The Circular Shield — How the Attorney Grievance Commission Protects the Attorneys Who Protect the Enterprise

What Happened

On or about September 27, 2026, a Request for Investigation was filed with the Michigan Attorney Grievance Commission against two attorneys:

1. Lamar Moreland — Assistant Attorney General. Serves as Vice Chair of the Purpose Charter Academy Board of Directors. Works in the AG’s Criminal Justice Bureau — the bureau that prosecutes state RICO under MCL 750.159i. Governs the school the AG should be investigating.

2. Todd Perkins — Brian Banks’ personal attorney. Filed the PPO (Case No. 26-114083-PH) to silence the complainant. Has 4 personal bankruptcies and $100K+ in IRS tax liens. His brothers are Judge Sean Perkins (36th District Court) and Judge David Perkins (Probate Court, Chief Judge Pro Tem).

On October 1, 2026, the AGC responded.

The Response — AGC File No. 26-2141

Cynthia C. Bullington, Assistant Deputy Administrator, sent the following:

“We received the enclosed correspondence, in which you list more than one attorney. You must complete a separate form for each attorney describing what actions by that attorney you believe constitute misconduct.”

“Your original correspondence is enclosed. No further action will be taken until you resubmit the Request for Investigation with the requested information.”

They returned the original evidence. They sent blank forms. They created a file number — 26-2141 — and closed it before it opened.

Michael V. Goetz, Grievance Administrator, signed the cover letter enclosing the blank Request for Investigation forms.

Why This Matters: The Circular Shield

The AGC is the entity that disciplines attorneys in Michigan. It operates under the authority of the Michigan Supreme Court (MCR 9.109 et seq.). When an attorney violates the Michigan Rules of Professional Conduct, the AGC investigates, and if warranted, files formal charges with the Attorney Discipline Board.

But the AGC is also a gate. And when the gate chooses not to open, every attorney behind it is shielded.

Here is the circle:

┌──────────────────────────────────────────────────────────┐
│                   THE CIRCULAR SHIELD                     │
│                                                          │
│  BANKS operates the enterprise                           │
│    ↓                                                     │
│  PERKINS (Banks' attorney) files PPO to silence          │
│  complainant                                             │
│    ↓                                                     │
│  MORELAND (AAG) governs the school from the board,       │
│  preventing AG investigation                             │
│    ↓                                                     │
│  Complainant files AGC complaint against Perkins         │
│  AND Moreland                                            │
│    ↓                                                     │
│  AGC BOUNCES IT — "you listed more than one attorney"    │
│  Returns evidence. Sends blank forms.                    │
│    ↓                                                     │
│  Enterprise continues. 362 children lose another day.    │
│    ↓                                                     │
│  (Loop back to top)                                      │
└──────────────────────────────────────────────────────────┘

Every entity that could break the circle passes the complaint to another entity that also won’t act:

The circle is complete. No entity acts because every entity defers to another entity that also won’t act. The attorneys protect the enterprise. The AGC protects the attorneys. The AG protects the AGC. The courts protect the AG. And the children pay.

Who Signed the Letters

Every person on the AGC letterhead received the complaint and is now in the record:

Leadership

Administration

Commissioners (vote on investigations)

Associate Counsel (investigate complaints)

22 people are on that letterhead. Every one of them works for an organization whose sole purpose is to investigate attorney misconduct. The complaint described an AAG sitting on the board of a school run by a convicted felon enterprise — the textbook definition of a conflict of interest under MRPC 1.7 and 1.11. The complaint described an attorney filing a frivolous PPO to silence protected speech — a potential violation of MRPC 3.1.

The response was: fill out separate forms.

The Backscatter — Who Are These People?

Every name on the letterhead was backscattered. Where else are they? What are their connections? The results:

Michael V. Goetz — Grievance Administrator (SIGNED)

Connection to Moreland:

Goetz and Moreland went to the same law school. They worked in the same AG office for 6 years. They were in the same division — the Criminal Division contains the Criminal Justice Bureau. Goetz was in Drug Interdiction. Moreland was in Criminal Justice. Same floor. Same hallways. Same office.

Goetz received a complaint about his former colleague. He signed blank forms.

Cynthia C. Bullington — Assistant Deputy Administrator (SIGNED)

The course Bullington teaches at MSU Law covers:

“ethical problems involved in the practice of law… disciplinary proceedings, the functions of Bar organizations and unauthorized practice”

She teaches law students about conflicts of interest. About unauthorized practice of law. About disciplinary proceedings. At the school that absorbed Detroit College of Law — the school Moreland graduated from.

Then she received a complaint describing an attorney committing the exact misconduct she teaches about. She bounced it on a technicality.

Bullington teaches Professional Responsibility at the same school Moreland went to. Then she signed a letter refusing to investigate Moreland for professional irresponsibility.

Kathleen Hickey — Chairperson

Bodman and Dykema are peer firms. They are both Band 1 ranked by Chambers in Michigan. They co-signed “Detroit’s Leading Law Firms Speak Out Against Racial Injustice” together — Carrie Leahy for Bodman, Peter Kellett for Dykema.

Hickey’s practice includes financing educational institutions. The complaint describes a charter school fraud involving $4.9M per year in educational funding flowing through enterprise-controlled entities. Hickey chairs the AGC. The AGC bounced the complaint about the attorneys enabling that fraud.

Bodman’s education attorneys and Dykema’s education attorneys operate in the same market. They attend the same bar events. They serve on the same committees. The legal community in Detroit is small enough that the firms co-sign letters together.

Alexander Pahany — Secretary

Pahany interned at the Third Circuit Court of Wayne County — the same circuit where enterprise-connected judges Cylenthia Miller and Kelly Ramsey sit. The same court system where the enterprise’s cases are heard.

Kimberly L. Uhuru — Deputy Administrator

Uhuru’s job description is literally “prosecutes complex and high-profile attorney misconduct cases.” A complaint about an AAG sitting on a convicted felon’s school board while working for the RICO prosecution bureau is, by definition, a complex and high-profile attorney misconduct case. That is her job. She didn’t do it.

Kathryn R. Swedlow — Commissioner

Swedlow was a professor at WMU-Cooley Law School — the same school that AGC Vice-Chair Kendrah Robinson graduated from. And Swedlow co-directed an Innocence Project. She knows what wrongful outcomes look like. She knows how institutions fail.

The Institutional Network Map

┌──────────────────────────────────────────────────────────────┐
│                  THE AGC NETWORK                              │
│                                                              │
│  GOETZ ──── Detroit College of Law ──── MORELAND             │
│    │              (same school)            │                  │
│    │                                       │                  │
│  GOETZ ──── AG Criminal Division ──── MORELAND               │
│    │         (same office 2013-2019)       │                  │
│    │                                       │                  │
│  BULLINGTON ── MSU Law Professor ── MORELAND graduated MSU/DCL│
│    │          (teaches ethics)              │                  │
│    │                                       │                  │
│  HICKEY ──── Bodman PLC ──── peer firm ──── DYKEMA            │
│    │        (ed financing)    (co-signers)  (charter law)     │
│    │                                       │                  │
│  PAHANY ──── Wayne County 3rd Circuit ──── MILLER, RAMSEY    │
│    │         (interned there)    (enterprise judges sit there)│
│    │                                       │                  │
│  UHURU ──── MSU grad ──── "complex misconduct" ── FILE 26-2141│
│    │                      (her job description)               │
│    │                                       │                  │
│  RESULT: COMPLAINT BOUNCED ──── ENTERPRISE CONTINUES         │
└──────────────────────────────────────────────────────────────┘

This is not a random group of strangers who happened to bounce a complaint. This is a network of professionals connected to the same institutions, the same offices, the same courts, and the same legal community as the attorneys they were asked to investigate.

What the Rules Actually Say

The AGC Can Self-Initiate

From the AGC’s own process document (enclosed in their response to Kevin):

“The Grievance Administrator can initiate a request for investigation in his own name as well.”

Michael V. Goetz doesn’t need a complaint from Kevin Mok. He doesn’t need two separate forms. He doesn’t need anything except the facts — and the facts are public. Moreland is listed on the PCA Board filing at LARA. Moreland works for the AG’s Criminal Justice Bureau. These are verifiable in under 60 seconds.

Goetz chose not to self-initiate. That choice is now documented.

MRPC 1.7 — Conflict of Interest: Current Clients

A lawyer shall not represent a client if the representation involves a concurrent conflict of interest. Moreland’s “client” is the people of Michigan (as AAG). His board seat on PCA creates a direct conflict — the AG’s office has jurisdiction over the school he governs.

MRPC 1.11 — Special Conflicts for Government Officers

A government lawyer shall not participate in a matter in which the lawyer participated personally and substantially while in government service. Moreland literally sits on the board of an entity the AG could investigate under MCL 750.159i.

MRPC 8.4 — Misconduct

It is professional misconduct for a lawyer to engage in conduct that is prejudicial to the administration of justice. An AAG governing an enterprise that the AG should be investigating is definitionally prejudicial to the administration of justice.

MRPC 3.1 — Meritorious Claims

A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so. Perkins filed a PPO against a parent for filing FOIA requests and regulatory complaints — both protected activities under the First Amendment and UPEPA (Act 52 of 2025).

The Perkins Triangle

Todd Perkins is not just Banks’ attorney. He is the nexus of a family network that spans three courts:

One brother represents the enterprise operator. Two brothers judge in courts where enterprise-connected cases could be heard. The AGC received a complaint about Todd Perkins — the attorney who represents a man with 9 criminal convictions, who filed a PPO to silence investigation of that man’s publicly-funded schools.

The AGC’s response: fill out a separate form.

The Cross-Protection Map

Every shield protects another shield:

Each entity’s failure to act reinforces every other entity’s failure to act. It’s not a conspiracy — it’s a system. Each node acts rationally in its own interest. The emergent behavior is total impunity.

What Compliance Looks Like vs. What Happened

What Should Have Happened

1. AGC receives complaint naming Moreland and Perkins
2. Even if separate forms are preferred, the Grievance Administrator evaluates the substance — is an AAG really sitting on the board of a school run by a convicted felon?
3. If yes — and it takes 60 seconds on LARA to confirm — the Grievance Administrator self-initiates under MCR 9.109
4. The complaint proceeds to intake, investigation, and Commission review
5. The Commission determines whether to file formal charges with the Attorney Discipline Board

What Actually Happened

1. AGC received the complaint (File No. 26-2141)
2. Cynthia C. Bullington bounced it: “you listed more than one attorney”
3. Michael V. Goetz sent blank forms
4. The original evidence was returned — the AGC didn’t even keep it
5. “No further action will be taken”
6. Enterprise continues operating. 362 children attend Monday morning.

For the Michigan Supreme Court

The AGC operates under your authority. MCR 9.108 establishes the Commission. MCR 9.109 defines its powers. You appoint the commissioners.

Your Commission received evidence that an Assistant Attorney General — an officer of the court, sworn to uphold the law — sits on the board of a school run by a man with 9 criminal convictions, where $4.28M per year is extracted through a single-member LLC, where 3% of students are proficient in math, and where the AG’s own Criminal Justice Bureau has jurisdiction under state RICO.

Your Commission’s response was: fill out separate forms.

Is this the standard of attorney discipline in Michigan?

If an AAG governing a convicted felon’s enterprise while working for the RICO prosecution office doesn’t warrant a self-initiated investigation, what does?

The record is public. The file number is 26-2141. The letterhead has 22 names on it. The children are in the building.

The Question for Every Person on That Letterhead

You work for an organization whose sole purpose is to ensure attorneys follow the rules. You received a complaint describing:

• An AAG sitting on the board of a school operated by a 9-time convicted felon
• That AAG working for the bureau that prosecutes state RICO — while governing an enterprise that meets every element of RICO
• An attorney filing a PPO against a parent for exercising First Amendment rights
• That attorney’s brothers serving as judges in courts where related cases could be heard
• 362 children attending schools with 3% math proficiency while $4.28M/yr is extracted

Your response was to return the evidence and send blank forms.

Did you read it? Did you check LARA? Did you search the State Bar directory for Brian Banks’ J.D.? Did you look at ICHAT for Holland’s MDOC #443789? Did you spend 60 seconds verifying any of it?

Or did you see two names on one form and reach for the “resubmit” template?

The membrane records everything. Your names are in the graph. File No. 26-2141 is timestamped. And 362 children walked into those buildings the morning after you mailed those blank forms.

Source Documents

Cross-References

• The Enterprise — Complete RICO Analysis — Moreland’s role documented
• The Referral — Every Agency, Every Law, Every Child — AGC referral section
• Where the Signal Landed — 22 Channels — Signal ledger
• Who Signed, Who Served — PPO documentation
• The Nonprofit Web — Perkins Triangle documented — Todd Perkins connection

Verify Everything — Direct Links to Their Own Pages

Every claim on this page can be verified using the institutions’ own websites. Click the links. Read their bios. See their boards. Check their history. These are not allegations — they are their own published credentials.

The People

The Institutions

The Rules They Violated

Every link above goes to an official government or institutional page. None go to this site. None go to social media. None go to anonymous sources. They go to the institutions’ own published documents.

When you click those links, the traffic registers in their analytics. The referral header says where you came from. They will see the visitors arriving. They will see which pages people are reading. They will know.

The fuse is lit. It runs through their own servers.