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

re Application of Heckman, Slip Opinion No. 2021-Ohio-2474.] 

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. 2021-OHIO-2474

IN RE APPLICATION OF HECKMAN.

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

may be cited as In re Application of Heckman, Slip Opinion No. 

2021-Ohio-2474.] 

Attorneys—Character and fitness—Applications to register as candidate for 

admission to practice of law—Past criminal conduct—Lack of candor—

Application disapproved and applicant permitted to reapply for admission 

at a later date, on conditions.

(No. 2021-0256—Submitted May 12, 2021—Decided July 22, 2021.) 

ON REPORT by the Board of Commissioners on Character and Fitness of the 

Supreme Court, No. 776. 

_______________________ 

Per Curiam.

{¶ 1} Applicant, William Michael Heckman, of Montague, Michigan, is a

2015 graduate of the Western Michigan University Cooley Law School. He applied 

to register as a candidate for admission to the practice of law in Ohio in July 2019. 
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Although he applied to take the September/October 2020 bar exam, he withdrew 

that application but proceeded with the character-and-fitness review process. 

{¶ 2} Two members of the Toledo Bar Association’s admissions committee 

interviewed Heckman in January 2020 and recommended that his application be 

denied. The bar association’s seven-member review committee then conducted a 

second interview of Heckman. Citing its concerns regarding Heckman’s emotional 

instability, alcohol usage, and lack of candor regarding his unsuccessful 

applications for admission to the Michigan and Indiana bars, the admissions 

committee recommended that Heckman’s application be disapproved. Heckman 

appealed that recommendation to the Board of Commissioners on Character and 

Fitness. See Gov.Bar R. I(14). 

{¶ 3} A three-member panel of the board conducted a hearing on January 

22, 2021. After considering Heckman’s testimony and exhibits, the panel 

concluded that he had failed to present clear and convincing evidence that he 

currently possesses the requisite character, fitness, and moral qualifications to 

practice law in Ohio. The panel recommended that (1) his application be denied, 

(2) he be permitted to reapply no earlier than January 15, 2023, and (3) he be 

required to submit to an evaluation by the Ohio Lawyers Assistance Program 

(“OLAP”) and successfully complete any treatment program recommended by 

OLAP before reapplying for admission to the Ohio bar. The board adopted the 

panel’s report and recommendation. 

Facts 

Alcohol-Related Offenses 

{¶ 4} In 1990, Heckman was arrested in Arizona for driving while under the 

influence of alcohol. The following year, he was convicted in Florida for public 

consumption of alcohol. Several years later, he was charged in Michigan with 

driving while having a suspended driver’s license, although the reason for the 

license suspension is not clear from the record. 
January Term, 2021 

3

{¶ 5} In 2014, Heckman was charged in Arizona with felony aggravated 

assault and misdemeanor disorderly conduct/domestic violence for striking his 

teenaged son during a social gathering at his sister’s home. The police report stated 

that Heckman had been drinking alcohol before the incident and had to be restrained 

by his relatives. He pleaded guilty to disorderly conduct/domestic violence, for 

which the court imposed a 60-day jail sentence (which, according to Heckman, was 

suspended) and 30 months of probation. He was released from probation after 

approximately 21 months. Heckman was also charged in Michigan with assault in 

2016 for allegedly striking a phone out of the hand of his other teenaged son. No 

finding of guilt was entered regarding that charge because Heckman successfully 

completed probation and 26 weeks of classes concerning domestic violence. 

{¶ 6} In addition to those criminal matters, Heckman’s ex-wife, who is a 

Michigan attorney, obtained four civil protection orders against Heckman 

following their 2007 divorce. One of those orders required Heckman to refrain 

from consuming alcohol when his children were in his care. 

{¶ 7} At the panel hearing, Heckman argued that two of his prior 

convictions relating to his alcohol use—including his conviction for driving while 

under the influence of alcohol—should not be held against him because they 

occurred nearly 30 years ago. He testified that the conduct giving rise to his 2014 

conviction for disorderly conduct/domestic violence and his 2016 assault charge 

involved mistakes that he had made in the heat of the moment while attempting to 

discipline his sons, and during his interview with the bar association’s sevenmember review committee, he suggested that the 2016 assault charge had been 

motivated by his ex-wife’s animosity toward him. Heckman stated in a letter to the 

board that he had successfully completed his domestic-violence-prevention classes 

and had not had an incident involving his children since 2016. 

{¶ 8} Heckman’s sons submitted affidavits in support of his application, 

attesting that they enjoy a loving relationship with him. One of Heckman’s sons 
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averred that Heckman is making progress in dealing with the difficulties in his life 

and has taken steps toward accepting responsibility for his actions. Heckman’s 

other son expressed his belief that Heckman understands the nature of his past 

conduct and has learned from it. After the panel hearing, a friend of Heckman’s 

who is a Michigan attorney submitted an affidavit expressing his opinion that 

Heckman has learned from his past mistakes and possesses the character and fitness 

necessary to practice law. 

{¶ 9} Although Heckman has generally denied that he has any problem with 

alcohol, the board noted that in 2015, Heckman obtained an evaluation from the 

Michigan Lawyers and Judges Assistance Program (“LJAP”) in conjunction with 

his efforts to gain admission to the Michigan bar and to secure his release from 

probation in Arizona. The LJAP evaluator rejected Heckman’s denials regarding 

his problem with alcohol, noting that he had twice been arrested for alcohol-related 

offenses in the early 1990s and that he had been drinking alcohol immediately 

before he was arrested for striking his son in November 2014. Based upon her 

clinical review and the information provided to her, the evaluator diagnosed 

Heckman with a moderate alcohol-use disorder. She recommended that he 

complete a structured substance-abuse program, a program for domestic-violence 

offenders, and a psychological evaluation to assess for the presence of a personality 

disorder. 

{¶ 10} The board acknowledged that Heckman has made strides in 

understanding some of the factors that contributed to his past behavior and has 

worked to maintain a loving relationship with his children. Heckman also 

submitted a favorable report from a counselor whom he had seen about 15 times in 

the previous five years, and a report following a March 2020 substance-abusedisorder assessment stating that he did not meet the criteria for a diagnosis under 

the DSM-5 (Diagnosis and Statistical Manual of Mental Disorders (5th Ed.2013)) 

and that no treatment was recommended. However, Heckman did not persuade the 
January Term, 2021 

5

board that he had meaningfully addressed the negative role of alcohol in his life, 

because he presented no evidence that he had entered into a monitoring program or 

had otherwise followed the recommendations made by the LJAP evaluator and he 

continued to deny that his alcohol use was a problem. 

Candor 

{¶ 11} In addition to its concerns about Heckman’s alcohol use, the board 

found that the record is replete with instances in which he was less than candid 

about his criminal offenses. For example, Heckman failed to disclose his 

November 2014 arrest to his law school until July 2015—approximately six months 

after he graduated. In a written response to that disclosure, the law school informed 

him that “[b]ecause you would have been placed on administrative probation for a 

felony arrest, and because this is a late disclosure, your status has been changed to 

administrative probation retroactive to November 14, 2014.” Notwithstanding that 

notification, Heckman denied on his Ohio registration application that he had ever 

been subjected to discipline by any law school. And as the board noted, although 

Heckman had disclosed in his registration application that he failed the Michigan 

bar exam, he waited until his interview with the bar association’s seven-member 

review committee to divulge that Michigan had refused to allow him to retake the 

exam on character-and-fitness grounds. Heckman could not recall during the 

hearing whether he had ever received written confirmation of that ruling but he 

testified that it had been orally conveyed to him.1

{¶ 12} Heckman testified that his omissions, including his failure to timely 

report his arrest in Arizona to his law school, were not intentional and that he simply 

forgot to disclose the information. But the board did not find his testimony 

1. The record in this case does not contain any evidence that Heckman’s Michigan bar application 

was denied on character-and-fitness grounds. The Michigan LJAP report states that the State Bar 

of Michigan Committee on Character and Fitness had expressed concerns regarding the numerous 

personal protection orders obtained by Heckman’s ex-wife, his November 2014 arrest for striking 

his son, and his failure to disclose and update information pertaining to his legal history. 
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persuasive and found that he did nothing to satisfy its lingering concerns regarding 

his lack of candor. Moreover, the record shows that in September 2018, Indiana 

denied Heckman’s application for admission to its bar on character-and-fitness 

grounds and will allow him to reapply for its July 2023 bar exam. 

Disposition 

{¶ 13} An applicant for admission to the Ohio bar bears the burden of 

proving “by clear and convincing evidence that the applicant possesses the requisite 

character, fitness, and moral qualifications for admission to the practice of law.” 

Gov.Bar R. I(13)(D)(1). An applicant may be approved for admission if the 

applicant satisfies the essential eligibility requirements for the practice of law as 

defined by the board and demonstrates that “the applicant’s record of conduct 

justifies the trust of clients, adversaries, courts, and others.” Gov.Bar R. 

I(13)(D)(3). 

{¶ 14} “A record manifesting a significant deficiency in the honesty, 

trustworthiness, diligence, or reliability of an applicant may constitute a basis for 

disapproval.” Id. In determining whether the record demonstrates such a 

deficiency, we consider a number of factors identified in Gov.Bar R. I(13)(D)(3), 

including the following factors that are present here: evidence of (1) the applicant’s 

untreated chemical dependency, (2) the applicant’s violations of his or her law 

school’s honor code, (3) the applicant’s failure to provide complete and accurate 

information concerning the applicant’s past, (4) the applicant’s false statements 

(including omissions), (5) the applicant’s acts involving dishonesty, fraud, deceit, 

or misrepresentation, and (6) the denial of the applicant’s admission to the bar in 

another jurisdiction on character-and-fitness grounds. See Gov.Bar R. 

I(13)(D)(3)(b), (d), (g), (h), (i), and (n). We also consider the age of the applicant 

at the time of the conduct, the recency of the conduct, the reliability of the 

information concerning the conduct, the seriousness of the conduct, the cumulative 

effect of the conduct, evidence of the applicant’s rehabilitation, the candor of the 
January Term, 2021 

7

applicant in the admissions process, and the materiality of any omissions or 

misrepresentations by the applicant. See Gov.Bar R. I(13)(D)(4)(a), (b), (c), (d), 

(f), (g), (i), and (j). 

{¶ 15} “Evidence of false statements, including material omissions, and 

lack of candor in the admissions process reflect poorly on an applicant’s present 

character, fitness, and moral qualifications.” In re Application of Panepinto, 84 

Ohio St.3d 397, 399, 704 N.E.2d 564 (1999); In re Application of Cvammen, 102 

Ohio St.3d 13, 2004-Ohio-1584, 806 N.E.2d 498, ¶ 22. “Even one incomplete 

answer can lead to the disapproval of an admission application if the applicant does 

not fully and honestly explain when the opportunity arises.” In re Application of 

Bagne, 102 Ohio St.3d 182, 2004-Ohio-2070, 808 N.E.2d 372, ¶ 23. Here, in 

addition to Heckman’s material omissions during the character-and-fitness review 

process, there are lingering concerns that he has an untreated alcohol-use disorder. 

Upon consideration of the record and the applicable rules, we agree with the board 

that Heckman has failed to carry his burden of proving by clear and convincing 

evidence that he currently possesses the requisite character, fitness, and moral 

qualifications for admission to the practice of law in Ohio. 

{¶ 16} Accordingly, we adopt the board’s report and disapprove Heckman’s 

pending registration application. Heckman shall be permitted to reapply for 

admission to the Ohio bar no earlier than January 15, 2023, and before then shall 

be required to submit proof that he has obtained an OLAP evaluation and 

successfully completed any treatment program recommended as a result of that 

evaluation. 

Judgment accordingly. 

O’CONNOR, C.J., and KENNEDY, FISCHER, DEWINE, DONNELLY, STEWART, 

and BRUNNER, JJ., concur. 

_________________ 

William Michael Heckman, pro se. 
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Joseph P. Dawson, for the Toledo Bar Association. 

_________________