In June 2025, the New Jersey Supreme Court publicly censured attorney Gwyneth K. Murray-Nolan for engaging in a non-waivable concurrent conflict of interest during a property dispute. The case involved representing both an LLC and its individual members—whose interests were directly at odds—without proper withdrawal or client consent. The matter also included a misrepresentation to the court, underscoring the dual ethical duties of loyalty to clients and candor to the tribunal.
In the Matter of Gwyneth K. Murray-Nolan, DRB 24-155 (N.J. June 11, 2025).
Docket No. DRB 24-155 was heard by the New Jersey Disciplinary Review Board, with oral argument held on November 21, 2024 and a decision issued on January 6, 2025.
The Board addressed whether Murray-Nolan had a concurrent conflict of interest by representing both H&H (an LLC) and two individual members, John O’Connor and Harry Hodkinson, whose interests were in conflict regarding a property dispute
Retainer Agreement & Dual Representation
The documents and correspondence indicated that Murray-Nolan had established an attorney-client relationship not just with H&H, but also individually with Hodkinson and O’Connor. Hodkinson even communicated directly with the court, implying a belief that Murray -Nolan represented him personally
Conflicting Interests
Although Murray-Nolan insisted that both individuals had aligned goals namely, maximizing proceeds from the property sale her actions showed otherwise. The Board found that she effectively prioritized O’Connor’s interests, to the detriment of Hodkinson, particularly because she pressed forward with work under O’Connor’s direction while leaving Hodkinson “without a loyal advocate”
Lack of Waivable Consent & Failure to Withdraw
The Board concluded that legally, representing opposing interests even under the guise of representing a single entity H&H requires voluntary withdrawal or proper consent under Rule of Professional Conduct (RPC) 1.7. Murray-Nolan neither obtained proper waivers nor withdrew, thereby exacerbating the conflict.
False Certification
In aggravation, the Board found she provided the court with a false certification signed by Hodkinson’s former spouse, inaccurately attesting that Hodkinson was satisfied with her representation another serious ethical breach.
The DRB determined that Murray-Nolan did indeed engage in a non-waivable concurrent conflict of interest, and that despite being aware of the conflict, she continued to represent clients with adverse interests; she further misrepresented material facts to the court.
Balancing the seriousness of these ethical violations against a generally unblemished 22-year record, the Board recommended a censure as the appropriate sanction.
On June 11, 2025, the New Jersey Supreme Court issued a formal order: Gwyneth K. Murray-Nolan was censured, required to reimburse administrative costs and actual expenses to the Disciplinary Oversight Committee, and the judgment will be permanently recorded in her attorney file.
The case shows that even when clients appear to have a “shared goal”, if their underlying legal interests diverge, the attorney must treat it as a non-waivable conflict. The New Jersey DRB made it clear that simply representing a business entity (like an LLC) does not shield you from conflicts with individual members especially if their positions oppose each other in practice.
Solo and small-firm lawyers often represent closely connected parties (businesses and their members, spouses, co-owners).
This case shows that blurred client boundaries can quickly turn into ethical violations especially when disputes arise mid-representation.
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