On Tuesday, February 17, 2026, the Supreme Court of Ohio issued a ruling against Pippa Lynn Henderson Carter, a former attorney, for engaging in the unauthorized practice of law. The court’s decision upholds findings that Carter, who was disbarred in 2006, acted as an attorney in a probate matter, prepared deeds for real property transfer, and notarized these deeds as an “attorney” without proper authorization.
The case is entitled “In the Matter of Pippa Lynn Henderson Carter,” with case no. 2025-1329.
The case originated from a complaint filed in October 2024 by the disciplinary counsel. The complaint alleged that Carter, despite her disbarment, was holding herself out as an attorney while representing a beneficiary in a probate case, specifically involving the estate of Inez W. Patterson, who passed away on August 19, 2020. Documents showed Carter drafted two quitclaim deeds transferring property from Denise Patterson to John C. Patterson, Jr., and notarized the deeds using a stamp identifying her as an attorney.
The Board on the Unauthorized Practice of Law attempted to serve Carter with the complaint and amended complaints at her last known address in Cleveland, using both certified and ordinary mail. While the first certified mailing was unclaimed and returned, the court deemed service complete, as there was no evidence that the complaints sent by ordinary mail were not received.
In June 2025, the board informed the relator that Carter was in default of the answer. Subsequently, a motion for default was filed, supported by evidence and citations, asserting Carter’s unauthorized practice of law. A three-member panel of the board determined that Carter was indeed in default and had engaged in the unauthorized practice of law by acting as an attorney, preparing quitclaim deeds, and notarizing these deeds without a license.
The court’s ruling stated that Carter engaged in five instances of unauthorized practice of law. In addition to enjoining Carter from further unauthorized practice of law, the Supreme Court also prohibited her from performing notarial acts in Ohio unless properly appointed and commissioned by the Ohio Secretary of State. The court ordered Carter to pay a civil penalty of $30,000, which equates to $6,000 for each of the five violations.
The Supreme Court referenced previous disciplinary actions against Carter, including her initial admission to the Ohio bar in 1989, her suspension in 1997 for failing to comply with a subpoena, and her indefinite suspension in 1999 for neglecting a client’s legal matter and failing to cooperate in a disciplinary investigation. She was permanently disbarred on April 5, 2006, for engaging in the unauthorized practice of law during her indefinite suspension and for additional acts of professional misconduct. Despite the disbarment order, Carter continued to practice law, leading to further contempt of court findings and sanctions.
According to the filing, Ms. Carter acquired her law license in Ohio in 1989.
A copy of the original filing can be found here.
