State Ex Rel. Oklahoma Bar Ass'n v. Dunlap

1994 OK 81, 880 P.2d 364, 65 O.B.A.J. 2331, 1994 Okla. LEXIS 92, 1994 WL 316934
CourtSupreme Court of Oklahoma
DecidedJuly 5, 1994
DocketSCBD 3972
StatusPublished
Cited by12 cases

This text of 1994 OK 81 (State Ex Rel. Oklahoma Bar Ass'n v. Dunlap) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Ex Rel. Oklahoma Bar Ass'n v. Dunlap, 1994 OK 81, 880 P.2d 364, 65 O.B.A.J. 2331, 1994 Okla. LEXIS 92, 1994 WL 316934 (Okla. 1994).

Opinions

ALMA WILSON, Justice:

The Bar Association filed a complaint against David M. Dunlap (Respondent) alleging that he had engaged in unprofessional conduct. Respondent and the Oklahoma Bar Association stipulated to findings of fact and conclusions of law. The parties joined in recommending that a six month suspension from the practice of law be imposed as discipline, and that Respondent be required to pay costs of the proceedings. The trial panel of the Professional Responsibility Commission has adopted the stipulations of fact, conclusions of law, and the recommendation for discipline.

The facts as stipulated and approved by the Trial Panel are as follows: On January 13, 1989, Vicky Kesterson (Kesterson) entered into a contingent fee contract with the respondent, David Dunlap. The parties agreed that Respondent would represent Kesterson in a claim for injuries Kesterson sustained when she slipped and fell in a restaurant.

On March 21, 1989, the restaurant’s insurance carrier paid Respondent $713.43, by check, to cover medical expenses already accumulated by Kesterson. On May 7, 1989, Respondent, who did not have a client trust account, deposited the check into his general operating account.

On July 26, 1989, Respondent received a second check from the insurer, on Kester-son’s behalf. Respondent opened a client trust account in August of 1989. The second check, in the amount of $4,286.57, was deposited into the attorney’s trust account on August 2, 1989.

Between March 1989 and March 1991, Respondent paid all but $10-$35 either directly to Kesterson, or to third parties on her behalf. In March 1991, the matter settled for an additional $100,000, for a total, including the two previous payments, of $105,000.

The $100,000 payment was made in the form of five checks: One for $83,212.96 to Respondent, who deposited the full amount into his trust account. Three additional checks totalling $14,597.54 were paid directly to medical providers. The 5th check was made payable jointly to Kesterson and to her physician.

On March 6, 1991, Respondent paid Kes-terson $40,000. While most other medical and legal expenses were paid, the client and Respondent agreed that a portion of the settlement would remain in Respondent’s trust account. The money was intended to cover future expenses in a companion products liability case, as well as additional medical expenses.

During the course of Ms. Kesterson’s representation, Respondent failed to keep accurate financial records. On several occasions the balance of the trust account fell a few hundred dollars below the amount Respondent was to have been holding in trust for Ms. Kesterson. A final accounting revealed that Kesterson actually received $350 more than she was entitled to under the fee contract.

[366]*366When the irregularities occurred, Respondent was experiencing marital problems. He is now divorced and is receiving counseling regarding the relationship issues. Respondent has acknowledged responsibility for the acts of misconduct and has implemented new office accounting procedures.

The parties agree that Respondent has violated Rules 1.5(c) and 1.15(a) and (b) of the Oklahoma Rules of Professional Conduct, and Rule 1.4(b), Rules Governing Disciplinary Proceedings. Rule 1.15(a) requires an attorney to maintain client funds in an account separate from the lawyer’s personal or business accounts, and to keep complete records of transactions involving client funds.1 Rule 1.15(b) directs lawyers to notify their clients whenever money is received on their behalf, and to promptly deliver the funds and/or a full accounting of any funds due to a client upon request.2 Rule 1.4 of the Rules Governing Disciplinary Proceedings sets out requirements for client trust accounts3, and provides that failure to account for and deliver funds upon demand constitutes conversion.4

Although the recommendations of the Trial Panel are given great weight, this Court has authority to disregard any or all of the Trial Panel’s findings where appropriate.5 After a de novo review of the record, we accept the Panel’s findings of fact and law, but we decline to follow the Panel’s recommendation for discipline.

This Court has assigned varying levels of discipline in matters involving mishandling of client funds. The disciplinary range has extended from censure to disbarment, depending in large part on the degree of harm to the client.6

[367]*367In State ex rel. Okla. Bar Ass’n. v. Johnston, 863 P.2d 1136 (Qkla.1993), we articulated a continuum of culpability employed in evaluating mishandling of funds in violation of Rule 1.15. We discussed commingling, simple conversion, and misappropriation, and assigned ascending levels of culpability to the behaviors, with misappropriation being the most offensive. Johnston, 863 P.2d at 1144.

An attorney has commingled funds when he has failed to keep client moneys, or money accepted on behalf of a client, in an account which is separate from that of the attorney. Johnston, 863 P.2d at 1145. In Johnston, we found an attorney had committed commingling when he withdrew trust account funds intended for his client’s medical bills and placed them in his personal account.7 For this and other acts of misconduct, Johnston was suspended for four months.8

Simple conversion, the next serious offense, occurs when the attorney uses a client’s money for some purpose other than that for which it was intended. In State ex rel. Okla. Bar n Ass’n v. Farrant, 867 P.2d 1279 (Okla.1994), the attorney committed simple conversion when he applied a client payment, intended for a private investigator’s services, to his own fees. The private investigator eventually instituted a collection action against the client. For this and other infractions, the attorney was suspended from the practice of law for one year.9

Finally, misappropriation occurs “when an attorney has ‘purposely deprived a client of money by way of deceit and fraud. A lawyer found guilty of intentionally inflicting grave economic harm in mishandling clients’ funds is deemed to have committed this most grievous degree of offense.” (Court’s emphasis.) Johnston, 863 P.2d at 1145. In accordance with the Rules of Professional Conduct, this Court has administered severe consequences for attorneys who purposefully misappropriated client funds.10 In State ex rel. Okla. Bar Ass’n v. Raskin, 642 P.2d 262 (Okla.1982), the attorney was disbarred after he used client funds to pay his own mortgage and car payments. The attorney’s misconduct caused the IRS to place a lien on the client’s home and property. The same attorney exposed a client in a criminal case to contempt charges when the attorney misappropriated funds intended for the client’s restitution. Raskin, 642 P.2d at 263.11

[368]*368In the instant ease, the attorney did not initially have a client trust account and commingled a portion of his Ghent’s fees with his personal funds. The attorney later allowed the balance of his trust account to fall to a level below the amount owed to his client. We have already noted that simple commingling falls at the lower end of a continuum of culpability.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State Ex Rel. Oklahoma Bar Ass'n v. Zimmerman
2012 OK 35 (Supreme Court of Oklahoma, 2012)
State Ex Rel. Oklahoma Bar Association v. Hammond
2008 OK 63 (Supreme Court of Oklahoma, 2008)
STATE EX REL. OKLAHOMA BAR ASS'N v. Wilson
2008 OK 42 (Supreme Court of Oklahoma, 2008)
State Ex Rel. Oklahoma Bar Ass'n v. Funk
2005 OK 26 (Supreme Court of Oklahoma, 2005)
State Ex Rel. Oklahoma Bar Ass'n v. Mayes
2003 OK 23 (Supreme Court of Oklahoma, 2003)
State ex rel. Oklahoma Bar Ass'n v. Phillips
2002 OK 86 (Supreme Court of Oklahoma, 2002)
STATE EX REL. BAR ASS'N v. Phillips
2002 OK 86 (Supreme Court of Oklahoma, 2002)
State Ex. Rel. Oklahoma Bar Ass'n v. Dunlap
2000 OK 8 (Supreme Court of Oklahoma, 2000)
State Ex Rel. Oklahoma Bar Ass'n v. Doris
1999 OK 94 (Supreme Court of Oklahoma, 1999)
State ex rel. Oklahoma Bar Ass'n v. Wilcox
1997 OK 87 (Supreme Court of Oklahoma, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
1994 OK 81, 880 P.2d 364, 65 O.B.A.J. 2331, 1994 Okla. LEXIS 92, 1994 WL 316934, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-oklahoma-bar-assn-v-dunlap-okla-1994.