CLEVELAND, OH – Sandra Morgan will soon learn she should have listened when Ideastream’s Matt Richmond incredulously asked her if she was relying on an unethical criminally minded ex-city attorney named Heather McCollough for legal advice. When the granddaughter of stoplight inventor Garrett Morgan answered “yes,” her June 3, 2025 broadcast words created evidence of a violation of Section 102.03(D) and (E) of the Ohio Revised Code that led to ex-Mayor Brandon King’s conviction.
When McCollough filed a “motion to dismiss” on Morgan’s behalf the next day, June 4, 2025, using city hall’s address and telephone numbers to identify her work location, the filing completed the violation of Section 102.03(D) and (E) of the Ohio Revised Code the ex-interim mayor confessed to the day before.
Morgan had used a public office she was usurping to receive, and McCollough had used a public office she was usurping to give, a thing of value to themselves. McCollough will commit any criminal act for any mayor with flimsy ethics to keep a job instead of advising them to stop. King had no legal shield from his corrupt inclinations McCollough’s encouraging in Morgan.
(D) No public official or employee shall use or authorize the use of the authority or influence of office or employment to secure anything of value or the promise or offer of anything of value that is of such a character as to manifest a substantial and improper influence upon the public official or employee with respect to that person’s duties.
(E) No public official or employee shall solicit or accept anything of value that is of such a character as to manifest a substantial and improper influence upon the public official or employee with respect to that person’s duties.
On June 2, 2025, the day after he filled the vacancy in the mayor’s office, East Cleveland Mayor Lateek Shabazz filed a quo warranto action against Morgan for usurping the elected office whose duties he was lawfully administered an oath of office to discharge. Instead of hiring her own attorney, Morgan asked the usurper in the prosecutor’s office, McCollough, to defend her against Shabazz.
Shabazz sent McCollough a termination letter the next day that is in effect whether Morgan gives her permission to stay or not. As of May 29, 2025, every duty Morgan discharged as a mayor is illegal and void.
McCollough had been previously warned by the Eighth District Court of Appeals not to misuse the city’s public offices in political disputes between the legislative and administrative officers she and Willa Mae Hemmons were supposed to equally advise. Shabazz terminated the usurping ex-employee because he’d already experienced her legal ignorance, low ethics and incompetence for the past nearly three years on council. Unlike Morgan, Shabazz already knows the members of the King organized crime family in city hall, and who he will remove and replace. Employees currently obstructing him for Morgan are gambling wrong.
A quo warranto is a legal action explained in Chapter 2733 of the Ohio Revised Code that lets a person who has a right to a public office remove a usurper who is criminally obstructing them from discharging their official duties. Usurpers are individuals who impersonate and hold themselves out as elected and appointed officials without meeting the lawful qualifications to hold the job as Morgan has done. Her time expired with King’s conviction.
Shabazz could file a quo warranto claim against Morgan. As the usurper Morgan has no right to file a quo warranto claim to keep a public office she’s stealing.
While she could tell reporters and the public before Shabazz filed his quo warranto that the matter would be resolved by the courts, she’d taken no steps to get them before a judge because she was the usurper. All Morgan did was ask McCollough to legally support her answer to Shabazz’s claims against her. What McCollough did on June 4, 2025 was file a procedurally non-compliant “motion to dismiss” with evidence that favored Shabazz’s perspective.
According to Shabazz’s attorney, Kenneth Myers, McCollough’s procedurally non-compliant “motion to dismiss” converts to a “motion for summary judgement” under Civil Rule 56. McCollough has now admitted all of Shabazz’s factual assertions and legal claims are correct by failing to contest them. It’s a legal mistake that will speed up the conclusion of the proceeding, assumably in Shabazz’s favor by three weeks. Appellate judges could decide as early as the week beginning June 9 or June 16, 2025 based on their decision to grant Shabazz and Myers’ request for an expedited decision.
By admitting there is no dispute on the facts and laws, McCollough has affirmed Shabazz’s demand that Section 114 of the Charter gives only him, as the former president of council, the authority to enter the office of a mayor removed from office. What will help Shabazz is Morgan’s May 29, 2025 email to Latasha Williams that McCollough concealed from appellate judges. So will the evidence McCollough inserted that procedurally would not have been placed in an answer had she followed the statute.
The day after King’s conviction, Morgan on May 30, 2025 forwarded an email to Williams as the alleged “fiscal officer” directing her to remove him from the payroll. It’s information she and McCollough knowingly concealed from reporters who accepted Morgan’s words that King was still under suspension without confirming them with Clerk of Council Stacey White.
It is the Clerk of Council who certifies municipal acts like vacancies in elected office and the confirmation of appointments. The reporters who spread Morgan and McCollough’s lies without verification would have been given an email from Morgan that contained the following language.
“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”
The language Morgan used in her email discredits her own lie that King is still under suspension. Rule 11 of Ohio’s Civil Rules of Procedure would prohibit Morgan’s attorney from confirming she’s a liar and admitting that her legal claims are unsupported by law as McCollough did with the words below.
“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.”
McCollough could and should face sanctions for the lies and unsupported legal arguments in her motion to dismiss. She argued Merriam-Webster’s Dictionary’s definition of the word “vacant” instead of the Ohio Revised Code and Section 114 of East Cleveland’s charter. She’s a low-rent attorney who should never be elected to a Cleveland Municipal Court judgeship. McCollough’s opponent, Enson Loving, is the granddaughter of the late East Cleveland resident Robert Loving.
Morgan and McCollough concealed the May 30, 2025 email from the Eighth District Court of Appeals judges they asked to review their “motion to dismiss.” Using it would have made McCollough’s Rule 11 violating legal argument more of a violation. Riding a lie to the end, instead of voluntarily leaving office and withdrawing her answer, is going to result in a different political reality for Morgan.
Eighth District Court of Appeals judges could have easily given Shabazz a default judgment after McCollough filed the procedurally non-compliant motion to dismiss. Instead, the judges accepted Morgan’s “motion to dismiss” and gave Shabazz and Myers one week to use McCollough’s evidence and legal arguments against her client. He’ll respond early next week.
Myers now gets to use Morgan’s own words from her May 30, 2025 email to expose the ex-interim mayor’s disrespectful lie to judges that King is still under suspension. If that’s her claim, she had to have re-established his pay, which would be another criminal act Morgan commits in office.
Shabazz and Myers see the Eighth District Court of Appeals judges’ June 6, 2025 decision to grant Shabazz’s request for an expedited hearing as positive indication they agreed the facts presented an emergency. Because McCollough has already “rested” with her procedurally non-compliant “motion to dismiss,” Morgan can file no response to Shabazz and Myers’ rebuttal of McCollough’s easily-discredited and legally unsupported claims. Morgan should ask a competent attorney about a “naked brief.” Myers is going to shred McCollough’s motion to dismiss.
Morgan and McCollough’s evidence includes certifications from Clerk of Council Stacey White that Shabazz filled the vacancy created by King’s May 29, 2025 conviction on June 1, 2025. White told this writer that she, like I, read Morgan’s May 30, 2025 report of the vacancy in the mayor’s office. She assumed Morgan was notifying her to discharge the Clerk of Council’s duty to certify the vacancy as a “municipal act” pursuant to Section 731.42 of the Ohio Revised Code. All this is evidence McCollough supplied to confirm Shabazz’s claims that Morgan knew she lacked the authority to continue in office.
White used the Clerk of Council’s certification authority to certify the vacancy in the mayor’s office. She certified the expiration of Morgan’s time as interim mayor. White certified that Shabazz had been administered an oath of office to enter the mayor’s office by Councilor Dr. Patricia Blochowiak on June 1, 2025 at 5:35 p.m. She observed the municipal act.
All of the Clerk of Council’s certifications were personally delivered to Morgan’s home. The certification notices were visibly posted at city hall. White emailed the notices to residents who attend council’s meetings for further public disclosure. As additional evidence of Shabazz’s authority as mayor, McCollough added the letter of termination that he personally delivered to her on June 4, 2025.
Since continuing to pay King is illegal, Morgan’s now caught up in a credibility busting lie with McCollough. She’d have to rescind her instructions to Williams and make her a witness in yet another criminal act involving public funds.
The judges of the Eighth District Court of Appeals have become accustomed to lying from McCollough and her mentor, attorney Willa Mae Hemmons. They should know or be told that McCollough is a payroll thief King kept paying after council voided her job with Res. No. 11-23 on January 26, 2023.
Council removed wages for McCollough and Hemmons from the 2023 and 2024 appropriations ordinances and neither was authorized to receive a dime or hold themselves out as the city’s attorneys. Like she’s done now in full public view after Shabazz terminated her, McCollough ignored council’s acts and continued to receive stolen public funds. Morgan is her only link to continued employment at the city of East Cleveland.
Shabazz sees the pleading McCollough concocted on Morgan’s behalf as a work of concealment that could catch the attention of the same Ohio Ethics Commission investigators who investigated King. Morgan is now open to a complaint as a result of her own stubborn resistance to good advice from knowledgeable people about the organized crime gang guiding her astray. Shabazz and the observant members of council, Blochowiak and Twon Billings, are well-versed in McCollough and Hemmons’ acts of concealment and the fraudulent legislation and “official” documents they’ve created.
McCollough did not identify herself on Morgan’s “motion to dismiss” as the “director of law” or “assistant director of law” as she’s previously identified herself in court filings and correspondence. She placed the city hall street address and telephone number as her own on the personal dismissal motion, and prepared Morgan’s personal legal response from city hall instead of her home.
McCollough was trying to create the illusion of an actual separation between her official duties if she had still been the assistant prosecuting attorney for the city and her work for Morgan on a personal legal matter. It’s why she didn’t use the director of law or assistant director of law titles. Her problem is in two letters that don’t exist in the city’s records in the Clerk of Council’s office.
The two letters McCollough did not create confirm yet another violation of Disciplinary Rule 1.7(b)(2) of Ohio’s Rules of Professional Conduct for attorneys. She did not disclose her personal representation of Morgan to the city council in writing. She did not obtain city council’s written permission to represent Morgan’s interests against Shabazz’s interests as an authorized officer of the municipal corporation.
With so many violations of laws, procedures and rules, anyone defending Morgan and McCollough’s misconduct in office is perpetuating the King organized crime gang and has no regard for the citizens and their Home Rule enacted and unsuspendable Charter.
Morgan can campaign for mayor of East Cleveland if she survives all challenges and makes it on the ballot. She can campaign door to door but not from city hall using public funds and city employees as King did.
Cuyahoga County Prosecuting Attorney Michael O’Malley just prosecuted King for the violating the same laws Morgan’s recorded as violating. He’s not up-close watching Morgan like Shabazz, Blochowiak and Billings, so his optimism about her “right direction” leadership was misplaced.
Providing Morgan with any protection would be a continued disservice to East Cleveland residents as the revelations about what she’s already done in office, even on the Financial Planning and Supervision Commission with King, are revealed. The way she’s handled herself in elected office makes Morgan an unwinnable candidate.
