The Indiana Supreme Court has imposed a Public Reprimand on Indianapolis attorney Steven P. Taylor for violating professional conduct rules in his representation of clients in a post-bankruptcy matter.
The discipline, stemming from his failure to diligently pursue an agreed-upon legal action and his persistent lack of communication, serves as a sharp reminder of the non-negotiable duty attorneys owe to their clients.
The Case: Unfiled Petition and Unanswered Calls
The disciplinary action (In the Matter of Steven P. Taylor, Supreme Court Case No. 24S-DI-210) arose from Taylor’s handling of a legal issue for a married couple following the successful discharge of their Chapter 13 bankruptcy.
The Core Issue
After their bankruptcy case closed, the clients were notified by the IRS of an audit resulting in a significant, additional tax liability for their 2015 taxes.
- The Agreement to Act: Taylor agreed to represent the clients, first handling an unsuccessful administrative appeal. Crucially, he then agreed to file a petition for an adversary proceeding against the IRS. The goal of this petition was to enforce the bankruptcy discharge and protect the clients from the new tax claim.
- The Failure to Act (Lack of Diligence): Despite his agreement, Taylor never filed the petition. The disciplinary record notes that the clients likely would not have won the proceeding under federal law, but the failure to act still constituted a violation of professional duty.
- The Failure to Communicate: Compounding the problem, Taylor became largely unresponsive to the clients’ numerous requests for information and updates on their case.
As a direct result of the delay and inaction, the IRS eventually retained the clients’ 2022 tax refund to apply against the outstanding 2015 tax debt.
Violations of the Professional Rules
By failing to act promptly and ignoring his clients’ requests, Steven P. Taylor admitted to violating two key rules under the Indiana Rules of Professional Conduct:
- Rule 1.3 (Diligence): Requires an attorney to act with reasonable diligence and promptness in representing a client.
- Rule 1.4(a)(4) (Communication): Mandates that a lawyer must promptly comply with a client’s reasonable requests for information.
The Sanction: Public Reprimand
The Indiana Supreme Court approved a Conditional Agreement for Discipline and issued a Public Reprimand. This disciplinary measure is a public censure of the attorney’s conduct.
The Court’s order serves as an official notice to the profession and the public that Mr. Taylor’s conduct was unprofessional.
Conclusion: Diligence is Non-Negotiable
The discipline imposed on Steven P. Taylor, while a public reprimand and not a suspension, is a powerful affirmation of the courts’ commitment to enforcing the basic duties of a lawyer. The outcome of the potential lawsuit was secondary to the lawyer’s process: an attorney must never neglect a matter entrusted to them.
The Indiana Supreme Court explicitly emphasized that the core misconduct was the failure to exercise reasonable diligence and the failure to maintain communication. For the public, this case highlights that even in complex legal matters like bankruptcy and tax disputes, clients are entitled to prompt action and clear, consistent communication from their attorney. Professionalism demands follow-through, and the failure to provide it has clear, public consequences.