On Friday, August 15, 2025, the Hearing Board of the Illinois Attorney Registration and Disciplinary Commission recommended that attorney Katherine A. Paterno be censured for misconduct involving the false notarization of a deed.
The case is entitled “In the Matter of Katherine A. Paterno,” with case no. 2024PR00010.
The board’s findings stemmed from a complaint filed by the Administrator, which alleged that Paterno violated Rule 8.4(c) of the Illinois Rules of Professional Conduct by engaging in dishonest conduct.
The hearing took place on May 29, 2025, at the Chicago office of the Attorney Registration and Disciplinary Commission (ARDC). A panel consisting of Rhonda Sallée, Scott M. Hoster, and Patrick Milhizer oversaw the proceedings. Paterno represented herself during the hearing, while Richard C. Gleason II represented the Administrator.
The complaint against Paterno was filed on February 16, 2024. However, during the hearing, the Administrator voluntarily dismissed one charge related to the recording of the deed, focusing solely on the false notarization claim.
The Hearing Board concluded that Paterno did indeed engage in dishonest conduct by certifying that she had witnessed a signature on a deed when she knew it to be false, as the individual in question had died nearly two years prior to the notarization.
Evidence presented during the hearing included various exhibits and testimonies. Paterno admitted to notarizing a quit-claim deed on December 15, 2017, which involved her stepbrothers and the trust of her stepmother. However, she testified that one stepbrother, Micheal Day, had not appeared before her to sign the deed, as he had died in 2015. Paterno claimed she had relied on the representations of her remaining stepbrothers regarding Micheal’s signature, believing it was valid based on her familiarity with it.
The board noted that while Paterno acknowledged her involvement in the notarization, she contested the authenticity of the deed presented by the Administrator, suggesting that it had been altered. Paterno claimed that her stepmother had created documents to undermine her credibility.
The Hearing Board emphasized that the Administrator had the burden of proving misconduct by clear and convincing evidence. They found sufficient evidence to support the claim that Paterno had engaged in dishonest conduct by falsely certifying a signature. However, they did not find sufficient evidence to prove that she had personally recorded the deed, which was another aspect of the original complaint.
In mitigation, Paterno testified that she had not benefited financially from the notarization and had intended to assist her family. She expressed deep remorse for her actions, stating that notarizing the deed was her biggest regret. Paterno also noted that she has practiced law without prior disciplinary issues for over 25 years and has engaged in various charitable activities.
The board’s recommendations took into account both mitigating and aggravating factors. While recognizing Paterno’s lengthy career without prior incidents, they also highlighted that she should have been aware of the professional standards regarding notarization. Ultimately, the board recommended censure rather than suspension, concluding that Paterno posed no ongoing threat to the public or the integrity of the legal profession.
The recommendation states:
“Based upon the foregoing cases and considering the relevant circumstances of this matter, we find that a censure is commensurate with Respondent’s misconduct, consistent with discipline that has been imposed for comparable misconduct, and sufficient to serve the goals of attorney discipline and deter others from committing similar misconduct. Accordingly, we recommend that Respondent, Katherine A. Paterno, be censured for her misconduct.”
According to Avvo.com, Ms. Paterno is an employment and labor attorney in Burr Ridge, Illinois. She acquired her law license in Illinois in 1998.
A copy of the original filing can be found here.
