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Attorney Discipline Supreme Court Opinion

by Mazur, Catherine


SC19535 - Disciplinary Counsel v. Parnoff ("In this appeal, we are asked to decide whether an attorney who knowingly appropriated client funds, but did not intend to do so wrongly, 'knowingly misappropriated' those funds and is therefore subject to mandatory disbarment pursuant to Practice Book § 2-47A. The plaintiff, Disciplinary Counsel, appeals from the judgment of the Appellate Court, which affirmed the judgment of the trial court reprimanding the defendant, Laurence Parnoff, rather than disbarring him pursuant to § 2-47A. Disciplinary Counsel v. Parnoff, 158 Conn. App. 454, 482, 119 A.3d 621 (2015). The plaintiff contends that the trial court improperly interpreted § 2-47A to mandate disbarment only if an attorney appropriates client funds knowingly and with the wrongful intent to steal them. Regardless of the defendant's intent, the plaintiff claims, the defendant’s knowledge that the funds he appropriated were disputed is sufficient to disbar him. We conclude that § 2-47A mandates disbarment only when an attorney misappropriates a client’s funds both knowingly and intentionally—that is, when an attorney steals from his or her client. Accordingly, we affirm the judgment of the Appellate Court.")