The California State Bar has delivered the ultimate professional sanction to attorney Stephen John Armstrong, ordering his permanent disbarment effective November 6, 2025. The ruling was imposed for a devastating combination of ethical violations, including failures in the fundamental handling of client money and an official finding of acts of moral turpitude.
For an attorney admitted to the Bar in 2000, this permanent removal is a stark reminder that the duty to protect client property is non-negotiable and absolute.
The Cardinal Sins: Moral Turpitude and Fund Mismanagement
Armstrong’s disbarment (Case No. 24-O-30806) was the result of severe breaches of professional conduct that compromised both his clients’ financial security and the integrity of the profession.
The key violations included:
-
Acts of Moral Turpitude: This is the most serious finding against an attorney. It means the court determined Armstrong’s conduct involved a fundamental violation of honesty, ethics, and morality, making him unfit to practice law.
-
Failure to Use a Trust Account (IOLTA): Armstrong failed to deposit client funds into a segregated Client Trust Account (IOLTA). By keeping client money outside of this protected environment, he exposed it to risk and violated the most basic rule for safeguarding client property.
-
Failure to Render Accounts: He failed to provide clients with proper accountings—the itemized statements detailing how their money was spent or how the fees were earned. This denied his clients the transparency required to verify the disposition of their funds.
The Final Sanction: Permanent Disbarment
The California State Bar Court determined that the gravity of these violations—especially the acts of moral turpitude coupled with a deliberate failure to utilize the trust account system—left no option other than permanent disbarment.
The duty to protect client funds is the cornerstone of the fiduciary relationship. When an attorney fails to keep client funds separate, refuses to provide an accounting, and engages in conduct deemed morally bankrupt, the privilege to practice law must be revoked.
The final order permanently removes Stephen John Armstrong from the roster of attorneys authorized to practice law in California.
Conclusion: Trust Account Rules Are Absolute
The disbarment of Stephen John Armstrong sends an unmistakable message to the California Bar: there is no greater ethical risk than compromising client funds.
Negligence or confusion about an IOLTA account is serious, but a willful failure to use a trust account and a refusal to account for money, compounded by a finding of moral turpitude, is grounds for immediate and permanent removal. The State Bar prioritizes the financial safety of the public above all else, and this disbarment confirms that attorneys who violate the rules of financial integrity will forfeit their professional license forever.