What is covered here? Michigan’s Attorney Discipline Board issued seven actions in February 2026: five reprimands, one 45-day suspension, and one reinstatement following a 2014 disbarment. Misconduct categories included trust account mismanagement, client communication failures, litigation neglect, excessive or unearned fees, and conduct connected to witness testimony. Most cases were resolved through consent discipline.
Key Findings — February 2026
Pattern Five of the seven actions involved trust account mismanagement, failure to communicate with clients, or both — the two most recurring categories in Michigan attorney discipline proceedings.
Notable Jalal J. Dallo received a 45-day suspension after accepting documents intended to influence a victim’s testimony in a client’s criminal matter. The conduct also resulted in his removal from the Oakland County indigent defense attorney list.
Restitution Steven E. Scharg was ordered to repay $13,603.19 after collecting an excessive fee and failing to return an unearned advance. He also made a false statement during the grievance investigation.
Reinstatement Jarrod A. Barron, disbarred in 2014, had his license restored after satisfying hearing panel conditions and receiving clearance from the State Board of Law Examiners.
Process Six of the seven actions were resolved through consent discipline — a stipulated process in which the attorney admits misconduct and agrees to a sanction without a contested hearing.
QuickFAQs
What attorney discipline actions occurred in Michigan in February 2026?
The Attorney Discipline Board issued five reprimands, one 45-day suspension, and one reinstatement. Misconduct included trust account violations, client communication failures, litigation neglect, excessive fees, and conduct related to witness testimony.
What is consent discipline in Michigan?
Consent discipline is a process in which the attorney and the Grievance Administrator agree to a stipulated sanction without a contested hearing. The attorney admits the misconduct and accepts the discipline, which is then approved by a hearing panel.
Who oversees attorney discipline in Michigan?
The Michigan Attorney Grievance Commission investigates complaints. The Michigan Attorney Discipline Board adjudicates cases. Proceedings operate under Michigan Court Rule 9.115 and the Michigan Rules of Professional Conduct.
What is an IOLTA trust account violation?
An IOLTA violation occurs when an attorney fails to properly separate client funds from personal or operating funds. Michigan Rule of Professional Conduct 1.15 governs trust account requirements for Michigan attorneys.

Disciplinary notices issued during February 2026 reflect a familiar pattern in Michigan’s attorney regulation system: trust account violations, client communication failures, litigation neglect, and fee disputes. One case involved conduct connected to witness testimony in a criminal matter.

Process Note — Consent Discipline
Most Michigan attorney discipline cases are resolved through consent discipline: a process in which the attorney and the Grievance Administrator agree to a stipulated sanction rather than proceeding to a full contested hearing. The attorney admits the misconduct, and the agreed sanction is reviewed and approved by a hearing panel under MCR 9.115(F)(5). Consent discipline does not preclude the Board from imposing a different sanction if the stipulated one is found to be inadequate.

Case Summary Table

Attorney City Discipline Effective Date ADB Record
Erica C. Cicchelli Southfield Reprimand Jan. 10, 2026 ADB #7518
Jalal J. Dallo Bloomfield Hills 45-Day Suspension Feb. 4, 2026 ADB #7519
Mohammed Abdrabboh Dearborn Reprimand Feb. 18, 2026 ADB #7521
Andrea D. Cartwright Southfield Reprimand w/ Condition Feb. 26, 2026 ADB #7524
Marc Aaron Asch Kalamazoo Reprimand Feb. 26, 2026 ADB #7523
Steven E. Scharg Detroit Reprimand + Restitution Feb. 27, 2026 ADB #7527
Jarrod A. Barron East Lansing Reinstatement Feb. 26, 2026 ADB #7526

Case Detail

Erica C. Cicchelli Reprimand Southfield • Effective January 10, 2026 • ADB #7518

The attorney mistakenly used an IOLTA trust account to process an ACH payment for a personal credit card purchase. The transaction was rejected by the bank. The hearing panel found that client property was not kept separate from personal funds.

Violations
MRPC 1.15(d) — failure to maintain client funds separately • MRPC 8.4(a), (c) • MCR 9.104(1)–(4)
Costs assessed: $763.54
Jalal J. Dallo 45-Day Suspension Bloomfield Hills • Effective February 4, 2026 • ADB #7519

While representing a client in a criminal matter, the attorney accepted an envelope of documents intended for a third party that contained requests to persuade a victim to change testimony. The conduct led to the attorney withdrawing from the case and removal from the Oakland County indigent defense attorney list.

Violations
MRPC 3.4(c) — disobeying tribunal rules • MRPC 8.4(a), (b) — assisting misconduct and dishonest conduct • MCR 9.104(1)–(4)
Costs assessed: $773.20
Mohammed Abdrabboh Reprimand Dearborn • Effective February 18, 2026 • ADB #7521

The attorney was disciplined for improper management of an IOLTA trust account, including depositing personal funds into the trust account and failing to maintain required separation between client and personal funds.

Violations
MRPC 1.15(d) — failure to keep client funds separate • MRPC 1.15(f) — improper deposit of personal funds into trust account • MCR 9.104(2) and (3)
Costs assessed: $1,399.99
Andrea D. Cartwright Reprimand w/ Condition Southfield • Effective February 26, 2026 • ADB #7524

The attorney mishandled two separate client matters. In a landlord-tenant case, she mishandled discovery, failed to complete case evaluation requirements, and filed an unauthorized offer of judgment. In a custody matter, she failed to properly seek adjournment, missed trial dates, and approved a consent judgment without client authorization.

Violations
MRPC 1.2(a) — client authority • MRPC 1.3 — diligence • MRPC 1.4(a)–(b) — communication • MRPC 8.4(c) • MCR 9.104(1)–(3)
Costs assessed: $1,160.00
Marc Aaron Asch Reprimand Kalamazoo • Effective February 26, 2026 • ADB #7523

During representation in a federal discrimination lawsuit, the attorney failed to respond to discovery, missed hearings, and allowed the case to be dismissed with sanctions without informing the client. Although the case was later reopened, the attorney failed to promptly turn over the client’s file upon the conclusion of representation.

Violations
MRPC 1.1(c) — neglect of legal matter • MRPC 1.3 — diligence • MRPC 1.4 — client communication • MRPC 3.4(c), (d) — discovery violations • MRPC 8.4 • MCR 9.104
Costs assessed: $912.14
Steven E. Scharg Reprimand + Restitution Detroit • Effective February 27, 2026 • ADB #7527

The attorney collected an excessive fee and failed to refund an unearned advance payment after representation ended. During the grievance investigation, he also made a false statement of material fact.

Violations
MRPC 1.16(d) — failure to refund unearned fees • MCR 9.104(2)
Restitution ordered: $13,603.19  •  Costs assessed: $761.87
Jarrod A. Barron Reinstatement East Lansing • Effective February 26, 2026 • ADB #7526

Barron was originally disbarred in 2014. After petitioning for reinstatement and satisfying the conditions established by a hearing panel, the State Board of Law Examiners verified his eligibility for recertification. The Attorney Discipline Board issued an order restoring his license to practice law in Michigan.

Applicable Court Rules

Michigan attorney discipline proceedings operate under Michigan Court Rules Chapter 9. The Michigan Rules of Professional Conduct govern the substantive conduct standards applied in each case.

Official rule references: MCR Chapter 9 — Attorney Discipline  •  Michigan Rules of Professional Conduct (PDF)

Why This Matters

Attorney discipline notices rarely attract public attention, but they document recurring failure patterns in everyday legal practice. The February 2026 actions cover five distinct misconduct categories: trust account mismanagement, client communication failures, litigation neglect causing direct harm to clients, collection of excessive or unearned fees, and conduct that implicated witness testimony in a criminal case.

Recurring Pattern
Trust account violations and client communication failures appear in Michigan ADB notices with consistent frequency. Both categories represent failures in basic professional infrastructure rather than isolated judgment calls — which is why they tend to generate discipline even when the underlying conduct caused no direct financial loss to a client.

Most actions were resolved through consent discipline, which is the standard resolution mechanism in Michigan attorney regulation. Consent discipline allows the system to process a high volume of cases efficiently, but it also means that most misconduct findings do not result in public contested hearings. The record available to the public is the ADB order itself.

Tracking these notices provides a more accurate picture of how professional accountability functions in practice — including which conduct categories surface repeatedly and how the system calibrates sanctions across them.

Sources

Primary Michigan Attorney Discipline Board — Official Notice Index, February 2026
Rule Michigan Court Rules, Chapter 9 — Attorney Discipline
Rule Michigan Rules of Professional Conduct
How to Cite This Article
Bluebook (Legal)

Rita Williams, Michigan Attorney Discipline Roundup — February 2026 (Reprimands, Suspension, and Reinstatement), Clutch Justice (Mar. 13, 2026), https://clutchjustice.com/2026/03/13/michigan-attorney-discipline-roundup-february-2026/.

APA 7

Williams, R. (2026, March 13). Michigan attorney discipline roundup — February 2026 (reprimands, suspension, and reinstatement). Clutch Justice. https://clutchjustice.com/2026/03/13/michigan-attorney-discipline-roundup-february-2026/

MLA 9

Williams, Rita. “Michigan Attorney Discipline Roundup – February 2026 (Reprimands, Suspension, and Reinstatement).” Clutch Justice, 13 Mar. 2026, clutchjustice.com/2026/03/13/michigan-attorney-discipline-roundup-february-2026/.

Chicago

Williams, Rita. “Michigan Attorney Discipline Roundup – February 2026 (Reprimands, Suspension, and Reinstatement).” Clutch Justice, March 13, 2026. https://clutchjustice.com/2026/03/13/michigan-attorney-discipline-roundup-february-2026/.

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Attorney Discipline, Blog,

Last Update: March 19, 2026

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