When an attorney receives documented notice that their client has registered domains in a minor child’s name and forwards that notice to the harasser without advising the client to stop, that is not legally neutral conduct. Michigan’s Rules of Professional Conduct say otherwise. This piece examines what the rules actually require, why forwarding a cease and desist to a harasser raises serious professional responsibility questions, and why filing a defamation suit against someone for accurately reporting that harassment is not zealous advocacy. It is something else.
The Moment I Keep Coming Back To
September 10, 2025. I sent a cease and desist to Philip L. Ellison through his firm’s own website contact form. The message was not subtle. It named domains that had been registered in my 14-year-old daughter’s full legal name. It named his client, Kevin Lindke, as responsible. It cited MCL 750.411h. It demanded the domains be removed and contact cease immediately.
Ellison replied the same day. He acknowledged receipt. He told me he had forwarded my message to his client as a courtesy.
He did not call the police. He did not advise his client to stop. He did not acknowledge that a minor child had been targeted by name. He forwarded the cease and desist to the person I had just accused of targeting my daughter, who then posted it publicly and mocked me for being upset about it.
Two months and twenty days later, Ellison filed this lawsuit against me.
I am a journalist. I document things. And what I have documented here is not just the conduct of one attorney in one case. It is a gap in how we talk about professional responsibility, specifically what an attorney is required to do when they receive credible notice that their client is targeting a child.
What the Michigan Rules of Professional Conduct Actually Say
The Michigan Rules of Professional Conduct do not give attorneys a pass because their client is doing the harassing rather than the attorney personally.
MRPC 1.2(d) prohibits a lawyer from counseling a client to engage in, or assisting a client in, conduct that the lawyer knows is criminal or fraudulent. The registration of domains in a minor child’s name, for the documented purpose of harassment, is conduct that implicates MCL 750.411h, MCL 750.411i, and MCL 750.411s. When an attorney receives a cease and desist identifying that conduct by name and statute, and forwards it to the client without advising the client to stop, the question of whether that attorney has crossed into facilitation is not abstract.
MRPC 8.4(b) makes it professional misconduct for a lawyer to commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer. MRPC 8.4(c) prohibits conduct involving dishonesty, fraud, deceit, or misrepresentation. When an attorney receives documented notice of a client’s targeting of a minor and does nothing, and then files a lawsuit against the person who sent the notice, the question of what that conduct reflects about the attorney’s fitness is not answered by pointing to zealous advocacy.
MRPC 3.1 requires that a lawyer not bring or defend a proceeding unless there is a basis in law and fact for doing so that is not frivolous. A defamation suit filed against someone for accurately reporting harassment that the attorney received documented notice of two months earlier has a structural problem with this rule that does not resolve itself.
When Ellison forwarded my cease and desist to Lindke as a courtesy, he did not merely fail to help. He provided the harasser with a tool for further harassment. The cease and desist was my documentation of harm to my child. He handed it to the person causing the harm. Lindke uploaded it publicly. That sequence is in the record.
The Child Protection Obligation That Does Not Disappear
Michigan, like every state, has a mandatory reporting framework. Under MCL 722.623, certain professionals are required to report suspected child abuse or neglect to the Department of Health and Human Services. Attorneys are not on the mandatory reporter list in Michigan. But the absence of a mandatory reporting obligation does not answer the question of what professional conduct requires when an attorney has direct, documented evidence that their client has registered internet domains targeting a named minor child for the express purpose of harassment.
The American Bar Association’s Model Rules address this in the context of client confidentiality. Under Model Rule 1.6(b)(1), a lawyer may reveal information relating to the representation of a client to the extent the lawyer reasonably believes necessary to prevent reasonably certain death or substantial bodily harm. Michigan’s equivalent, MRPC 1.6(c)(1), contains similar permissive disclosure language.
The word “may” is doing a lot of work there. Attorneys and ethics scholars have long debated whether “may” in this context should sometimes function as “must,” particularly when the potential victim is a child, the harm is documented, and the attorney has received direct notice.
What is not debated is this: when an attorney receives that notice, forwards it to the client without any guidance to stop, and then files a lawsuit against the person who sent it, the attorney has made a choice. That choice has professional consequences.
There is no reason for an adult with no connection to a child to register domains in her name. It is predatory. Ellison claimed my protests about it were defamation. He had the cease and desist documenting what his client did before he filed a single court paper. He never contacted police. He never told his client to stop. He sued me instead.
The Pattern This Creates
The specific facts of my case are mine. But the pattern they reflect is not unique.
Attorneys who represent clients engaged in coordinated harassment campaigns, the kind that use social media, domain registration, restraining order abuse, and litigation as instruments, face a recurring ethical inflection point. At some moment, someone sends them a notice. A cease and desist. An email. A court filing. Something that puts them on actual notice that their client’s conduct has crossed lines.
What the attorney does at that moment matters. Not just ethically, but legally and professionally.
Forwarding the notice to the client without guidance is not ethically neutral. If the client then escalates, publishes the cease and desist, mocks the person who sent it, continues or intensifies the targeted conduct, the attorney’s inaction at the moment of notice becomes part of the record. Courts have found in analogous contexts that an attorney’s failure to act on clear notice of client misconduct can constitute ratification of that misconduct.
Filing a lawsuit against the person who sent the notice is not ethically neutral either. When that lawsuit is filed on the same day as a final retraction demand, without any prior demand having been sent, and when the underlying claims rest on a characterization of the defendant’s conduct as defamatory despite the attorney’s own documented knowledge that the conduct complained of was accurate reporting of real harassment, the good-faith basis required by MRPC 3.1 is in serious question.
The gap is not in the rules. MRPC 1.2(d), 3.1, 8.4(b), and 8.4(c) are clear. The gap is in enforcement, specifically in how bar grievance systems respond when the misconduct takes the form of facilitation and retaliatory filing rather than direct action. This is the gap this case documents.
What Should Have Happened
An attorney who receives a cease and desist documenting that their client has registered domains in a minor child’s name should, at minimum, advise the client in writing to cease the conduct immediately. This is not complicated. It is basic competent representation. A client who is creating legal exposure by targeting a minor should be told to stop creating that exposure.
The attorney should document that advice and the client’s response. If the client refuses to follow the advice, the attorney has a decision to make about continued representation. An attorney cannot continue to advocate for a client while knowing the client is engaged in ongoing conduct that violates the law and harms children.
The attorney should decline to use the harassed party’s accurate reporting of that conduct as the basis for a defamation claim. Truth is an absolute defense to defamation. If the attorney knows, because they received a cease and desist documenting the conduct two months before filing, that the underlying conduct occurred, filing a defamation suit over accurate reporting of that conduct is not a legitimate exercise of advocacy.
The attorney should not forward the cease and desist to the client for ridicule. I want to be direct about this. When Ellison forwarded my cease and desist to Lindke, and Lindke then uploaded it publicly and mocked me for being upset that my child had been targeted, Ellison did not merely fail to help. He actively provided the harasser with a tool for further harassment.
Advise the client in writing to cease. Document it. If the client refuses, evaluate continued representation. Do not file a defamation suit against the person who documented the harm. Do not forward their cease and desist to the harasser. These are not high bars. They are the floor.
Why This Matters Beyond My Case
I write about courts and legal proceedings because I believe transparency in the justice system matters. What I have documented in this case is not just a story about what happened to me. It is a story about a gap in how professional responsibility is enforced, and a gap in how courts evaluate attorney conduct when the misconduct is facilitation rather than direct action.
Every person who has received a harassing domain registered in their child’s name, sent a cease and desist to the responsible attorney, and watched that attorney forward it to the harasser deserves to know: that is not how it is supposed to work. The rules say otherwise. The question is whether anyone enforces them.
The Attorney Grievance Commission file on Philip L. Ellison, AGC File No. 25-2363, assigned to Senior Associate Counsel Cora L. Morgan as of December 17, 2025, remains open.
Time will tell what the record produces. But I damn well know how to read it.
Sources
Rita Williams, When Your Client Targets a Child: What the Rules of Professional Conduct Actually Require, Clutch Justice (May 10, 2026), https://clutchjustice.com/2026/05/10/attorney-duty-minor-harassment/.
Williams, R. (2026, May 10). When your client targets a child: What the rules of professional conduct actually require. Clutch Justice. https://clutchjustice.com/2026/05/10/attorney-duty-minor-harassment/
Williams, Rita. “When Your Client Targets a Child: What the Rules of Professional Conduct Actually Require.” Clutch Justice, 10 May 2026, clutchjustice.com/2026/05/10/attorney-duty-minor-harassment/.
Williams, Rita. “When Your Client Targets a Child: What the Rules of Professional Conduct Actually Require.” Clutch Justice, May 10, 2026. https://clutchjustice.com/2026/05/10/attorney-duty-minor-harassment/.
