IN RE: Muriel Offan VAN HORN (2026)

Suspension imposed. See per curiam.

ATTORNEY DISCIPLINARY PROCEEDING

This disciplinary matter arises from formal charges filed by the Office of Disciplinary Counsel (“ODC”) against respondent, Muriel Offan Van Horn, an attorney licensed to practice law in Louisiana.

UNDERLYING FACTS AND PROCEDURAL HISTORY

In September 2023, the ODC filed the formal charges in 23-DB-061. In July 2024, the ODC filed the formal charges in 24-DB-020. In September 2024, the ODC filed the formal charges in 24-DB-031. Respondent filed an answer to each set of charges. The matters were then consolidated for a hearing before a hearing committee. Prior to the hearing, the parties filed a joint stipulation in which respondent stipulated to some alleged facts and to all of the rule violations set forth in the formal charges. The stipulation includes the following:

23-DB-061

Counts I & II

Two complaints were filed against respondent with the ODC. The ODC requested responses to the complaints in April 2023, but respondent failed to respond, necessitating the issuance of a subpoena to obtain her sworn statement. After respondent was served with the subpoena in May 2023, she submitted responses to the complaints.

Respondent stipulated that her conduct in Counts I and II violated Rules 8.1(b) (knowing failure to respond to a lawful demand for information from a disciplinary authority) and 8.1(c) (failure to cooperate with the ODC in its investigation) of the Rules of Professional Conduct, as well as Supreme Court Rule XIX, § 9(c) (it shall be a ground for discipline for a lawyer to knowingly fail to respond to a lawful demand from a disciplinary authority).

24-DB-020

In 2022, Feltralynn Hall retained Regan Law PLC to file an application for post-conviction relief on behalf of Arthur Grandpre, III. The matter was assigned to respondent for handling. By April 2022, Ms. Hall had paid $11,000 towards the $15,000 fee quoted for the representation. In June 2023, Mr. Grandpre filed a complaint against respondent with the ODC, alleging that she failed to perform the work she was retained to do.

In her initial response to the complaint, sworn testimony, and subsequent correspondence to the ODC, respondent represented that she had filed various pleadings on behalf of Mr. Grandpre, including an application for post-conviction relief with the Orleans Parish Clerk of Court and an application for civil rights review with the Orleans Parish District Attorney's Office.

However, the docket master for the Orleans Parish Clerk of Court does not reflect that respondent ever filed a single post-conviction pleading on behalf of Mr. Grandpre. At his sworn statement, Edwin Lombard, the Chief Deputy Clerk of Court, testified that he reviewed the record and conferred with employees of the clerk's office, and confirmed that no attorney had filed an application for post-conviction relief on behalf of Mr. Grandpre.¹

Likewise, at her sworn statement, Emily Maw, then the Chief of the Civil Rights Division for the Orleans Parish District Attorney's Office, testified that she had checked all sources by which a civil rights review request is received, and nothing in the physical or electronic files for the district attorney's office showed that respondent sought review of Mr. Grandpre's convictions.

Respondent failed to provide Mr. Grandpre with a complete copy of his client file, despite his numerous requests, claiming that portions of the file were misplaced. To date, respondent has not returned any portion of the $11,000 fee paid.

Respondent stipulated that her conduct violated Rules 1.3 (failure to act with reasonable diligence and promptness in representing a client), 1.4 (failure to communicate with a client), 1.5(f)(5) (failure to refund an unearned fee), 1.15(a) (safekeeping property of clients or third persons), 1.16(d) (obligations upon termination of the representation), 3.2 (failure to make reasonable efforts to expedite litigation), 8.1(c), 8.4(a) (violation of the Rules of Professional Conduct), 8.4(c) (engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation), and 8.4(d) (engaging in conduct prejudicial to the administration of justice) of the Rules of Professional Conduct.

24-DB-031

In September 2021, Ramona Lane retained Regan Law PLC to file an application for post-conviction relief on behalf of her son, Anthony Lane. The matter was assigned to respondent for handling. Ms. Lane paid in full the $10,000 fee for the representation. Nevertheless, respondent did not file an application for post-conviction relief on Mr. Lane's behalf before the two-year prescriptive period expired in March 2023, nor has she filed any pleadings to date.

Respondent knew of the prescription issue as early as December 17, 2023. When confronted about the passage of time, respondent deliberately concealed the fact of the prescription from her client. Respondent also falsely claimed that the application was not filed because there were no viable claims and because the law had changed since Mr. Lane's conviction. Given that respondent had never obtained or reviewed the necessary documentation to assess whether any viable claims existed, these statements were misrepresentations.

Ms. Lane made several requests for her son's file, but respondent denied the requests, falsely claiming the file was her work product. During her sworn statement, respondent admitted that she did not return the file because she was ashamed and embarrassed she had performed no work in furtherance of the representation. She also claimed to have misplaced portions of the file, and she never provided an accounting, despite requests for same.

Respondent returned the $10,000 fee after Ms. Lane filed a disciplinary complaint in May 2024; however, respondent conditioned the return of the fee upon Ms. Lane signing a settlement agreement that included a release of liability and an agreement not to pursue the disciplinary complaint. Respondent failed to advise Ms. Lane in writing of the desirability of seeking counsel, and she failed to give Ms. Lane an opportunity to seek independent counsel.

Respondent stipulated that her conduct violated Rules 1.1 (failure to provide competent representation to a client), 1.3, 1.4, 1.5(f)(5), 1.8(a) (a lawyer shall not enter into a business transaction with a client unless certain conditions are met), 1.8(h) (a lawyer shall not settle a malpractice claim or potential claim with an unrepresented client or former client unless that person is advised in writing of the desirability of seeking and is given a reasonable opportunity to seek the advice of independent legal counsel in connection therewith), 1.15(a), 1.16(d), 3.2, 8.1(c), 8.4(c), and 8.4(d) of the Rules of Professional Conduct.

DISCIPLINARY PROCEEDINGS

Formal Hearing

A hearing was conducted by a hearing committee on July 15, 2025. Respondent appeared at the hearing and was represented by counsel. Both parties introduced documentary evidence. The following witnesses testified: respondent; Arthur Grandpre (via Zoom); Michael Grey, the Chief of the Civil Rights Division for the Orleans Parish District Attorney's Office; Anthony Lane (via Zoom); Ramona Lane; Feltralynn Hall (via Zoom); and Viviana Rayon, a paralegal formerly employed at Regan Law PLC.

Hearing Committee Report

The hearing committee considered the evidence and testimony presented at the hearing, accepted the joint stipulation of facts as its factual findings, and noted that the testimony established that respondent had engaged in a consistent pattern of neglect, miscommunication, and lack of oversight in the handling of client matters while employed at Regan Law PLC. The committee summarized the relevant testimony as follows:

Respondent - Respondent testified that she began working for attorney Martin Regan in January 2021 after she recovered from cancer. She was assigned to handle post-conviction relief cases and relied heavily on staff for administrative support. She described the firm as increasingly dysfunctional following Mr. Regan's health decline, his death in February 2022, and the subsequent involvement of attorney Stravros Panagoulopoulos, who likewise faced discipline. Respondent attempted to continue operations and complete pending matters but claimed she was hindered by poor recordkeeping and unreliable staff.

Regarding the Grandpre matter, respondent testified that she accepted $11,000 from Mr. Grandpre to pursue a wrongful conviction claim and post-conviction relief. Respondent admitted that she represented to the client that a civil rights application was filed when, in fact, it was not. She never obtained the district attorney's file and did not have procedures in place to confirm whether filings were completed. While she did not intend to deceive the client, she acknowledged that the failure to file the application constituted a misrepresentation. Despite the lack of action, no refund was issued. Respondent claimed the client's bad behavior during his incarceration had disqualified him from relief regardless of any efforts on her part.

Regarding the Lane matter, respondent admitted that she accepted $10,000 to file an application for post-conviction relief but then allowed the two-year deadline to lapse without filing. For several months after the prescriptive period passed, respondent continued to assure Ms. Lane that the case was being handled. When Ms. Lane asked for a refund, respondent required her to sign a “settlement agreement” which included a waiver of potential malpractice claims in exchange for partial repayment. Respondent admitted she executed the agreement without reading it.

Mr. Grandpre – Mr. Grandpre testified via Zoom from jail that he had been incarcerated since the age of sixteen and paid respondent to seek relief on his behalf. Mr. Grandpre believed respondent's representations that the filing of the civil rights application could lead to his early release if he maintained good behavior. When he later learned that no application had been submitted, he felt betrayed and hopeless. Mr. Grandpre ultimately filed his own application in 2023.

Mr. Grey – Mr. Grey testified that the only civil rights application received in connection with Mr. Grandpre's case was the one submitted by the client himself. No filing from respondent was ever located. He explained that the review process was internal and merit-based, that good behavior was a consideration but not dispositive, and that the office ceased accepting such applications in 2024. His testimony confirmed that respondent's representation to Mr. Grandpre was inaccurate.

Mr. Lane – Mr. Lane testified that respondent repeatedly told him that he had three years to file an application for post-conviction relief although the prescriptive period was two years. Mr. Lane believed his claims had merit and that her inaction left him feeling hopeless, although he ultimately received a refund.

Ms. Lane – Ms. Lane believed her payment would result in her son's release. She was unable to reach respondent for extended periods. She signed the refund agreement without understanding that it waived malpractice claims. The experience caused emotional harm and financial loss to her family.

Ms. Rayon – Ms. Rayon denied that she ever sabotaged respondent, withheld mail, or failed to file documents intentionally. While there was some interpersonal tension between them early on, their working relationship improved and she bore no animosity toward respondent. Ms. Rayon's testimony contradicted respondent's repeated suggestion that staff negligence or misconduct caused the errors.

The committee agreed with and accepted the joint stipulation that respondent violated the Rules of Professional Conduct as alleged in the formal charges.

The parties stipulated that respondent violated duties owed to her clients, the public, the legal system, and the legal profession. The parties further stipulated that respondent caused actual harm to Mr. Lane, Ms. Lane, and Mr. Grandpre, and that she harmed the legal profession and the disciplinary process.

The committee determined that respondent acted knowingly. The committee found “her actions or inactions resulted in actual harm to her clients, including missed deadlines, loss of opportunity, loss of funds, and waiver of rights.” The committee also found that the conduct surrounding the “settlement agreement” with Ms. Lane was unconscionable, explaining:

․ not only because of the content of the document, which conditioned the return of client funds on the surrender of legal rights, but also because Respondent admitted that she did not review or understand the agreement prior to its execution. This demonstrates a serious disregard for client rights and professional duties of honesty and fairness.

Relying on the ABA's Standards for Imposing Lawyer Sanctions, the committee determined that the baseline sanction is suspension.

The committee determined that the following aggravating factors are present: a pattern of misconduct, multiple offenses, bad faith obstruction of the disciplinary proceeding by intentionally failing to comply with the rules or orders of the disciplinary agency, vulnerability of the victims, substantial experience in the practice of law (admitted 1986), and “failure to make restitution.”

The committee determined that the following mitigating factors are present: absence of a prior disciplinary record and personal or emotional problems. The committee noted that respondent faced significant health issues, including cancer and a broken leg, as well as a difficult work environment, and that she expressed some remorse for her conduct and indicated that she would not handle client maters the same way again. However, the committee also noted that respondent repeatedly deflected responsibility onto office staff and law firm conditions, demonstrating an insufficient appreciation of her independent professional obligation. The committee did not question respondent's sincerity about helping her clients but found that her ability to do so, deflection on support staff, and continued affiliation with an unsupportive law firm remain a paramount concern.

The committee examined the court's prior jurisprudence and found no case law exactly on point, but cited several cases involving similar misconduct in which suspension of various lengths, as well as disbarment, was considered appropriate.² The committee found that both the “numerosity of the violations” and respondent's “seeming unwillingness to accept responsibility for her actions” warrant more than a year of suspension. The committee added:

The fee issues in this case are also especially concerning – one complainant was given partial restitution upon signing an unconscionable agreement and another has received no restitution to date. The individuals wronged were vulnerable and Respondent misled them on matters of significance – and she did this repeatedly.

Based on the above findings, the committee recommended that respondent be suspended from the practice of law for eighteen months. The committee further recommended that she be ordered to pay full restitution ($11,000) in the Grandpre matter, and given her continued assertion that the atmosphere at Regan Law PLC contributed to her misconduct, the committee also recommended that in the event she returns to the practice law in the future, she associate with a law firm that can provide appropriate support.

Neither respondent nor the ODC filed an objection to the hearing committee's report and recommendation. Therefore, pursuant to Supreme Court Rule XIX, § 11(G), the disciplinary board submitted the committee's report directly to the court for review.

DISCUSSION

Bar disciplinary matters fall within the original jurisdiction of this court. La. Const. art. V, § 5(B). Consequently, we act as triers of fact and conduct an independent review of the record to determine whether the alleged misconduct has been proven by clear and convincing evidence. In re: Banks, 09-1212 (La. 10/2/09), 18 So. 3d 57. While we are not bound in any way by the findings and recommendations of the hearing committee and disciplinary board, we have held the manifest error standard is applicable to the committee's factual findings. See In re: Caulfield, 96-1401 (La. 11/25/96), 683 So. 2d 714; In re: Pardue, 93-2865 (La. 3/11/94), 633 So. 2d 150.

Respondent has stipulated to the underlying facts as set forth above, and to the rule violations alleged in the formal charges. Respondent also stipulated that she violated duties owed to her clients, the public, the legal system, and the legal profession, causing actual harm. We agree with the committee's finding that she acted knowingly. The record also supports the aggravating and mitigating factors found by the committee. Accordingly, the only issue before the court is that of an appropriate sanction.

In determining a sanction, we are mindful that disciplinary proceedings are designed to maintain high standards of conduct, protect the public, preserve the integrity of the profession, and deter future misconduct. Louisiana State Bar Ass'n v. Reis, 513 So. 2d 1173 (La. 1987). The discipline to be imposed depends upon the facts of each case and the seriousness of the offenses involved considered in light of any aggravating and mitigating circumstances. Louisiana State Bar Ass'n v. Whittington, 459 So. 2d 520 (La. 1984).

The baseline sanction for a single count of neglect, failure to communicate, and failure to cooperate with the ODC is typically a one year and one day suspension.³ Considering that this matter encompasses four counts of knowing misconduct, which resulted in serious harm, as well as numerous rule violations, we find the committee's recommended sanction is appropriate.

DECREE

Upon review of the findings and recommendations of the hearing committee, and considering the record, it is ordered that Muriel Offan Van Horn, Louisiana Bar Roll number 17730, be and she hereby is suspended from the practice of law for eighteen months. It is further ordered that respondent make full restitution to Arthur Grandpre, III. All costs and expenses in the matter are assessed against respondent in accordance with Supreme Court Rule XIX, § 10.1, with legal interest to commence thirty days from the date of finality of this court's judgment until paid.

FOOTNOTES

1.   Respondent did not stipulate that she failed to file a PCR application on behalf of Mr. Grandpre. Respondent maintains she filed a “Second or Subsequent Uniform Application for Post-Conviction Relief” dated December 31, 2022. In December 2022, respondent prepared and mailed to the clerk of court a PCR application and motion for extension, together, in a single package, with no cover letter. The pleadings were filed under a single docket entry, identifying for filing only the motion for extension of time. A review of the physical record reveals the presence of a handwritten PCR application dated December 31, 2022, filed in or around the same time.

2.   See In re: Malone, 20-0762 (La. 11/4/20), 303 So. 3d 614 (two-year suspension imposed upon an attorney who neglected legal matters, failed to communicate, failed to return client files upon request, failed to provide accounting and unearned fees, and failed to cooperate with the ODC); In re: Vix, 08-2290 (La. 5/15/09), 11 So. 3d 1090 (two-year suspension, with all but three months deferred, imposed upon an attorney who neglected post-conviction matters, failed to return unearned fees, and failed to cooperate with the ODC); In re: Brancato, 06-0124 (5/26/06), 932 So. 2d 651 (disbarment imposed upon an attorney who neglected several legal matters, failed to communicate, failed to refund unearned fees, and failed to cooperate with the ODC); In re: Randolph, 05-0125 (La. 6/3/05), 905 So. 2d 1069 (one year and one day suspension imposed upon an attorney who failed to communicate with clients, failed to account for and/or refund unearned fees, failed to return client files, and failed to cooperate with the ODC); In re: Bradley, 04-0169 (La. 6/4/04), 875 So. 2d 67 (eighteen-month suspension, with five months deferred, imposed upon an attorney who neglected a post-conviction matter).

3.   See, e.g., In re: Jackson, 21-1488 (La. 1/12/22), 330 So. 3d 307; In re: Montgomery, 18-0637 (La. 8/31/18), 251 So. 3d 401; In re: Brown-Manning, 15-2342 (La. 3/4/16), 185 So. 3d 728; In re: Taylor, 14-0646 (La. 5/23/14), 139 So. 3d 1004.

McCallum, J., dissents and would reject the proposed discipline as too lenient. Cole, J., dissents and would reject the proposed discipline as too lenient. Penzato, J., dissents and would reject the proposed discipline as too lenient.