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August 2026
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The Keystone Lex
 
From the Chair
 
The image is a professional headshot of the current Board Chair, Shohin H. Vance, smiling and wearing a suit and tie.

On August 12, 2026, the Supreme Court issued an Order administratively suspending 1,113 Pennsylvania attorneys who failed to file their 2026–2027 annual registration form and pay the required fees. Any attorney who has not met those obligations by the effective date of the Order will lose the privilege of practicing law in this Commonwealth. The Board and I urge every affected attorney to address the matter without further delay. Membership in the Pennsylvania bar is both a privilege and a responsibility.

As a new academic year begins, I also wish Pennsylvania’s law students, faculty, and staff every success. The Disciplinary Board values its partnerships with our law schools. In recent years, Board Members, Chief Disciplinary Counsel Thomas J. Farrell, and members of the Board’s staff have visited area law schools to discuss lawyers’ ethical obligations and the challenges that new lawyers may encounter. Board staff also communicate regularly with deans of students as we work together to prepare the next generation of lawyers for ethical practice.

The Board must discipline members of the legal profession when circumstances require it. But discipline alone does not fulfill our overarching responsibility to the public or the profession. Ethics education, support for lawyer well-being, and other efforts to prevent misconduct remain essential to both.

Be well,

Shohin H. Vance
Board Chair

Annual Attorney Registration
 
2026-2027 Registration Past Due
 
By Order dated August 12, 2026, the Supreme Court administratively suspended 1,113 attorneys who have not yet completed their annual registration. The order is effective in thirty days, allowing these attorneys the opportunity to complete annual registration on or before September 10, 2026 to avoid transfer to administrative suspension.

The current license status of a Pennsylvania attorney can be found on the Board’s website at padisciplinaryboard.org/for-the-public/find-attorney
Discipline Imposed
Reinstatements

July 2026
A pie chart shows that, in July 2026, the following types of reinstatements were ordered: six from inactive, one from retired, one from suspension, and one from disbarment.
From Inactive
Sara Burns Fobian
Sara Bess Gruen
Anita Jandu
Kelly L. Jerabek
Elene Mountis Moran
Saam Youssefi-Rad
 
From Retired
Stephen Gerard Maliszewski
 




 
From Suspension
Brian Dooley Kent
From Disbarment
David Tevis Shulick 
 
Note: The above-listed granted reinstatement matters reflect only those granted by Supreme Court Order. An attorney listed as reinstatement granted, but whose current license status does not reflect reinstatement, has yet to submit the fees necessary to finalize reinstatement.
Rules


Pennsylvania Supreme Court Clarifies Rule on Multijurisdictional Practice from PA
 
By Order dated July 16, 2026, the Supreme Court of Pennsylvania, acting on a recommendation of the Disciplinary Board, adopted new language to Comment 4 to Rule 5.5 of the Rules of Professional Conduct, clarifying the responsibilities of lawyers who practice remotely in other jurisdictions while physically located in PA.
 
The comment states the intent of the change: “With the rise of advanced communications technology, and in the advent of the 2020 global pandemic, the legal profession confronted the issue of remote legal practice and the unauthorized practice of law, in the context of Rule 5.5(b)(1).”
 
First, the comment notes that a lawyer who is not admitted to practice in PA may remotely practice the law of the jurisdictions in which the lawyer is licensed while physically present in PA. The lawyer must not hold themself out as being admitted to practice in PA or provide or offer to provide legal services in PA. Such remote practice is not considered to be “systematic and continuous presence in this jurisdiction” for the purposes of Rule 5.5(b)(1).
 
Second, a lawyer authorized to practice law in PA may remotely do so while the lawyer is physically outside of PA, provided the lawyer is not prohibited from doing so in the jurisdiction where the lawyer is physically present.
 
The amendment of this comment is effective immediately.
Upcoming Public Proceedings
 
We encourage you to observe our public disciplinary and reinstatement hearings, oral arguments, and public reprimands on the Board’s YouTube channel. You can also view “Upcoming Public Proceedings” at the bottom of the Board’s home page.

Scheduled proceedings begin at 9:30 am unless otherwise noted.

This chart lists all currently-scheduled upcoming public proceedings. For a full list, please visit https://www.padisciplinaryboard.org/cases/upcoming-public-proceedings.
Resources for Law Students


Law students! The Disciplinary Board offers free resources to help law students prepare and stay ahead of the curve. Learn Pennsylvania's Rules of Professional Conduct, understand expectations, support mental health and well-being, and stay informed about cases and precedents. Visit padboard.org and follow the Board on social media.

The Board has also created a resource guide which includes Rules Books, an introduction to the Board’s mission and functions, well-being, pro bono work, and more – tailored to the unique experiences and needs of law students.
 
The image features the text, "Ethical law practice is empowering," followed by, "The Disciplinary Board of the Supreme Court of Pennsylvania offers free resources to help you prepare and stay ahead of the curve. Learn the Rules of Professional Conduct, understand expectations, support your mental health and well-being, and stay informed about cases and precedents." Below is a photo of a professionally dressed young woman looking directly at the viewer. To his right is a QR code leading to law student FAQs on the Board website. To the far right is the URL for the Board's website, a shortened URL to subscribe to the Board's newsletter, and an icon with the Board's LinkedIn handle. The Board logo is displayed in the top lefthand corner.
Articles of Interest


Lawyer Agrees to Suspension for Sexual Involvements
 
A Pennsylvania lawyer agreed to a three-year suspension of his law license after admitting to sexual involvement with a client and a woman he encountered in the course of his practice.
 
Timothy Reitz of Lycoming County entered into a Joint Petition for Discipline on Consent with Disciplinary Counsel in which he admitted that he had engaged in sexual interactions with the two women.
 
One was a client whom he was appointed to represent in three dependency matters involving her children. Reitz, who did not have an office and saw clients at various locations, first met the client when he attended a meeting at a shelter where she was staying. The client told him she had been a victim of domestic abuse, and he knew she was vulnerable. They began exchanging text messages with erotic content and ultimately engaged in sex. Reitz did not have a romantic or sexual relationship with the client before undertaking the representation. He acknowledged that this conduct violated RPC 1.7(a)(2), concurrent conflict of interest, and RPC 1.8(j) which prohibits a lawyer to engage in sexual conduct with a client, including communications of a sexual nature if the lawyer and client did not have a prior consensual relationship.
 
The second case arose out of a custody matter in which Reitz was appointed as guardian ad litem (GAL) for the children. He engaged in a series of flirtatious and inappropriate text messages with the children’s mother. He was aware that, as GAL, he was in a position to make recommendations that would affect the outcome of the case and even mentioned his role as GAL in messages to the mother. The mother disclosed this conduct to her lawyer who notified Reitz of her concerns. He then moved to withdraw as GAL which the court ordered fifteen days later. Reitz admitted that this conduct violated RPC 1.7(a)(2).
 
The parties agreed that mitigating factors were present, including Reitz’s acknowledgement of wrongdoing, remorse, and apologies. As an aggravating factor, the Joint Petition noted that he misused a position of trust to take advantage of a vulnerable client and an interested party, both of whom depended on his representation in serious legal matters.
 
After a review of the caselaw, the parties agreed that the appropriate discipline is a suspension for three years, which will require Reitz to file a Petition for Reinstatement and prove his fitness, should he seek to return to active status. A three-member panel of the Board approved this recommendation, and the three-year suspension was imposed by the Supreme Court in an Order dated July 6, 2026.
 

Florida Lawyers Suspended After Settling Dead Client’s Cases
 
A pair of Florida lawyers were suspended after admitting that they settled two cases after their client had died, signing his name to a settlement agreement and receiving the settlement funds into their trust account.
 
Lee Sarkin of Boca Raton, Florida and Drew Mark Levitt of Ocean Ridge, Florida pled guilty to the disciplinary charges. The record showed that they represented frequent litigant David Poschmann in numerous Americans with Disabilities Act (ADA) cases. In November 2021, they reached a settlement in a case Poschmann had filed against a condo association. Unable to reach Poschmann, they signed his name to the settlement agreement with an ink signature. The settlement proceeds were paid into Levitt's trust account in accordance with the settlement agreement.
 
A month later, they learned that Poschmann had died a few days before the settlement was reached. They did not inform the defendants’ counsel or the court of this fact.
 
Approximately a year and a half later, the defendant’s counsel learned that Poschmann had died before Levitt and Sarkin settled the case and filed a motion to set aside the dismissal and vacate the settlement. The court found that because the settlement was reached after Poschmann’s death, Levitt and Sarkin no longer had authority to act on Poschmann’s behalf, that the settlement was unauthorized, and that their conduct constituted a fraud on the court. The settlement was vacated, Levitt and Sarkin stipulated to a fee award of $11,287.40 in favor of the defendant, and the matter was referred to the grievance committee of the Federal bar. They admitted that this conduct violated Rules Regulating the Florida Bar: 4-1.3 Diligence, 4-3.3(a)(1) Candor Toward the Tribunal, 4-3.4(a) Fairness to Opposing Party and Counsel, and 4-8.4(c) Misconduct. On that committee’s recommendation, the attorneys were suspended from the Federal bar for nine months in addition to other sanctions.
 
In a second case, the attorneys admitted to an almost identical pattern in litigation against a revocable trust. In that case, Levitt and Sarkin returned the settlement proceeds without intervention of the court.
 
Based on the same facts, the Supreme Court of Florida suspended Levitt and Sarkin for a period of three years.
 

AI Roundup: It’s Everywhere Now
 
We really don’t want this newsletter to become the Artificial Intelligence in Legal Practice Review, but the stories keep coming.
 
It seems like every month we are seeing stories about lawyers who were dressed down by courts for filing documents or briefs containing bad information generated by AI resources.

The 11th U.S. Circuit Court of Appeals reprimanded a Florida lawyer for filing briefs that included “fake and hallucinated” artificial intelligence-generated information. This might not be a story these days except that the lawyer, Anthony Sabatini, a current county commissioner and former member of the Florida House of Representatives, cited a fictitious case supposedly decided by the 11th Circuit Court itself. The Court noted, “Whatever the merits of artificial intelligence, it is no substitute for actual intelligence.”
 
Misuse of AI resources is not limited to busy private practitioners. In the Michigan immigration case of Izzeddin Ahmed Abdulgahffar Daghra, the U.S. District Court for the Western District of Michigan criticized an Assistant U.S. Attorney for citing a nonexistent case evidently generated by AI. The judge wrote, “It should be obvious that any attorney who uses AI must scrupulously review its work product to ensure that the cited cases exist and that the citations accurately and fairly represent the underlying case law.”
 
It gets worse. In the case of Withers v. City of Aberdeen, a Mississippi Federal court found that not one, not two, but four attorneys on both sides had submitted briefs containing hallucinated cases. Two were out-of-state counsel admitted pro hac vice, and two were local counsel for the respective parties. The court’s level of unhappiness was reflected in the sanctions order. One out-of-state attorney had her pro hac vice admissions revoked, was barred from appearing before the court for two years, fined $2,500, and ordered to take a CLE course on artificial intelligence with an ethics component. The other was revoked, barred from appearing for two years, and fined $3,500. The two local attorneys were disqualified from appearing in the case and fined $1,000 each. Disciplinary referrals all around.
 
Such stories have made many law firms and lawyers reluctant to invest heavily in AI tools. Alternative legal services provider Axiom reports that a survey of 528 in-house legal leaders from six countries found that 83% of legal teams cannot determine whether their spending on AI is paying off. However, all the respondents said their legal teams plan to raise their budgets for AI, and 98% said their teams would benefit from outside guidance on AI. Fear of falling behind the curve on new technology motivated many of these firms.
 
Whatever reservations more experienced practitioners may have, younger attorneys seem to be embracing the technology at a faster rate. A survey by the NALP Foundation (National Association for Law Placement) found that 48% of 2022 law school graduates use AI tools “frequently” or “occasionally” as either an essential part of their daily work or for specific tasks or projects, and another 30% reported they “rarely” do so. Only 22% reported they “never” use AI tools in their current work.
 
How can lawyers avoid the risk of citing hallucinated authorities? The ABA Journal asked several IT-savvy lawyers and received a number of helpful strategies, including:
  • Ask it some follow-up questions. Challenge it about the information it provides. It may admit it was wrong.
  • Use AI in the middle of a project to see if something was missed along the way. 
  • Read every case a colleague on the other side has cited and, if they have cited a hallucinated case or an inaccurate quotation, call and ask them to correct the submission. Otherwise, one may be responsible for it as well.
  • Change the prompt or use the same prompt more than once to see if the results change. 
  • Don't use general-purpose chatbots for caselaw research. Use tools grounded in actual legal databases.
But the advice most of the experts give is the same: read the cases. All of them. One’s own and one’s opponent’s. As the court said, “Artificial intelligence . . . is no substitute for actual intelligence.”
 
Whatever reservations attorneys have about AI technology, it appears that clients view it as a valuable tool in finding attorneys. The AI Legal Consumer Report 2026, produced by LLM Listed, found that 96% of 871 Americans who hired a lawyer in the past six months, or were planning to, said they trust AI platforms to recommend a good law firm; 84% said they wouldn’t trust a firm that did not appear in AI results; and 74% would use AI to vet a firm's reputation before hiring.
 

Beekeeper Sentenced to Six Months for Apian Attack
 
A Massachusetts court sentenced a beekeeper to six months in prison for her conviction on charges of releasing her bees to attack deputies who were trying to evict her friend. Rebecca Woods was charged with seven felony counts, including assault with a deadly weapon, after she drove up in a truck with several beehives and opened them up while deputies were attempting to serve eviction papers on her eighty-year-old friend who was undergoing cancer treatments. Several officers were stung and one was hospitalized.
 
A jury acquitted her of all the felony counts but found her guilty of four misdemeanor counts of assault and two counts of reckless assault.
 
Woods probably didn’t help herself by claiming she only released her truckload of hives to allow the bees to enjoy the “lovely, flowering landscape.” At trial, though, she admitted she was trying to stop the eviction.
 
Although her sentence was for six months, she will only serve two weeks as she has been held without bail since being extradited to Massachusetts after fleeing to Tennessee. Her lawyer said that Woods, an advocate for the homeless in addition to her beekeeping avocation, was driven by a desire to protect people from predatory lenders who charged extortionate rates on non-mainstream mortgages. Despite her efforts, her friend was evicted.
 
In a sad note, Woods asserted that nearly a thousand of her bees lost their lives in her ill-fated rescue mission. Some died of the stings, and many of them were crushed when several hives toppled as she wrestled with deputies trying to arrest her.

Attorney Well-Being


Free Well-Being Resources for Pennsylvania Law Students

Did you know? Law students can register for free, virtual, confidential support sessions with Lawyers Concerned for Lawyers of Pennsylvania (LCL). Law students can schedule a thirty-minute session with Laurie Besden, Executive Director of LCL, during their school’s designated day and times. For a school's registration link, please see the respective Dean of Students or contact LCL at info@lclpa.org.

Learn about this and other resources tailored to the experience of law students at lclpa.org/help-for-law-students.
 



Explore the Disciplinary Board's Lawyer Well-Being Webpage

The Disciplinary Board's "Lawyer Well-Being" webpage connects Pennsylvania attorneys with pertinent resources, articles, events, and CLE opportunities to better understand and support their mental health and well-being. To access the Board’s “Lawyer Well-Being” page, visit padisciplinaryboard.org/for-attorneys/well-being.
 

On the left side of the graphic is the large text "Lawyer Well-Being." Below is the text, "Connect to available resources to better understand and support mental health and well-being as they related to the legal profession. On the right side of the graphic, a man, professionally dressed, smiles next to the text "Digital resources, informative articles, upcoming events, CLE opportunities."
 



This graphic is an advertisement for Lawyers Concerned for Lawyers of Pennsylvania, a free and confidential lawyers assistance program. The graphic includes the organization's logo, website (lclpa.org), and the number for its confidential, 24-hour hotline: 1-888-999-1941.

Lawyers Concerned for Lawyers is a confidential assistance program for the Pennsylvania legal community and their family members. LCL may not report information about a subject attorney back to the Disciplinary Board.
 

Confidential 24/7 Helpline: 1-888-999-1941

The Supreme Court of Pennsylvania adopted amendments to the Pennsylvania Rules of Disciplinary Enforcement (Pa.R.D.E.) relating to confidentiality of proceedings, providing for three exceptions to the requirement of confidentiality under Pa.R.D.E. 402(d). Included in these exceptions is the allowance for Disciplinary Counsel to make a referral of an attorney to Lawyers Concerned for Lawyers of Pennsylvania (LCL) and share information as part of the referral. However, it is crucial to note that LCL may not report information about a subject attorney back to the Disciplinary Board. LCL is a confidential assistance program for the Pennsylvania legal community and their family members.

Around the Court

This is an image of commemorative Pennsylvania Courts logo honoring the United States' 250th anniversary. A border of red stripes and blue with the "1776 . America 250 . 2026" surrounds the Courts' modern logo.


Pennsylvania Courts Bring Awareness to Traffic Citations in School Zones through New Infographic

As students and teachers return to classrooms for a new school year, the Unified Judicial System (UJS) recently published a new infographic bringing awareness to traffic citation in school zones. Over the past five years, from 2021 through 2025, over 25,000 drivers in Pennsylvania have been cited for school zone violations. Such violations include speeding in a school zone and overtaking or illegally passing a school bus.

UJS wants to remind PA drivers to "slow down in school zones, stop for school buses, and stay alert to help ensure the safety of our students."

Read the full press release and access the infographic here on the UJS website.



 


 

The lefthand side of the image displays a photo of the Chief Justice of Pennsylvania, Hon. Debra Todd sitting in the Supreme Court’s chamber. To the right is the text: “No place is more deeply connected to our nation’s founding than Pennsylvania. For 250 years, our courts have played a vital role in protecting the rights and freedoms envisioned by our founders. While the challenges facing out judiciary have evolved, our mission remains constant: to uphold the Constitution and apply it fairly.” Below is the text, “Debra Todd, Chief Justice of Pennsylvania.”
via PA Courts on Facebook and X

From the Pennsylvania Bar Association


This is the logo of the Pennsylvania Bar Association. It includes the motto, "Your Other Partner."


November 12th: PBA’s Committees and Sections by Day and NightOUT by Night
 
Save the date for Thursday, November 12th and plan to spend the day with the Pennsylvania Bar Association in Harrisburg.
 
Connect with colleagues, participate in the work of committees and sections, and help to shape the conversations and initiatives that move the PBA forward during Committee/Section Day.
 
Then, when the meetings wrap up, stay for NightOUT, the PA Bar Foundation’s annual evening of fun and fundraising at the Harrisburg Hilton. Friends, family members, PBA supporters, and new, soon-to-be friends are invited for a great evening.
 
This year, Felix and Fingers will take the stage for a fast-paced, interactive dueling pianos show where audience requests drive the music. Expect plenty of laughs, great music, and a room full of PBA friends — all while supporting the PA Bar Foundation.
 
Thursday, November 12th
Committee/Section Day & Pennsylvania Bar Foundation NightOUT
Harrisburg Hilton
 
Registration details are coming soon. Check PBA’s social media pages for more details.
 
Not a PBA Member? Join a statewide network of attorneys committed to professional excellence, connection, and advocacy. The Pennsylvania Bar Association (PBA) supports members’ practice with cutting-edge CLEs, timely legal resources, leadership opportunities, and a strong collective voice for the profession.

The image is a save the date for the Pennsylvania Bar Foundation's NightOUT. Text includes: "Thursday, November 12th. Harrisburg Hilton After the PBA Committee/Section Day. Bring your energy to NightOUT! Felix and Fingers will deliver a fast paced, interactive dueling pianos show where your requests drive the music. Expect big laughs, bigger applause, and a room buzzing as we raise funds for the Pennsylvania Bar Foundation. Registration will open soon." To the right is a photograph of a man playing the piano and sitting next to a microphone. The Pennsylvania Bar Foundation logo is displayed at the bottom lefthand corner.
 


Please note that the Disciplinary Board of the Supreme Court of Pennsylvania and the Pennsylvania Bar Association (PBA) are separate organizations. For more information about PBA, visit pabar.org or follow on Facebook, Instagram, and LinkedIn.
We Want To Hear From You...
 
We are always on the lookout for stories of interest relating to legal ethics, new issues in the practice of law, lawyer wellness, and funny or just plain weird stories about the legal profession. If you come across something you think might be enlightening, educational, or entertaining to our readers or social media followers, pass it along. If you are our original source, there may be a hat tip in it for you.
 
 
 

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