Direct Answer

The Michigan Attorney Discipline Board issued three disciplinary notices in April 2026. Christopher J. Woolf of Dewitt was disbarred following felony convictions for child sexually abusive activity and related computer crimes. Robert A. Canner of Southfield received a second disbarment for intentional misappropriation of client funds across two matters, with restitution of $16,549.10 ordered. Zhigang Ma of Northville received a reprimand through Michigan’s reciprocal discipline process, mirroring a USPTO sanction issued in January 2026.

Key Points
WoolfDisbarred effective August 7, 2025, the date of his felony convictions. Four counts: child sexually abusive activity, accosting a child for immoral purposes, and computer-facilitated versions of each. License automatically suspended under MCR 9.120(B)(1) on conviction.
CannerSecond disbarment, effective December 12, 2025. Findings include intentional misappropriation of funds from two clients, IOLTA commingling, excessive fees, and client abandonment. Restitution of $16,549.10 ordered. Continuously ineligible to practice since his first disbarment on April 16, 2025.
MaReprimand effective April 16, 2026 through Michigan’s reciprocal discipline process under MCR 9.120(C). Mirrors a USPTO reprimand and six-month probation from January 29, 2026. Neither party objected or requested a hearing.
CostsTotal assessed costs across all three matters: $5,053.54. Woolf: $2,057.08. Canner: $2,485.44. Ma: $1,511.02.

Christopher J. Woolf — Disbarment

Discipline Record — Woolf, Christopher J. Disbarred
P Number P 79877
Case Nos. 25-81-AI; 25-95-JC
City / County Dewitt, Michigan — Ingham County
Effective Date August 7, 2025
Notice Issued April 15, 2026
Hearing Panel Washtenaw County Hearing Panel #2
Costs Assessed $2,057.08
Criminal Matter State of Michigan v Christopher James Woolf, 30th Circuit, Ingham County, No. 24-000182-FH-C30

The Grievance Administrator filed a Notice of Filing of a Judgment of Conviction under MCR 9.120(B)(3) after a jury returned a guilty verdict on August 7, 2025 on all four counts charged in Ingham County Circuit Court.

The convictions were: Count One, Child Sexually Abusive Activity, a felony under MCL 750.145C(2); Count Two, Using a Computer to Commit the Crime of Child Sexually Abusive Activity, a felony under MCL 752.7973(D); Count Three, Accosting a Child for Immoral Purposes, a felony under MCL 750.145A-A; and Count Four, Using a Computer to Commit the Crime of Accosting a Child for Immoral Purposes, a felony under MCL 752.7973(F).

Woolf’s license was automatically suspended on the date of conviction under MCR 9.120(B)(1). The Board issued a Notice of Automatic Interim Suspension on September 12, 2025 in Case No. 25-81-AI. Washtenaw County Hearing Panel #2 subsequently found that the convictions established professional misconduct and ordered disbarment. Woolf’s license has been continuously suspended since August 7, 2025.

Rules Violated
MCR 9.104(5) and MRPC 8.4(b)

The panel found Woolf’s felony convictions established violations of MCR 9.104(5), which treats criminal conduct as grounds for professional discipline, and MRPC 8.4(b), which prohibits conduct involving criminal law violations reflecting adversely on the lawyer’s honesty, trustworthiness, or fitness to practice.

Robert A. Canner — Second Disbarment

Discipline Record — Canner, Robert A. Disbarred (Second)
P Number P 11572
Case No. 24-70-GA
City / County Southfield, Michigan — Oakland County
Effective Date December 12, 2025
Notice Issued April 13, 2026
Hearing Panel Tri-County Hearing Panel #71
Restitution Ordered $16,549.10
Costs Assessed $2,485.44
Prior Disbarment Case No. 23-83-GA, effective April 16, 2025

The Grievance Administrator filed a three-count formal complaint alleging professional misconduct in Canner’s representation of three separate clients. Canner initially answered by invoking his Fifth Amendment privilege as to the majority of the allegations. Before the hearing, he amended his answer to plead no contest to those same allegations. At the hearing, the Grievance Administrator moved to dismiss Count Three, which the panel granted. The findings and resulting discipline rest on Counts One and Two.

Tri-County Hearing Panel #71 found that Canner intentionally misappropriated one client’s funds by retaining them for himself, intentionally misappropriated a second client’s settlement funds by failing to disburse the remaining balance, and intentionally commingled personal funds with client funds by depositing non-client money into his IOLTA account during the period those client funds were required to be held there.

Finding 01
Communication, Fee, and Contingency Agreement Violations — Count One

The panel found Canner violated MRPC 1.4(a) by failing to keep a client reasonably informed and failing to comply promptly with reasonable requests for information; MRPC 1.5(a) by charging or collecting an illegal or clearly excessive fee; and MRPC 1.5(c) by failing to put a contingent-fee agreement in writing stating the method by which the fee would be determined.

Finding 02
Client Funds, Safekeeping, and Abandonment Violations — Counts One and Two

Across both counts, the panel found violations of MRPC 1.15(b)(3), requiring prompt delivery of funds the client or third party is entitled to receive; MRPC 1.15(d), requiring that client property be held separately from the lawyer’s own property; and MRPC 1.16(d), requiring reasonable steps to protect a client’s interests upon termination, including notice, time to secure other counsel, return of papers, and refund of unearned fees. Count One additionally established a violation of MRPC 8.4(b) for conduct involving dishonesty, fraud, deceit, or misrepresentation reflecting adversely on fitness as a lawyer. Both counts further established violations of MCR 9.104(2)-(4) and MRPC 8.4(a).

The panel’s original order set Canner’s disbarment to run consecutively with the prior disbarment in Case No. 23-83-GA, placing the effective date at April 17, 2030. Before that order took effect, Canner moved to amend it to change the effective date to December 12, 2025, shifting the discipline to run concurrently rather than consecutively. Following a hearing on the motion, the panel granted the amendment. All other provisions, including the restitution order, remained unchanged. Canner has been continuously ineligible to practice in Michigan since his first disbarment on April 16, 2025.

Zhigang Ma — Reprimand (Reciprocal Discipline)

Discipline Record — Ma, Zhigang Reprimand
P Number P 72952
Case No. 26-22-RD
City / County Northville, Michigan — Wayne County
Effective Date April 16, 2026
Notice Issued April 16, 2026
Discipline Type Reciprocal — MCR 9.120(C)
Originating Jurisdiction U.S. Patent and Trademark Office
USPTO Proceeding In the Matter of Zhigang Ma, No. D2026-12, effective January 29, 2026
USPTO Sanction Reprimand and six-month probation
Costs Assessed $1,511.02

The Grievance Administrator filed a Notice of Filing of Reciprocal Discipline under MCR 9.120(C), attaching a certified copy of a Final Order Pursuant to 37 C.F.R. § 11.26 from the United States Patent and Trademark Office. The USPTO issued that order on January 29, 2026 in Proceeding No. D2026-12, reprimanding Ma and placing him on probation for six months.

The Attorney Discipline Board issued a procedural order on March 10, 2026 directing both parties to notify the Board within 21 days whether they objected to the imposition of comparable Michigan discipline and whether a hearing was requested. On March 10, 2026, both parties responded in writing, stating they neither objected nor requested a hearing. The Board entered its reprimand order on March 18, 2026, with an effective date of April 16, 2026.

QuickFAQs
Why was Christopher J. Woolf disbarred in Michigan?
Woolf was disbarred after a jury convicted him on four felony counts involving child sexually abusive activity and computer-facilitated crimes against a child. His license was automatically suspended on the date of conviction, August 7, 2025, and Washtenaw County Hearing Panel #2 subsequently ordered disbarment.
What did Robert A. Canner do to receive a second disbarment?
Canner was disbarred a second time after findings that he intentionally misappropriated client funds, failed to disburse settlement proceeds, commingled personal funds with client funds in his IOLTA account, collected excessive fees, and abandoned clients without notice. Restitution of $16,549.10 was ordered. His first disbarment became effective April 16, 2025.
What is reciprocal discipline under MCR 9.120(C)?
Michigan’s reciprocal discipline process allows the Attorney Discipline Board to impose comparable discipline when another jurisdiction has already sanctioned a Michigan-licensed attorney. The Board gives parties 21 days to object or request a hearing. If neither party objects, the Board imposes matching discipline. Zhigang Ma’s Michigan reprimand mirrors a January 2026 USPTO sanction and six-month probation.
What MRPC rules are most commonly cited in Michigan misappropriation disbarments?
Intentional misappropriation cases typically cite MRPC 1.15(b)(3), requiring prompt delivery of client funds; MRPC 1.15(d), requiring client funds be held separately from the attorney’s own property; MRPC 8.4(b), prohibiting dishonesty and criminal conduct; and MRPC 1.5(a), prohibiting excessive fees. MCR 9.104(2)-(4) is also a standard citation as a general misconduct provision.

Sources and Documentation

Primary Michigan Attorney Discipline Board — Notice of Reprimand: Zhigang Ma, Case No. 26-22-RD, issued April 16, 2026
Law Michigan Rules of Professional Conduct — MRPC 1.4(a), 1.5(a), 1.5(c), 1.15(b)(3), 1.15(d), 1.16(d), 8.4(a), 8.4(b)
Law Michigan Court Rules — MCR 9.104(2)-(4), MCR 9.104(5), MCR 9.120(B)(1), MCR 9.120(B)(3), MCR 9.120(C)
Federal U.S. Patent and Trademark Office — Final Order Pursuant to 37 C.F.R. § 11.26, In the Matter of Zhigang Ma, Proceeding No. D2026-12, January 29, 2026
Court State of Michigan v Christopher James Woolf, 30th Circuit, Ingham County Circuit Court, Case No. 24-000182-FH-C30
How to Cite This Article
Bluebook (Legal)

Rita Williams, Michigan Attorney Discipline Roundup: Disbarments and Reprimand, April 2026, Clutch Justice (Apr. 21, 2026), https://clutchjustice.com/michigan-attorney-discipline-roundup-april-2026/.

APA 7

Williams, R. (2026, April 21). Michigan attorney discipline roundup: Disbarments and reprimand, April 2026. Clutch Justice. https://clutchjustice.com/michigan-attorney-discipline-roundup-april-2026/

MLA 9

Williams, Rita. “Michigan Attorney Discipline Roundup: Disbarments and Reprimand, April 2026.” Clutch Justice, 21 Apr. 2026, clutchjustice.com/michigan-attorney-discipline-roundup-april-2026/.

Chicago

Williams, Rita. “Michigan Attorney Discipline Roundup: Disbarments and Reprimand, April 2026.” Clutch Justice, April 21, 2026. https://clutchjustice.com/michigan-attorney-discipline-roundup-april-2026/.

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