. What should you do if your device is lost or stolen or you suspect that there may have been a data breach? California has released a new advisory opinion. No. 16-0002. The opinion covers a number of situations where the lawyer has reason to fear or believe that client data was accessed by a hacker. The option discusses several examples, from a lost phone (which is recovered quickly) to a missing laptop. The bottom line is that where there is a reasonable suspicion of an intrusion into a device, the lawyer must notify the clients involved.

In one of the examples an attorney visits a cafe and uses what he believes to be the free wifi. The attorney later learns that the “free wifi” network did not belong to the cafe but was the creation of some bad actor or hacker. The attorney realizes that client documents on his device were accessed. What is the lawyer to do?

According to the opinion, once he learns of the data breach the lawyer must notify the client that there was an intrusion into his laptop and that the company’s confidential information was accessed by some unknown person. The opinion insists that lawyers should not be held to a strict liability standard when it comes to data theft or loss. The example above is distinguished from the typical situation where a lawyer leaves his phone or iPad at a restaurant and retrieves it the next day. Since the device is password protected, there is no danger to clients that the missing device was accessed improperly.

The ABA Opinion No. 18-483

ABA Formal Opn. No. 18-483 (Lawyer’s Obligations After an Electronic Data Breach or Cyberattack) provides a useful list of competence-based duties that explain the requirement of “reasonable efforts” in addressing the potential for inadvertent disclosure of confidential client information due to a data breach:

• The obligation to monitor for a data breach: “lawyers must employ reasonable efforts to monitor the technology and office resources connected to the internet, external data sources, and external vendors providing services relating to data and the use of data.” Id. at p. 5.

• When a breach is detected or suspected, lawyers must “act reasonably and promptly to stop the breach and mitigate damage resulting from the breach.” Id. at p. 6. A preferable approach is to have a data breach plan in place “that will allow the firm to promptly respond in a coordinated manner to any type of security incident or cyber intrusion.” Id. at p. 6.

• Investigate and determine what happened: “Just as a lawyer would need to assess which paper files were stolen from the lawyer’s office, so too lawyers must make reasonable attempts to determine whether electronic files were accessed, and if so, which ones. A competent attorney must make reasonable efforts to determine what occurred during the data breach.” Id. at p. 7.

ABA Formal Opn. No. 18-483 describes a “data breach” as a “data event where material client confidential information is misappropriated, destroyed, or otherwise compromised, or where a lawyer’s ability to perform the legal services for which the lawyer is hired is significantly impaired by the episode.” ABA 18-483 at p. 4.4 Thus, not all events involving lost or stolen devices, or unauthorized access to technology, would necessarily be considered a data breach. Consistent with their obligation to investigate a potential data breach, however, lawyers and law firms should undertake reasonable efforts, likely through the use of individuals with expertise in such investigations, to ascertain, among other things, the identity of the clients affected, the amount and sensitivity of the client information involved, and the likelihood that the information has been or will be misused to the client’s disadvantage. This will assist in determining whether there is a duty to disclose. If the lawyer or law firm is unable to make such a determination, the client should be advised on that fact. Id. at p. 14.

Lawyers and clients may also differ as to what events would trigger the duty to disclose. The key principle, however, in considering whether the event rises to the level of a data breach, is whether the client’s interests have a “reasonable possibility of being negatively impacted.” ABA 18-483 at 11. Certainly disclosure is required in situations where a client will have to make decisions relevant to the breach, such as the need to take mitigating steps to prevent or minimize the harm, or to analyze how the client’s matter should be handled going forward in light of a breach. When in doubt, lawyers should assume that their clients would want to know, and should err on the side of disclosure.

Passwords and Security Measures

If a lawyer failed to protect a device with a password, I believe that there might be grounds for a professional complaint or lawsuit. The opinion does not go this far, but I believe that every device containing client confidences should be protected by a strong password.

If you have a question about an ethics issue, do not hesitate to contact me. The sooner you get impartial advice the better. Many problems can be solved by seeking the advice of a disinterested ethics lawyer.

https://www.clintonlaw.net/legal-ethics.html

West Virginia Suspends Criminal Lawyer for 120 Days for Failing To Meet Appeal Deadlines

The case is captioned Lawyer Disciplinary Board v. Sayre, 18-0617, West Virginia Supreme Court. Sayre represented a client in a case where the client was convicted of attempted murder. Sayre missed several deadlines in the appeal process. The court set forth the facts as follows:

The events that led to Mr. Sayre’s conduct underlying this disciplinary proceeding first originated in 2016 when Mr. Sayre was appointed to be counsel in a criminal matter arising in Wood County. An order adjudging Mr. Sayre’s client guilty upon a jury verdict of guilty to the offense of second-degree murder was entered by the Circuit Court of Wood County on March 14, 2016. Mr. Sayre and another attorney were then appointed as appellate counsel. On March 15, 2016, Mr. Sayre filed a request for transcripts in the case. Three days later, he filed a notice of appeal with the Supreme Court of Appeals of West Virginia. A scheduling order was entered by the Supreme Court of Appeals of West Virginia on April 1, 2016, setting the deadline for perfecting the appeal as July 15, 2016.

Mr. Sayre did not perfect the appeal before the deadline. On July 22, 2016, a notice of intent to sanction was entered by this Court, directing him to perfect the appeal within ten days and show good cause as to why the appeal was not timely perfected. On August 9, 2016, Mr. Sayre filed a motion to extend the deadline and requested an additional sixty days to perfect the appeal, noting that he had received the trial transcript within the past thirty days. His motion was granted, and the deadline for perfecting the appeal was extended to September 15, 2016.

Mr. Sayre filed two more motions to extend the deadline to perfect the appeal—both of these motions were untimely. In his motion dated September 16, 2016, he requested an additional sixty days to perfect the appeal and asserted that he had not been able to completely review the transcripts or obtain feedback from his client to complete the brief. This motion was granted, and he was ordered to perfect the appeal on or before October 17, 2016. Later, on October 26, 2016, he filed another motion to extend, citing an overload of appointed work and a recent illness, and advised that he would have the appeal perfected by October 28, 2016. Mr. Sayre did not file the appeal by October 28, 2016, and the Court entered another notice of intent to sanction on November 4, 2016, directing him to file the brief within fifteen days, and show cause as to why the appeal was not perfected timely. Mr. Sayre filed his brief on January 4, 2017. This Court considered the appeal on the merits and issued a unanimous decision affirming the order sentencing Mr. Sayre’s client.

Sayre was found to have engaged in the violations of the following rules:

A Statement of Charges was issued against Mr. Sayre, and filed with this Court on July 9, 2018. It set forth the following alleged violations of the West Virginia Rules of Professional Conduct: Rules 1.1[6] and 1.2(a)[7] for failure to provide competent representation to his clients consistent with their stated objectives of timely pursuing appeals; Rule 1.3[8] for failure to diligently pursue his clients’ appeals; Rules 1.4(a)[9] and 1.4(b)[10] for failure to adequately keep his clients informed and for failure to communicate; Rule 3.2[11] for failure to make efforts to expedite appeals consistent with the desires of his clients; Rules 3.4(c)[12] and 8.4(d)[13]because he repeatedly violated the Rules of Appellate Procedure by failing to comply with multiple orders issued by the Supreme Court of Appeals of West Virginia

Sayre was also charge with exchanging text messages of a sexual nature with another criminal client. This was found to violate Rule 1.8(j) and 8.4(a).