In the Matter of Michael Cerulli

Summary

The court affirmed a public reprimand imposed on an attorney who displayed a sexually suggestive meme to detainees in a courthouse lockup and responded disrespectfully to a probation officer who objected. The court held that the respondent received a fair hearing, that the sanction was not markedly disparate from comparable discipline, and that the reprimand punished demeaning professional conduct rather than protected political expression.