CLEVELAND, OH – In order to sell her creative lie that the office of East Cleveland’s mayor is not vacant, and that convicted ex-mayor Brandon L. King is still under suspension until his appeal rights are exhausted, mayor’s office usurper Sandra F. Morgan has to direct employees to place the convict back on the payroll of a city in fiscal emergency. It’s the only way her lie will work.
If the claims in the quo warranto Cuyahoga County Prosecuting Attorney Michael O’Malley filed against East Cleveland Mayor Lateek R. Shabazz for Morgan are to be believed, the private citizen usurping the mayor’s office will be paid until the November 2025 election, and the political thief will be paid long after he’s in prison. This conundrum is what happens when officials get caught in a public lie in court.
O’Malley’s quo warranto for Morgan challenges Shabazz’s lawful claim to the mayor’s office. He submitted it after Shabazz filed a June 2, 2025 quo warranto seeking Morgan’s removal from the mayor’s office Section 114 of East Cleveland’s charter instructs the president of council to assume. Morgan is not even a member of council and has never campaigned for an elective office in East Cleveland.
The problem for O’Malley is last year he was assigned by the same Cuyahoga County Probate Court that appointed Morgan as interim mayor to represent Shabazz in a misfeasance and malfeasance in office complaint against King. To now represent Morgan, he needed Shabazz’s written permission.
The attorney assigned to help O’Malley back the usurper, Assistant Prosecutor Regina A. Russo, submitted a pleading they hoped would support the “motion to dismiss” Morgan’s attorney, Heather McCollough, submitted as a procedurally wrong answer to Shabazz’s quo warranto. Instead of filing an “answer” to Shabazz’s quo warranto, McCollough’s motion to dismiss admitted all of Shabazz’s facts and laws were correct.
Russo appears not to have considered Civil Rule 11’s demands that an attorney’s signature on a pleading means her arguments are supported by law when she filed it. There isn’t a law in the Constitution of Ohio, Ohio Revised Code or East Cleveland’s charter and ordinances O’Malley’s assistant prosecutor quoted to support Morgan’s outrageous reasons for creating a paper trail of crimes she’s committed from an elected office she’s usurped since May 29, 2025.
“King was convicted but he hasn’t even been sentenced yet. He is likely to appeal his conviction and the election will not be held until November of 2025. Therefore, Brandon King is still under suspension. He has not been “removed”, the mayor’s seat is not vacant and Sandra Morgan is still interim Mayor. Even if R.C. 3.16 didn’t clearly state that King was still under suspension, the mayor’s seat is not vacant. Merriam-Webster’s Dictionary defines vacant as “not occupied by an incumbent, possessor or officer.” Sandra Morgan took office March 3, 2025 and has continued to possess the office and conduct the business of the city as mayor ever since.”
Russo pretty much offered the same insane legal argument Morgan and McCollough concocted as a response to Shabazz’s quo warranto to avoid obeying a charter a “home rule city” mayor has a duty to obey and enforce.
Shabazz was administered an oath of office by Councilor Dr. Patricia Blochowiak to assume the mayor’s office Section 114 of the Charter authorized him to enter on June 1, 2025. Morgan was notified the same day by Clerk of Council Stacey White that the mayor’s office vacancy reported to her by email on May 30, 2025 had been filled.
When Morgan refused to step down on June 2, 2025, Shabazz and attorney Kenneth Myers filed a quo warranto seeking her removal the same day. The granddaughter of famed inventor Garrett Morgan, like another private citizen named Mark McClain, wanted to deprive Shabazz of a job for a second time that only he is lawfully authorized to hold. The Eighth District Court of Appeals ruled against McClain and Nathaniel Martin’s untimely quo warranto complaints in 2023.
Morgan’s motivation for her usurpation is she wants to campaign for mayor from the mayor’s office using city employees in violation of Section 3517.092 of the Ohio Revised Code. The political novice doesn’t know she’s prohibited from soliciting “things of value” from the taxpayer paid workers she supervises. Extortion. Coercion.
The petitions residents said they signed in the city hall mayor’s office she’s illegally occupying could be tossed if they come forward with affidavits. Morgan wants to use city hall for politics the same way King did over the past eight years. She’s telling residents and reporters of her campaign for mayor from city hall.
The same Eighth District Court of Appeals that declared Shabazz the rightful holder of the Ward 3 council seat in McClain’s quo warranto against him will decide his fate against Morgan’s unlawful demand for his job of mayor with O’Malley’s backing. Assistant prosecutor Russo’s words cast shade on her credibility as an attorney since they directly contradict her boss, O’Malley’s, own May 29, 2025 statement after King’s conviction. O’Malley declared the office of East Cleveland mayor to be vacant.
“As a result of the conviction, Brandon King will not be reinstated as the mayor of East Cleveland and will be disqualified from public office for seven years from the date of conviction,” O’Malley said.
Russo’s argument also contradicts Morgan’s own acknowledgement that the office of mayor was vacant in a May 30, 2025 to the temporary agency payroll clerk King appointed finance director, Latasha Williams, instructing her to remove him from the payroll. Neither Russo nor McCollough shared Morgan’s exculpatory email with the appellate judges. The words below stimulated Clerk of Council White to certify the mayor’s office vacancy.
“Dear Latasha: I hope you are well. As you know, former Mayor Brandon King was found guilty of 10 counts yesterday and is now awaiting sentencing. He is effectively no longer Mayor of East Cleveland, and as such, is no longer entitled to salary payments. Therefore, please end payment to Brandon King as of Thursday, May 29, 2025. He is officially separated from employment at the City of East Cleveland. Please copy Mansell, Heather, and me with final details of his payment for our records, along with any request for payment of sick time, etc. Thanks, Sandra”
Shabazz and Myers note how Morgan through McCollough created and now peddle an impossible argument that completely contradicts facts and laws. The two did not offer a single law to support McCollough’s dumb claim that because Morgan is illegally filling a vacancy Section 114 of East Cleveland’s charter demands be filled by the president of council, and McCollough thinks she’s doing a good job, the mayor’s office won’t be vacant until she either wins the November election or a new mayor is elected to replace her.
That’s their dumb interpretation of Cuyahoga County Probate Court Judge Anthony Russo’s order of appointment. It’s the one with which they stuck O’Malley and Assistant Prosecutor Russo to repeat. Shabazz attorney, Myers, had to remind O’Malley and McCollough of Section 2961.02(B) of the Ohio Revised Code.
“Any person who pleads guilty to a disqualifying offense and whose plea is accepted by the court or any person against whom a verdict or finding of guilt for committing a disqualifying offense is returned is incompetent to hold a public office or position of public employment or to serve as a volunteer, if holding the public office or position of public employment or serving as the volunteer involves substantial management or control over the property of a state agency, political subdivision, or private entity.”
It’s obvious that Morgan, O’Malley, McCollough and Russo are cherry picking through language in Section 3.16 of the Charter they believe supports their flawed conclusions while ignoring the sections that don’t. They’re desperately arguing “Webster’s” dictionary instead of the Ohio Revised Code by acting as if Section 3.16(E)(5) doesn’t exist. Judge Russo, just like Shabazz and Myers in their response to Morgan and O’Malley, also identified Section 3.16(E)(5) as one of the guiding instructions in his February 28, 2025 order. Morgan acts as if the words below don’t exist.
“If the office of the suspended public official becomes vacant during the period of suspension, a public official shall be appointed or elected to fill such vacancy as provided by law. If a regular election is to occur during the period of suspension, a public official shall be elected as provided by law.”
Shabazz and Myers argue that Section 2961.02(B) of the Ohio Revised Code created a vacancy in the office of a suspended official charged with a felony that is required to be filled in the manner spelled out by law. The suspension ended with King’s conviction and the vacancy filling law is Section 114 of East Cleveland’s charter designated the president of council as King’s successor.
“During the time when the Mayor is absent from the city, or is otherwise not accessible, or is temporarily unable for any cause to perform his or her duties, the order of succession as Acting Mayor shall be as follows: Director of Finance, Director of Law, and the Director of Public Service. In the case of death, resignation, removal or long-term absence of the Mayor, the order of succession as Mayor shall be as follows: President of Council, Vice President of Council and ranking Council member based upon aggregate years of service …”
Not only does “home rule” East Cleveland’s charter conclude that the president of council replaces a mayor whose office has been vacated, the instruction is consistent with Section 731.31(A)(1) of the Ohio Revised Code, “Filling vacancies in elective and appointed offices.” It sets forth that “vacancies in the office of mayor shall be filled in the manner provided by section 733.25 of the Revised Code.”
A plain reading of Section 731.25 of the Ohio Revised Code refers to villages but applies to Dillon’s Rule or statutory cities as well. The president of council, not a private citizen with no knowledge of the municipal government who is appointed by a judge, replaces a mayor.
A reading of the law shows there is no conflict with state laws on which official has the right to the mayor’s office. Even if a conflict existed, courts all over Ohio have upheld that a home rule city’s charter prevails according to State ex rel. Bardo v. City of Lyndhurst, 37 Ohio St. 3d 106 (1988).
“The general rule is that in matters of local self-government, if there is a conflict between a charter provision and a statute, the charter provision prevails. State, ex rel. Devine, v. Hoermle (1959), 168 Ohio St. 461, 7 O.O. 2d 284, 156 N.E. 2d 131; State, ex rel. Allison, v. Jones (1960), 170 Ohio St. 323, 10 O.O. 2d 417, 164 N.E. 2d 417.”
Russo’s quo warranto pleading on behalf of O’Malley seeks to obstruct Shabazz’s succession to the office vacated by King’s May 29, 2025 conviction. He favors Morgan until the November 2025 election. It is a direct attack on “local self government.”
O’Malley should be concerned that the county’s interim puppet mayor has kept much of King’s organized crime gang intact and is violating the same sections of East Cleveland’s charter, ordinances and Ohio laws that King violated. The effect on the city’s government and residents is not good. A payroll clerk is handling the city’s finances from home. Seriously.
Shabazz and Myers have argued that O’Malley has no “standing” to file a complaint against him. He can’t use the prosecutor’s office to support a candidate for East Cleveland mayor who’s using the taxpayer paid city employees she supervises as campaign workers even on their own time. It creates a conflict if he’s asked to prosecute her, or if her unlawful campaign acts are challenged in a Board of Elections complaint and another assistant prosecutor is drawn into the interest conflicting drama.
How Russo avoids a Rule 11 complaint before the Supreme Court of Ohio’s disciplinary counsel, for signing her name to a pleading that is supported by no laws, will only be if no one files it. Russo and McCollough could each face challenges to their law licenses for arguing against laws Article 15, Section 7 of the Constitution of Ohio does not give them the authority to suspend.
“There shall be no suspension of laws but by the General Assembly.”
Russo may have dug herself into a deeper Civil Rule 11 violating hole with her unsupported claim that Shabazz may not be the president of council because he’s not an at-large member of the legislative authority. She obviously didn’t read Ord. No. 111.01(d) when she repeated an argument no member of the legislative authority accepted last October 2024 when Shabazz was voted by a majority of three to replace Councilor Twon Billings as council’s president.
“Nominations. Any Council member shall be qualified to nominate any other Council member or himself or herself for the office of President or Vice President and no second shall be required. The nominations and election of the President shall first be completed before proceeding with the nomination and election of the Vice President.”
What assistant prosecutor Russo did was misread Section 102 of East Cleveland’s charter.
“The President of Council, in addition to the Council’s obligations, rights, and duties as a Councilperson at large, shall preside at all meetings and shall perform such duties as may be imposed upon him or her by the Council.”
All five of East Cleveland’s councilmembers were elected at-large until voters in 2000 decided to amend Section 98 of the Charter to divide the city into three wards with a councilperson for each ward. Borders for wards 2, 3 and 4 were drawn so that every ward councilor represented a portion of each of the city’s neighborhood from the Forest Hills section to the Hayden area and in between.
Voters gave two members of council at-large duties. Instead of representing only his or her ward, the president of council was given the rights and duties as a council person at-large. They wanted each ward councilperson to have a sensitivity for every resident’s interests regardless of income status.
There’s a reason successful elected officials surround themselves with specialists who know vastly more than they. Morgan lacks the depth of city hall perspective like Shabazz does to know King handpicked employees for their lack of knowledge and susceptibility to his unlawful orders. King didn’t want ethical legal minds that knew more than Hemmons and McCollough advising him to stop stealing. He needed obstructionist minded attorneys to help him conceal his thefts.
King knew he could rely on McCollough and Hemmons to tamper with public records and create sham legal documents like the quo warranto she filed for Morgan. It explains why McCollough didn’t sign as the “assistant director of law.” She thought it concealed her conflicting role as Morgan’s “personal” attorney. McCollough gave herself away by using city hall’s address instead of her personal address.
McCollough’s refusal to obey East Cleveland’s charter and ordinances is why Shabazz voted to vacate both her and Hemmons’ offices on January 26, 2023, and refused to fund wages for them in the 2023 and 2024 appropriations ordinances. He knew they were trash attorneys who criminally obstructed council like McCollough’s doing for Morgan like she did for King.
McCollough knows she’s already been fired as soon as Shabazz walks in the door. A Shabazz appointed law director will review her conduct through a more statutory lens.
Anyone who can read, and who’s read this far, can see all laws support Shabazz’s claim to the mayor’s office and that Morgan is a stubborn usurper.
If the Eighth District Court of Appeals is guided by the home rule laws it’s already affirmed in numerous other rulings, and not politics, Shabazz will prevail. Morgan will be out and she will have confirmed to voters she’s no different than King, and that she’s keeping the same ratchet-azzed members of his crime gang, right before the September 2025 primary election.
If the Eighth District Court of Appeals rules in Shabazz’s favor, everything Morgan’s done since May 29, 2025 will be void ab initio (from the beginning) because she acted beyond her powers or ultra vires. All the contracts she signed, employees she hired, legislation she signed are void.
Employees were told to stay out of politics and follow laws not a crooked mayor. Before he’s indicted, Kenneth Lundy should not add to his troubles and must restore Mayor Shabazz’s key fob access to city hall. Latasha Williams had no authority to obstruct payment of his wages. One member of council has no authority outside of a council meeting where they’re talking and voting. Council members do not “direct” administrative employees. Taking orders from a council member obstructs the mayor’s authority.
Every employee and official of the city of East Cleveland has a duty to ensure that Section 114 of the Charter is enforced. Those who don’t understand the Charter controls their conduct by the oath of office they were required to take, whether they did or did not, should not work for a municipal government.
Morgan is not East Cleveland’s mayor. McCollough is not the assistant director of law.
