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Sean K. Hornbeck v. Board of Professional Responsibility Of The Supreme Court of Tennessee

Tenn.February 16, 2018No. M2016-01793-SC-R3-BPCited 13 times
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Case Details

Judge(s)
Kirby, Bivins, Clark, Lee, Roger
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

Breach of Contract

Outcome

The Tennessee Supreme Court affirmed the disbarring of attorney Sean Hornbeck for multiple acts of professional misconduct including conversion of client funds, falsifying documents, and fraud, and rejected his argument that the disbarment should be made retroactive to his temporary suspension.

Excerpt

In this attorney disciplinary appeal, upon petition by the Tennessee Board of Professional Responsibility, this Court ordered the temporary suspension of the attorney from the practice of law based on the threat of substantial harm he posed to the public. For a time, the attorney was placed on disability status later he was reinstated to suspended status. Subsequently, after an evidentiary hearing, a hearing panel found multiple acts of professional misconduct, including knowing conversion of client funds with substantial injury to clients, submitting false testimony and falsified documents in court proceedings, engaging in the unauthorized practice of law, violating Supreme Court orders, and defrauding clients. The hearing panel determined that the attorney should be disbarred. On appeal to the chancery court, the attorney argued inter alia that the disbarment should be made retroactive to the date of his temporary suspension. The chancery court affirmed the decision of the hearing panel. On appeal to this Court, the attorney does not question the disbarment but argues that it would be arbitrary and capricious not to make his disbarment retroactive to the date of his temporary suspension, in order to advance the date on which he may apply for reinstatement of his law license. We disagree. In contrast to suspension, which contemplates that the lawyer will return to law practice, disbarment is not a temporary status. Disbarment is a termination of the individual's license to practice law in Tennessee. Therefore, we decline to make the effective date of the attorney's disbarment retroactive to the date of his temporary suspension. Accordingly, we affirm.

What This Ruling Means

**What happened:** Sean Hornbeck, a Tennessee attorney, was accused of serious professional misconduct while working as a lawyer. The Tennessee Board of Professional Responsibility investigated him for multiple violations, including stealing client money, creating fake documents, and committing fraud. Initially, the court temporarily suspended him from practicing law because he posed a threat to the public. After a full hearing examining the evidence, a panel found he had indeed committed these serious offenses. **What the court decided:** The Tennessee Supreme Court permanently disbarred Hornbeck, meaning he can never practice law again in Tennessee. The court rejected his request to make the disbarment retroactive to when he was first suspended. This was a complete victory for the Board of Professional Responsibility. **Why this matters for workers:** This case shows that professional licensing boards take misconduct seriously and will remove bad actors from their professions. For workers in licensed professions (lawyers, doctors, accountants, etc.), this demonstrates that regulatory boards have real power to investigate complaints and impose severe penalties, including permanent removal from the profession, when professionals violate ethical standards or commit crimes against clients or the public.

This summary was generated to explain the ruling in plain English and is not legal advice.

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