On Friday, October 31, 2025, the Disciplinary Counsel filed a complaint with the Board of Professional Conduct of the Supreme Court of Ohio against attorney Carol Beth Adelstein, alleging multiple instances of misconduct. The complaint details accusations of misappropriation of client funds, dishonest conduct, and failure to maintain proper IOLTA (Interest on Lawyers Trust Account) records.
The case is entitled “In the Matter of Carol Beth Adelstein,” with case number 2025-027.
Adelstein has previously faced disciplinary action, including suspensions in 2007 and 2011 for failing to register as an attorney. In 2020, she was suspended for one year, fully stayed, for mismanaging client trust accounts and engaging in dishonest conduct regarding client funds.
The current complaint outlines three specific counts of alleged misconduct. Count One, referred to as “The Barnhart Matter,” accuses Adelstein of misappropriating a $3,500 retainer from Candace Barnhart in May 2024. According to the complaint, Adelstein withdrew $3,000 in cash from her IOLTA shortly after Barnhart’s payment, later depositing $2,300 into her personal account and using the funds for personal expenses. When Barnhart requested a refund, Adelstein allegedly failed to disclose the withdrawal and subsequently used funds from other clients to cover the refund after Barnhart contested the charge with her credit card company.
Count Two, “The Morrow Matter,” involves allegations that Adelstein misappropriated funds from Sally Morrow, who retained Adelstein for a divorce case in February 2024. The complaint states that Morrow paid Adelstein over $21,000 in legal fees, but Adelstein’s IOLTA balance dropped significantly below what it should have been, indicating misappropriation. Additionally, Adelstein is accused of notarizing an affidavit for Morrow outside of Morrow’s presence, falsely attesting that Morrow had sworn to or affirmed the document before her. Despite Morrow’s repeated requests for a refund of unused retainer fees after terminating Adelstein’s services in June 2025, no refund was ever issued.
Count Three focuses on “False Statements and Failure to Reconcile and Maintain Rule-Compliant IOLTA Records.” The Disciplinary Counsel alleges that Adelstein provided false information during the investigation into the IOLTA overdrafts and failed to maintain accurate and compliant records of client funds. The complaint cites several instances of discrepancies in client ledgers, general ledgers, and bank statements, including instances where client retainers were not properly recorded or accounted for. Adelstein is also accused of misrepresenting the purpose of certain withdrawals and deposits in her IOLTA.
The Disciplinary Counsel is seeking sanctions against Adelstein for violating the Ohio Rules of Professional Conduct and requests that restitution be paid to Morrow, with the exact amount to be determined through further discovery.
According to Avvo, Ms. Adelstein is a divorce and separation lawyer in Cleveland, OH. She acquired her law license in Florida in 1998.
A copy of the original filing can be found here.
