The Tennessee Supreme Court upheld the decision of a Tennessee Board of Professional Responsibility hearing panel to disbar a Davidson County attorney following three criminal convictions. These convictions stemmed from the attorney’s conduct while representing a client in post-divorce proceedings.
Robert Allen Doll, III, who practiced family law in Tennessee, was involved in a case beginning in 2013 when one of his clients raised concerns about her children’s safety during visitations with her ex-husband. An emergency petition was filed in Williamson County domestic relations court to prevent the ex-husband from exercising visitation rights. The petition included an oath that appeared to bear the client's notarized signature, which Mr. Doll signed as her attorney. A judge granted the petition and scheduled a hearing.
At the initial hearing, Mr. Doll was absent, and his client testified that she had not signed the petition. Consequently, the judge terminated the restraining order and requested Mr. Doll's presence at another hearing to explain the signature discrepancy. At this subsequent hearing, Mr. Doll asserted that his client had reviewed and signed the petition in his office on the day it was notarized. The judge warned Mr. Doll of potential criminal allegations due to conflicting testimonies.
The District Attorney General obtained grand jury indictments against both Mr. Doll and his client. During Mr. Doll's criminal trial, his client testified that she did not sign the petition nor visit Mr. Doll's office for that purpose but claimed he instructed her outside a courtroom to lie under oath about signing it without informing her of possible legal repercussions for perjury.
A jury convicted Mr. Doll on two counts of subornation of aggravated perjury for instructing his client to lie under oath and one count of criminal simulation for forging her signature—both Class E felony offenses considered serious crimes under Tennessee Supreme Court Rule 9.
Following these convictions, Mr. Doll’s law license was suspended, and the matter was referred to a Board of Professional Responsibility hearing panel to determine final disciplinary actions. During this hearing, Mr. Doll admitted to his convictions related to actions taken while representing his client in court.
The panel concluded that disbarment was appropriate due to Mr. Doll's engagement in serious criminal conduct involving intentional interference with justice and violation of professional duties owed by attorneys, causing significant harm or potential harm to his client.
Mr. Doll appealed this decision first to Davidson County chancery court—which affirmed—and subsequently to the Tennessee Supreme Court, arguing for suspension instead of disbarment based on precedents set by similar cases.
However, the Supreme Court rejected these arguments, stating that neither Board panels nor trial courts have authority under disciplinary rules to consider similar misconduct cases when determining sanctions; only the Supreme Court holds such authority upon review but found no comparable case warranting suspension over disbarment for Mr. Doll.
Acknowledging "it is undisputed that the jury credited testimony showing that Mr. Doll took advantage of his client's trust and pressured her into lying," Chief Justice Holly Kirby wrote that Mr. Doll's conduct “cuts through the very heart of the judicial system.” Consequently, he was ordered disbarred from practicing law in Tennessee.
To read Chief Justice Holly Kirby's opinion on Robert Allen Doll, III v. Board of Professional Responsibility of the Supreme Court of Tennessee, visit TNCourts.gov.
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