MI Bar Attorney Discipline
Thursday, April 16, 2026
Robert A. Canner Disbarred, $16,549 Restitution
The Michigan Attorney Discipline Board ordered disbarment of attorney Robert A. Canner (P 11572) effective December 12, 2025, following findings that he intentionally misappropriated client funds, failed to disburse settlement funds, and commingled non-client funds with client funds in his IOLTA account. The panel ordered restitution totaling $16,549.10 and assessed costs of $2,485.44.
Christopher J. Woolf Disbarred Effective August 7, 2025
The Michigan Attorney Discipline Board disbarred attorney Christopher J. Woolf (P79877) effective August 7, 2025, following felony convictions including child sexually abusive activity and accosting a child for immoral purposes in Ingham County Circuit Court. A hearing panel found professional misconduct under MCR 9.104(5) and MRPC 8.4(b), ordering disbarment with total costs of $2,057.08 assessed against respondent.
Immigration Representation Misconduct, Board Affirms Summary Disposition Denial
The Michigan Attorney Discipline Board granted interlocutory review and affirmed a hearing panel's denial of partial summary disposition in Case No. 25-65-GA. The Board held that Michigan Rules of Professional Conduct apply to attorney Richard Kessler's conduct in representing a client in immigration matters before USCIS and EOIR, rejecting his argument that only federal tribunal standards applied under MRPC 8.5(b). This establishes precedent on disciplinary jurisdiction over Michigan attorneys practicing before federal immigration agencies.
Robert Pasionek - Stay and License Restoration Denied
The Michigan Attorney Discipline Board denied respondent Robert Pasionek's motion for an immediate stay of discipline and motion for immediate restoration of his law license. The Board found that Pasionek failed to establish good cause for the granting of that relief. The underlying suspension arose from Pasionek's failure to appear at an in-person hearing on March 12, 2026, claiming physical incapacity. A subsequent order of disbarment was issued effective April 11, 2026. Substantive issues including due process arguments will be considered in the pending review proceeding.
Richard Kessler Disciplinary Amended Order Affirmed
The Michigan Attorney Discipline Board granted respondent Richard Kessler's petition for interlocutory review and affirmed the hearing panel's order denying his motion for partial summary disposition. The Board ruled that Michigan Rules of Professional Conduct apply to attorney conduct in immigration matters pending before USCIS and EOIR, rejecting the argument that only federal immigration practice rules apply. This establishes that Michigan attorneys practicing before federal immigration tribunals remain subject to MRPC.
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