This proceeding centers on whether the State Bar’s five-year limitations rule barred a disciplinary charge alleging moral turpitude by misappropriation arising from a film-financing deal. The complaining witness invested funds for a movie, and Saxon agreed to hold those funds in trust pending completion of production—a fiduciary role even though the relationship was not attorney-client. Years later, after civil litigation in Tennessee (judgment for fraud/breach of contract) and related collection efforts, OCTC filed a Notice of Disciplinary Charges in December 2018. A hearing judge dismissed the case as time-barred; OCTC sought review. :contentReference[oaicite:0]{index=0}

The Review Department reversed. It held that the limitations period is tolled while an attorney acts in a fiduciary relationship with the complainant (or related party), and that Saxon’s fiduciary duty continued until the film’s production closed in 2014—the point at which the purpose of the entrusted funds ended. Because the NDC was filed within five years of that termination, the charge was timely. The court further recognized tolling during the Tennessee civil action based on the same acts or circumstances; by contrast, later sister-state judgment enforcement and bankruptcy dischargeability proceedings did not toll the period. :contentReference[oaicite:1]{index=1}

Framing the merits, the Review Department emphasized that misappropriation by a fiduciary can constitute moral turpitude even outside a classic attorney-client setting; lawyers who accept fiduciary responsibilities are held to the profession’s standards regardless of capacity. Rather than reach final culpability or sanction, the court remanded to the Hearing Department for further proceedings consistent with its tolling analysis. Practically, Saxon clarifies that where a continuing fiduciary duty and continuing violation exist, the disciplinary “clock” runs from termination of the entire course of conduct, not from the first diversion of funds. :contentReference[oaicite:2]{index=2}