In the legal profession, ethical rules aren’t just guidelines; they’re the foundation of public trust and professional integrity. When attorneys neglect their duties, mismanage client funds, or fail to communicate with those they represent, the consequences can be career-ending. This post examines two recent disciplinary cases that highlight how repeated misconduct, especially involving client trust accounts and professional negligence, can lead to suspension or even disbarment.
Matter of Abraham, 2024 NY Slip Op 03841 Appellate Division, First Department Decided: July 18, 2024
Improper Borrowing of Client Funds
In 2015, Abraham represented a client in real estate, estate planning, and personal injury matters. During their representation, the client interested in helping Abraham with real estate investments provided him $140,000, which Abraham deposited into his attorney trust account and then transferred to his personal account without a formal agreement. Only $5,000 was repaid. The client later became incapacitated, and due to no agreement and depleted funds, her guardian couldn’t file for Medicaid. She ultimately died with significant medical debt.
Abraham failed to respond to interrogatories in one case and failed to appear for mandatory arbitration in another, resulting in two default judgments against his client.
In a 2021 Stipulation, Abraham admitted to the violations, waived a hearing, and faced sanctions. The Disciplinary Review Board (DRB) recommended a three-month suspension. On April 28, 2022, the Supreme Court of New Jersey formally suspended him for three months, effective May 30, 2022.
The Attorney Grievance Committee (AGC) of New York sought reciprocal discipline. Abraham agreed, requesting the suspension be retroactive to May 30, 2022. The AGC did not oppose. The New York Appellate Division granted this request on July 18, 2024, suspending him for three months, effective nunc pro tunc to May 30, 2022.
Borrowing client funds especially for personal use and without formal agreements can result in serious disciplinary measures.
Failing to diligently manage cases may lead to client harm, like default judgments. Ethical obligations extend across jurisdictions with reciprocal discipline ensuring professional accountability even out-of-state.
In the Matter of Santo V. Artusa, Jr., Disciplinary Review Board Docket No. DRB 24-104 New Jersey Supreme Court Docket No. 088349 Order Date: January 14, 2025
2021 (Artusa I): Artusa was censured for passing bad checks and recordkeeping violations like failing to maintain trust account records and writing checks totaling $3,353 to the Superior Court.
2023 (Artusa II): He received another censure for repeated trust-account failures and for not cooperating with disciplinary investigation.
2024 (Artusa III): He was reprimanded for grossly negligent handling of a guardianship matter, failing to communicate or refund an unearned fee, and for lack of diligence. Conditions were imposed: proof of fitness to practice and continuing alcohol treatment.
In a detailed DRB decision dated October 23, 2024, the board found Artusa violated several Rules of Professional Conduct, Given his disciplinary history and repeated defaults, the DRB recommended a three‑month suspension, along with conditions requiring two years of probation under a supervising proctor plus reimbursement of disciplinary costs.
On January 14, 2025, the New Jersey Supreme Court formally ordered a three‑month suspension, effective immediately. Artusa has remained suspended since August 21, 2023.
The order reiterated the underlying violations confirmed his default in responding to disciplinary complaints, and mandated two years of practice under proctor supervision upon reinstatement.
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