The Wisconsin Supreme Court issued a 30-month suspension for attorney John P. Buran after he admitted to forging witness signatures on estate planning documents, rejecting both a referee's recommendation for a shorter suspension and the Office of Lawyer Regulation's request for complete license revocation.
Attorney Buran, who has practiced law in Manitowoc since his admission to the Wisconsin bar in September 1990, committed professional misconduct by forging the name of a former employee of his law firm as a witness to nine wills. He then submitted six of those fraudulent documents to probate court, according to the disciplinary complaint filed by the Office of Lawyer Regulation.
The case, decided Aug. 14, 2025, in *Office of Lawyer Regulation v. John P. Buran* (2025 WI 40), centered not on whether misconduct occurred but on the appropriate level of discipline. Buran admitted to almost all substantive factual allegations in the three-count complaint, though he did not admit that his conduct violated applicable Rules of Professional Conduct.
Referee Sue E. Bischel initially recommended an 18-month suspension of Buran's law license. However, the Office of Lawyer Regulation appealed that recommendation, seeking the complete revocation of his license to practice law in Wisconsin.
In its per curiam decision, the Wisconsin Supreme Court found that complete revocation was "unsupported by our prior disciplinary decisions." The court concluded that while Buran's conduct was serious enough to warrant significant discipline, the particular facts of the case fell short of justifying license revocation.
"The dispute in this matter centers on the appropriate level of discipline to be imposed," the court wrote, noting there was no dispute about the underlying misconduct.
The court ultimately settled on a 30-month suspension, finding this penalty appropriately balanced the seriousness of the misconduct with established precedent in similar disciplinary cases. This represents a significant increase from the referee's initial 18-month recommendation but stops short of the permanent revocation sought by regulators.
Buran's misconduct involved estate planning work, an area of law where client trust and document integrity are paramount. By forging witness signatures on wills, Buran potentially compromised the validity of these critical legal documents and violated the trust placed in him by clients seeking to ensure their final wishes would be properly executed.
The forgery of witness signatures on wills raises particular concerns because witness attestation serves as a crucial safeguard in estate planning. Wisconsin law, like that in most states, requires witnesses to observe the testator signing their will and then sign the document themselves to verify the testator's mental capacity and freedom from coercion.
When Buran submitted six of the fraudulently witnessed wills to probate court, he compounded his initial misconduct by presenting potentially invalid documents to the judicial system. This action could have led to improper distribution of estates and legal challenges from beneficiaries or excluded heirs.
The case highlights the Wisconsin Supreme Court's approach to attorney discipline, which considers both the severity of misconduct and consistency with prior disciplinary decisions. The court's rejection of the OLR's revocation request suggests that while document forgery in estate planning is serious, it did not rise to the level of misconduct typically warranting permanent disbarment.
Buran had no prior disciplinary history during his 35-year legal career, which likely factored into the court's decision to impose suspension rather than revocation. First-time disciplinary offenses, even serious ones, often result in suspension rather than permanent license revocation, particularly when the attorney admits wrongdoing.
The 30-month suspension means Buran cannot practice law in Wisconsin until the suspension period expires and he meets any additional requirements for reinstatement. During the suspension, he cannot represent clients, provide legal advice, or hold himself out as an attorney in Wisconsin.
The decision serves as a reminder to attorneys about the critical importance of maintaining integrity in document preparation and execution, particularly in estate planning matters where families depend on the validity of legal instruments to carry out their loved ones' final wishes.
For the legal profession, the case underscores that even attorneys with clean disciplinary records face serious consequences for document fraud. The court's measured approach in determining the appropriate penalty reflects the balance between protecting the public and maintaining proportionality in professional discipline.
The Office of Lawyer Regulation's appeal of the initial 18-month recommendation demonstrates the agency's commitment to ensuring adequate deterrence for serious misconduct, even when seeking the most severe penalty available was ultimately unsuccessful.