Disciplinary Counsel v. Black

2025 Ohio 1790, 178 Ohio St. 3d 647
CourtOhio Supreme Court
DecidedMay 22, 2025
Docket2024-1725
StatusPublished

This text of 2025 Ohio 1790 (Disciplinary Counsel v. Black) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Disciplinary Counsel v. Black, 2025 Ohio 1790, 178 Ohio St. 3d 647 (Ohio 2025).

Opinion

[This opinion has been published in Ohio Official Reports at 178 Ohio St.3d 647.]

DISCIPLINARY COUNSEL v. BLACK. [Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as Disciplinary Counsel v. Black, 2025-Ohio-1790.] Attorneys—Misconduct—Violation of the Rules of Professional Conduct by engaging in conduct that adversely reflects on a lawyer’s fitness to practice law—Two-year suspension with six months conditionally stayed. (No. 2024-1725—Submitted February 11, 2025—Decided May 22, 2025.) ON CERTIFIED REPORT by the Board of Professional Conduct of the Supreme Court, No. 2024-012. __________________ The per curiam opinion below was joined by KENNEDY, C.J., and FISCHER, DEWINE, DETERS, HAWKINS, and SHANAHAN, JJ. BRUNNER, J., did not participate.

Per Curiam. {¶ 1} Respondent, Ryan Richard Black, of Columbus, Ohio, Attorney Registration No. 0097679, was admitted to the practice of law in Ohio in 2018. Black was elected Hocking County prosecutor in November 2020 and took office in January 2021. {¶ 2} In an April 2024 complaint, relator, disciplinary counsel, charged Black with three counts of misconduct arising from acts that occurred during his tenure as Hocking County prosecutor. The first count alleged that Black engaged in inappropriate sexual conduct with two employees of the prosecutor’s office. The other two counts alleged that Black engaged in an inappropriate sexual relationship with a client of the prosecutor’s office and that he inappropriately used his public office by threatening to arrest the Hocking County information-technology director SUPREME COURT OF OHIO

for obstructing official business after the director refused to stop what he was doing to fix a computer issue for the prosecutor’s office. {¶ 3} The parties entered stipulations of fact, and Black agreed that his inappropriate sexual conduct with the two employees violated Prof.Cond.R. 8.4(h) (prohibiting a lawyer from engaging in conduct that adversely reflects on the lawyer’s fitness to practice law). The parties also stipulated to aggravating and mitigating factors and submitted 14 stipulated exhibits. In addition, they agreed that the appropriate sanction for the stipulated misconduct is a two-year suspension with six months stayed on conditions primarily related to Black’s mental health. {¶ 4} Black and one other witness testified at a hearing before a three- member panel of the Board of Professional Conduct. Following the hearing, the panel unanimously voted to dismiss the second and third counts of relator’s complaint. Based on the stipulations and evidence presented at the hearing, the panel found that Black’s inappropriate sexual conduct with the two employees adversely reflected on his fitness to practice law. The panel recommended that he be suspended from the practice of law for two years, with six months conditionally stayed, and that certain conditions be placed on his reinstatement to the practice. The board adopted the panel’s findings of fact, conclusions of law, and recommended sanction. No objections have been filed. {¶ 5} After reviewing the record and our relevant precedent, we adopt the board’s finding of misconduct and its recommended sanction. FINDINGS OF FACT AND MISCONDUCT General Office Conduct {¶ 6} After taking office as the Hocking County prosecutor in January 2021, Black created an unprofessional work environment through his inappropriate language and behavior. His use of obscenities and inappropriate sexual comments made staff members uncomfortable. For example, while interviewing two

2 January Term, 2025

candidates for jobs in the prosecutor’s office, Black asked whether they would mind the use of the word “fuck” in the office or receiving “dogshit pay.” {¶ 7} Black’s office behavior was erratic. He frequently engaged in screaming outbursts and refused to speak to staff members for several days at a time. At least one employee was frightened of him and avoided being around him. Black stipulated that if A.T., who worked as an assistant prosecutor in his office beginning in November 2022, had been called as a witness, she would have testified that Black “disparaged and exploited employees.” {¶ 8} In A.T.’s affidavit, a stipulated exhibit in this case, she avers, “Throughout my time at the prosecutor’s office, I have preferred to work outside of regular work hours or work from home whenever possible to avoid the chaos.” She further averred that she “came in only as necessary for [her] court hearings if [Black] was in the office.” She also stated that she “built a wall of bookshelves” around her workspace in an attempt to “hide away” and “just do [her] job.” {¶ 9} Although Black was not charged with any misconduct arising from these facts, they nonetheless offer some insight into Black’s leadership and the office culture in which the alleged misconduct occurred. Inappropriate Sexual Conduct Involving S.R. {¶ 10} S.R. worked as a Hocking County assistant prosecutor from January through November 2021. During S.R.’s employment, Black, who was S.R.’s supervisor, made inappropriate sexual comments to S.R. and to others about S.R. On one occasion, in front of a colleague at work in March 2021, Black told S.R. that her dress made him want her to “wrap [her] legs around [his] face until [she] orgasmed,” then did an impression of himself performing oral sex. {¶ 11} On July 20, Black sent S.R. a text message containing a photograph of himself shirtless because he was looking for compliments. He later added: “[T]hank you for being complimentary. It certainly makes my day and definitely keeps me motivated to keep working lol. Means a lot.” The next day, Black and

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S.R. attended a party. The host asked S.R. whether she wanted to feed his pet donkey a carrot. Black interjected with a sexual innuendo, stating that he had a “carrot” that he would like to feed S.R. He later sent S.R. a text message containing four carrot emojis. {¶ 12} Black and S.R. also exchanged text messages concerning Black’s plan to seek a salary increase on S.R.’s behalf. Black told S.R. that he would try to increase her salary “to the low- to mid-70s,” before stating, “Now, that said, I’d give ya 200k if it meant I got flattered all the time .” He later added: “Besides I don’t want some fancy county going and offering you more money for less stress and stealing you away! I’d only be able to counter that other counties probably have less guns and carrots. . . And abs you can occasionally belly rub when you’re bored or feeling down hahahaha.” (Punctuation in original.) By the end of July, Black texted S.R. three more photographs of himself shirtless. {¶ 13} S.R. left her employment in the prosecutor’s office in November 2021. Inappropriate Sexual Conduct Involving K.V. {¶ 14} In April 2021, Black hired K.V. to work as a victim advocate in the prosecutor’s office. He was her supervisor. {¶ 15} K.V. discovered that she was unexpectedly pregnant in early 2022. When she told Black about her pregnancy, he joked about helping her terminate it. Later, after hearing that she had suffered a miscarriage, he joked about that as well. {¶ 16} In May 2022, Black began to send K.V. inappropriate text messages. On one occasion, K.V. sent Black a text saying that she had bought new clothes and was feeling self-conscious about wearing them; he responded, “If you look dashing and I grope you, don’t sue me lmao.” {¶ 17} Among numerous text messages in June, Black sent K.V. a link to a sexually explicit song titled “Pussy” by the German band Rammstein as well as

4 January Term, 2025

images of two cats cuddling. K.V. responded to one of the images with a text stating, “Cats making out this time[,] aye? .” Black replied, “Lol

throwing out hints .” In another text conversation, K.V. stated that she was going to a police department to discuss a protection order.

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Bluebook (online)
2025 Ohio 1790, 178 Ohio St. 3d 647, Counsel Stack Legal Research, https://law.counselstack.com/opinion/disciplinary-counsel-v-black-ohio-2025.