The Enforcement Ecosystem — Who Is Supposed to Be Doing This?

The Question

Who has the mandate, the evidence, and the authority to act — and what did they do with it?

This is not an investigation of the network. This is an investigation of the investigators. Every body below has statutory or court-rule authority over some piece of the documented misconduct. Not one of them has the full picture.

Ten Bodies. One Complaint. Two Letters.

On October 7, 2026, 📰 Clutch Justice : Clutch Justice documented the exact moment the enforcement gap becomes visible :

A Michigan resident filed a UPL complaint on August 31. On September 30, the State Bar closed the file — “did not meet the standards set by the UPL Committee.” The standards were not identified. On October 1, the AGC returned the filing — Banks “is not a listed attorney.” That is the fact that makes the conduct a violation. The remedy offered: a State Bar complaint form, for the office that closed the file the afternoon before.

Two letters. One day apart. Each pointing at the other office.

Put the letters in date order and the problem explains itself.

The Map

1. State Bar of Michigan — UPL Department

Jurisdiction: Unauthorized practice of law by non-lawyers (Rule 16, Supreme Court Rules) Authority: Investigate, recommend prosecution to Board of Commissioners, issue subpoenas

Evidence available:

• Detroit Police Report 26-0909-0176: Banks identified himself as “attorney” to officers
• School website: “Dr. Brian Banks, J.D., Ph.D.” — never admitted to any bar
• School name: “Purpose Charter Academy School for Law and Public Service”
• Serenity Guardianship Services Inc (LARA 802290962): for-profit guardianship firm, sole officer never barred

What happened: File No. 26-UP-51 was administratively closed September 30, 2026. The closure letter says the matter “did not meet the standards set by the UPL Committee.” The standards are not published. The letter does not say what the investigation consisted of or whether anyone reviewed the police report.

MCL 600.916 has three prohibitions. The third — “shall not in any manner whatsoever represent or designate himself as an attorney” — requires no client, no legal advice, no fee. Telling police officers you are an attorney, and watching them escort a father off school property on that representation, is the conduct the statute was written to prevent.

2. Attorney Grievance Commission (AGC)

Grievance Administrator: Michael V. Goetz (appointed Sep 2019) Deputy Administrator: Kimberly L. Uhuru Asst Deputy Administrator: Cynthia C. Bullington (at AGC since 1982 — 44 years) Jurisdiction: Attorney misconduct — licensed attorneys only Staff: 13 attorneys, 3 investigators

Evidence available:

• Lisa Moreland: AAG who argued against Banks’ administrator certificate → became PCA Board Director AND Banks’ litigation attorney (MRPC 1.7 conflict)
• Gregory Meihn: Attorney retained within 14 minutes of MDE investigation notification
• Verkeydia Hall: Filed PPO against journalist investigating Banks
• The complainant wrote to AG Nessel about Moreland’s dual role on September 10. No response.

What happened: The AGC returned the Banks UPL filing on October 1. Cynthia Bullington’s letter notes Banks is not a listed attorney and encloses a State Bar complaint form.

The gap: The supplemental complaint also addressed licensed attorneys (Moreland, Meihn, Hall). The return letter addresses only Banks. It is silent on the licensed attorneys who ARE within AGC jurisdiction.

As documented in the Institutional Immunity Pattern, the AGC’s own annual reports show:

• 2024: 88.8% of dispositions dismissed (1,627/1,832)
• 2023: 72.2% dismissed at intake
• 2012–2020: Three of every four complaints dismissed by the Grievance Administrator before reaching a hearing panel

3. Attorney Discipline Board (ADB)

Chair: Peter A. Smit (Oct 2026 – Sep 2027) Executive Director: Wendy A. Neeley Function: Adjudicates attorney discipline cases prosecuted by the AGC

The structural problem: Jehan Crump-Gibson is an ADB Hearing Panelist (appointed May 2017). Hearing panelists sit on three-member panels that conduct evidentiary hearings in attorney discipline cases.

Crump-Gibson simultaneously:

• Serves on panels that adjudicate attorney misconduct
• Represents Banks — a person who is the subject of interconnected attorney misconduct complaints
• Sits on the CitizenDetroit Action Group board with the DPSCD Board member who authorized Banks’ charter

The ADB processes what the AGC sends it. If the AGC doesn’t prosecute, the ADB has nothing to adjudicate. The system depends on the AGC acting.

4. Judicial Tenure Commission (JTC)

Interim Executive Director: Glenn J. Page (returned from retirement Feb 1, 2026) Commission Chair: Thomas J. Ryan, Esq. Staff: 15 positions (13 attorneys, 2 admin) — for all judicial oversight in the State of Michigan Phone: (313) 875-5110

Evidence available: Five Wayne County judges with documented connections to the Banks network:

• Judge Miller — PCA Board Chair while on the bench. Dismissed infant murder case.
• Judge Yancey — MacDowell Board Chair. Campaign paid [data pending] to Banks Strategy LLC.
• Judge Aliyah Sabree — MSU Law classmate of Banks’ claimed JD cohort.
• Judge Sean Perkins — Brother of Todd Perkins (Banks’ attorney). Previously worked at Perkins Law Group.
• Judge David Perkins — Family donated to Banks-aligned campaigns.

What happened: The JTC acknowledged five Requests for Investigation on September 24, 2026, and assigned them to staff for review.

What happened next (October 12, 2026): When the same complainant sent an email to 88 institutional recipients — including the JTC — with full evidence links and the 88-person CC line visible, the JTC responded in 23 minutes with a boilerplate: “As you were advised in an email response sent to you on September 21 of this year, the Commission cannot take any action in response to an email message.”

The JTC has five open RFIs from this complainant. Staff were assigned. The investigations are pending. Yet the JTC’s October 12 response treats the complainant as if they are a stranger emailing general questions.

Compare: Nikki Snyder — a State Board of Education member on the same CC line — responded in 13 minutes with her personal cell phone number. Same evidence. Same email. One institution gave a personal phone number. The other gave a form letter pretending it had never heard of the complainant.

The JTC is not refusing to investigate. The formal complaints are on file. The JTC is refusing to acknowledge, in a reply-all to 88 recipients, that it has open investigations. This is how the Institutional Immunity Pattern operates in real time: process the complaint through the confidential channel, perform the boilerplate on the public channel.

The gap:

• No permanent Executive Director. Applications closed July 13. As of October 12 — no appointment.
• Lynn Helland retired “abruptly” January 31, 2026. 📰 Clutch Justice : Clutch Justice flagged the leadership shift and broader questions about the Commission’s internal culture.
• Page returned from retirement — he retired July 2022, came back February 2026.
• 15 staff for the entire state of Michigan’s judicial oversight.
• Judge Miller is on the ballot November 3, 2026 — 22 days from today.
• No public proceeding has been initiated.
• The SBE meets October 13, 2026. Snyder — who responded in 13 minutes — will be in the room.

The same JTC pattern documented in Cross-Subgraph Patterns: Schipper (Barry County) investigation acknowledged, Galen (Eastpointe) confidentially admonished. Different counties, same processing mode.

5. LARA — Corporations Division

LARA Director: Dr. Marlon I. Brown (appointed Feb 2024) Corporations Division Director: Alexis Lupo

Evidence available:

• 6+ entities in “Not Good” standing or dissolved
• Purpose Foundation (803294855): 501(c)(3) with two convicted felons in all officer positions
• Serenity Guardianship (802290962): for-profit guardianship, sole officer never barred
• SDJ (802002459): three sequential assumed names — Save Detroit Jobs → Impact Detroit → Detroit Leaders

What happened: Automated “Not Good” standing for non-filing. Eventual dissolution for persistent failure.

The gap: LARA’s Corporations Division “promotes economic development and growth by facilitating the formation of business entities.” Their mandate is facilitation, not oversight. Entity formation is ministerial — if the paperwork is correct, it gets filed. There is no mechanism to cross-reference criminal records against entity officer filings. No mechanism to flag entities where every officer is a convicted felon.

6. Attorney General — Charitable Trust Section

AG: Dana Nessel Contact: ct_email@michigan.gov Jurisdiction: Charitable organization oversight under MCL 400.271 and MCL 14.251

Evidence available:

• Purpose Foundation (803294855): 501(c)(3), two convicted felons in all officer positions
• Right Turn Project (800936257): dissolved — were charitable assets properly transferred?

What the AG’s office CAN do: The AG just charged Fay Beydoun with 16 felonies for $20M grant abuse at Global Link International. Filed a complaint against Chosen Kingdom Builders for nonprofit governance and fiduciary-duty failures. The AG’s office actively prosecutes nonprofit fraud.

What happened here: No public record of action against any Banks network entity.

Purpose Foundation: two convicted felons, [data pending] revenue school, 3% math proficiency, 72.67% of revenue extracted by management company. Global Link: $20M grant, prosecution. The scale is different. The pattern — felon-controlled entity, government funding, inadequate governance — is identical.

7. DPSCD — Office of Charter Schools

Superintendent: Dr. Nikolai Vitti Director of Charter Schools: Kisha Verdusco (since February 2013 — 13 years) Jurisdiction: Charter authorization and oversight under MCL 380.502(4) and 380.507

MCL 380.507(1)(d): “Oversee each public school academy operating under a contract issued by the authorizing body. The oversight must be sufficient to ensure that the board of directors is in compliance with the terms of the contract and with applicable law.”

What happened: PCA was authorized in July 2025 despite the operator’s bottom- 3% academic record at MacDowell ( 3% math proficiency, statewide rank 1,443/1,488).

DPSCD recently declined to reauthorize Barack Obama Leadership Academy (BOLA). Superintendent Vitti publicly explained that decision by citing “contractual compliance, academic outcomes, and fiscal stewardship.” Those same criteria apply to Banks’ schools. Different outcome.

PCA’s board includes:

• A sitting judge (Miller) — Board Chair
• An assistant attorney general (Moreland) — Board Vice Chair
• A sitting City Council member (Johnson) — Board Secretary

These are DPSCD appointees. Under MCL 380.507, authorizers appoint board members who swear constitutional oaths.

8. Michigan Department of Education

What happened: MDE investigated Banks in February 2022 for having no teaching credential. Application #590606, status: HOLD. Banks continues to operate as superintendent of two schools.

The investigation letter went to Board President Wells-Stallworth. The response: Banks applied for an administrative permit. It was placed on HOLD. No credential has been issued. Banks has continued as superintendent for four years after the investigation.

9. Wayne County Prosecutor

Prosecutor: Kym Worthy

MCL 600.916 makes unauthorized practice of law contempt of the circuit court in the county where it happened. Purpose Charter Academy is in Wayne County. Banks told Wayne County police officers he was an attorney. The complainant asked both the State Bar and AGC to coordinate with the Wayne County Prosecutor. Neither letter mentions doing so.

Worthy herself alleged Judge Miller “displayed a bias” in an infant murder case (WXYZ, 2024). But broader enforcement on the Banks network: no public record of action.

10. Michigan Supreme Court

The Supreme Court:

• Appoints the Grievance Administrator (Goetz)
• Appoints the ADB (9 members, including the chair who oversees hearing panelists)
• Appoints the JTC Commissioners (9 members)
• Oversees the State Bar’s UPL program
• Declined in 2014 to publish a definition of “the practice of law” for comment

The enforcement system is their creation. When the State Bar closes a holding-out case and the AGC sends it back, the Supreme Court’s system produced that outcome. That is not a bug. It is an architectural gap.

The Pattern

Every body exercises authority up to its jurisdictional edge and stops. The edges don’t overlap. They gap.

What This Is Not

This is not an allegation of corruption. The Grievance Administrator is following his jurisdiction. The AGC correctly identified that a non-lawyer is outside its scope. The JTC assigned investigations to staff. LARA processes filings. Each body is doing what its mandate says.

The problem is that each mandate was written to handle one actor at a time. The Banks network operates across every mandate simultaneously. An operator who is not a lawyer (State Bar), whose attorneys may have conflicts (AGC), whose board includes judges (JTC), whose entities are controlled by felons (LARA), whose nonprofits hold charitable assets (AG), whose schools are authorized by public bodies (DPSCD), and whose credentials were investigated and left unresolved (MDE). No single body sees the whole pattern. The pattern lives in the gaps.

Connected Analysis

On this site:

• Hey Mikey, He Likes It! — the man who authored CISPA wants to join the Senate that killed it. Same donors fund Barrett. Same Dykema OS. Same election day. $88.8M from people who don’t live in Michigan.

• Institutional Immunity Pattern — the mathematics of 88.8% dismissal

• Cross-Subgraph Patterns — same oversight bodies appear across five investigations

• They Banked on Banks — the man the ecosystem failed to stop. Brian Roderick Banks: 9 convictions, 2 charter schools, board chair is a sitting judge, parent blocked at the door, PPO weaponized. The enforcement ecosystem measured against a live case.

• Signal Permeability — Live Anderson study: evidence sent to all ten oversight bodies. Measuring who opens it, who forwards it, who ignores it.

On detroit.primals.eco:

• Data Braid — GLLG Entity Graph — six independent searches converge: defense attorney + charter authorizer on same nonprofit board
• Corporate Network — LARA — the entity infrastructure
• Agency Referrals — eight federal agencies, state referrals, JTC investigations

Independent reporting:

• 📰 Clutch Justice : Mind the Gap: Michigan's Two Lawyer Regulators Pointed at Each Other, One Day Apart (Oct 7, 2026)
• 📰 Clutch Justice : No One Is Coming (Sep 24, 2026)
• 📰 Clutch Justice : JTC Names Glenn J. Page Interim Executive Director (Feb 2, 2026)

Verify Everything

The enforcement system is not broken. It is fragmented. Each body does exactly what its mandate says. The network operates in the space where no mandate reaches. The complainant did everything right. The system produced two letters, one day apart, each pointing at the other door.