[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as 

Trumbull Cty. Bar Assn. v. Bodor, Slip Opinion No. 2015-Ohio-3634.] 

NOTICE

This slip opinion is subject to formal revision before it is published in 

an advance sheet of the Ohio Official Reports. Readers are requested 

to promptly notify the Reporter of Decisions, Supreme Court of Ohio, 

65 South Front Street, Columbus, Ohio 43215, of any typographical or 

other formal errors in the opinion, in order that corrections may be 

made before the opinion is published. 

SLIP OPINION NO. 2015-OHIO-3634

TRUMBULL COUNTY BAR ASSOCIATION v. BODOR.

[Until this opinion appears in the Ohio Official Reports advance sheets, it 

may be cited as Trumbull Cty. Bar Assn. v. Bodor, Slip Opinion No. 

2015-Ohio-3634.] 

Attorneys—Misconduct—Failure to promptly refund unearned fee upon 

withdrawal from employment—Public reprimand. 

(No. 2015-0276—Submitted April 14, 2015—Decided September 9, 2015.) 

ON CERTIFIED REPORT by the Board of Professional Conduct 

of the Supreme Court, No. 2014-048. 

_______________________ 

Per Curiam.

{¶ 1} Respondent, Csaba Andrew Bodor of Warren, Ohio, Attorney 

Registration No. 0025613, was admitted to the practice of law in Ohio in 1972. 

On July 2, 2014, relator, Trumbull County Bar Association, charged Bodor with 

violating four Rules of Professional Conduct in his handling of a client’s fee. 

Bodor and relator subsequently submitted joint stipulations of fact, a single 
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violation, and aggravating and mitigating factors, and they recommended that 

Bodor be publicly reprimanded for his misconduct. Relator agreed to withdraw 

the remaining alleged violations. A panel of the Board of Professional Conduct 

unanimously accepted the parties’ stipulations and recommended sanction, and 

the board adopted the panel report in its entirety. 

{¶ 2} We agree with the recommendation of the board, adopt the parties’ 

stipulations of fact and misconduct, and publicly reprimand Bodor. 

Misconduct 

{¶ 3} In October 2010, Howard Baldwin retained Bodor to file a Chapter 

13 bankruptcy on his behalf. He signed a fee agreement agreeing to pay $3,000 

for Bodor’s services—the standard fee set by the relevant bankruptcy court for a 

Chapter 13 filing at that time. Baldwin paid $250 a month from October 2010 

through March 2011, for a total of $1,500, and Bodor deposited those payments in 

his client trust account. 

{¶ 4} Baldwin contacted Bodor and others in Bodor’s office on numerous 

occasions to provide information relevant to his bankruptcy, but he did not 

provide all of the information necessary to prepare and file the bankruptcy 

petition. Baldwin scheduled a time to meet with Bodor on March 14, 2012, to 

clarify what was required to move forward with his bankruptcy. But on March 9, 

2012, Bodor sent Baldwin a letter terminating his representation and canceling 

that appointment. Bodor failed to provide Baldwin with an accounting of the 

$1,500 he had paid and failed to promptly refund any unearned portion of the fee. 

When Bodor did not respond to Baldwin’s request for a refund, Baldwin filed a 

grievance with relator. Two months after Bodor terminated the representation, he 

sent Baldwin a $550 refund. He provided an accounting to relator during its 

investigation. 

{¶ 5} The parties stipulated and the board found that Bodor’s conduct 

violated Prof.Cond.R. 1.16(e) (requiring a lawyer to promptly refund any 
January Term, 2015 

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unearned fee upon the lawyer’s withdrawal from employment). Relator agreed to 

withdraw the remaining alleged violations. 

Sanction 

{¶ 6} When imposing sanctions for attorney misconduct, we consider 

relevant factors, including the ethical duties that the lawyer violated and the 

sanctions imposed in similar cases. Stark Cty. Bar Assn. v. Buttacavoli, 96 Ohio 

St.3d 424, 2002-Ohio-4743, 775 N.E.2d 818, ¶ 16. In making a final 

determination, we also weigh evidence of the aggravating and mitigating factors 

listed in Gov.Bar R. V(13). 

{¶ 7} The parties stipulated, and the board agreed, that the relevant 

mitigating factors include the absence of a prior disciplinary record, the absence 

of a dishonest or selfish motive, Bodor’s effort to rectify the consequences of his 

misconduct and his reimbursement of unearned legal fees and expenses, his full 

and free disclosure to the board and his cooperative attitude toward the 

disciplinary proceedings, and evidence of his good character and reputation apart 

from the charged misconduct. See Gov.Bar R. V(13)(C)(1) through (5). Other 

than the two-month delay in obtaining the unearned portion of his retainer, 

Baldwin suffered no harm as a result of Bodor’s conduct, and none of the 

aggravating factors set forth in Gov.Bar R. V(13)(B) are present. 

{¶ 8} Based upon Bodor’s misconduct and the presence of significant 

mitigating factors, the parties agreed that the appropriate sanction is a public 

reprimand. The board agreed and, in support of the recommendation, cited Lake 

Cty. Bar Assn. v. Kubyn, 121 Ohio St.3d 321, 2009-Ohio-1154, 903 N.E.2d 1215. 

In that case, we publicly reprimanded Kubyn for failing to promptly return 

unearned fees and failing to take reasonable steps to protect his client’s interest 

after the client had discharged him. There were no aggravating factors and the 

mitigating factors were similar to those found here. 
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{¶ 9} We adopt the board’s findings of fact, find that Bodor’s conduct 

violated Prof.Cond.R. 1.16(e), and dismiss the remaining allegations contained in 

the complaint. Because we imposed a public reprimand for comparable 

misconduct in Kubyn, we agree that a public reprimand is the appropriate sanction 

here. 

{¶ 10} Accordingly, Csaba Andrew Bodor is hereby publicly reprimanded 

for his misconduct. Costs are taxed to Bodor. 

Judgment accordingly. 

O’CONNOR, C.J., and PFEIFER, O’DONNELL, LANZINGER, KENNEDY,

FRENCH, and O’NEILL, JJ., concur. 

_________________ 

Randil J. Rudloff, for relator. 

Thomas J. Wilson, for respondent. 

_________________