In re Ulrich

78 N.E.3d 1097 (Ind. 2017) · Indiana Supreme Court · March 2, 2017

Summary

The Indiana Supreme Court approved a conditional agreement disciplining an attorney for failing to act diligently, failing to keep a client informed, delaying distribution of client funds, and mismanaging trust-account records and withdrawals. The court imposed a six-month suspension, stayed subject to at least two years of probation with certified-public-accountant trust-account monitoring, and assessed costs against the respondent.

Court
Indiana Supreme Court
Writing for the Court
Loretta H. Rush, Chief Justice
Jurisdiction
Indiana
Decision date
March 2, 2017
Procedural posture
The Indiana Supreme Court reviewed and approved a Statement of Circumstances and Conditional Agreement for Discipline submitted by the Indiana Supreme Court Disciplinary Commission and the respondent attorney.
Standard of review
The Court considered whether to approve the parties' stipulated agreement and proposed discipline under Indiana Admission and Discipline Rule 23(12.1)(b).
Precedential value
Published disciplinary order; binding as to the respondent's stipulated violations and imposed discipline, but of limited general precedential value.
Disposition
approved

Topics

administrative lawinsurance

Practice areas

legal ethics and professional responsibilityattorney disciplinetrust account complianceinsurance litigation

Questions Presented

  1. Whether respondent violated the Indiana Rules of Professional Conduct and Indiana Admission and Discipline Rules through deficient diligence and client communication, delayed delivery of client funds, trust-account recordkeeping failures, commingling, and unauthorized withdrawals.
  2. Whether the stipulated Statement of Circumstances and Conditional Agreement for Discipline should be approved and the agreed six-month suspension stayed subject to probation.

Holdings

  1. The Court approved the parties' stipulation that respondent violated Indiana Professional Conduct Rules 1.3, 1.4(a)(3), 1.15(a), and 1.15(d), and Indiana Admission and Discipline Rules 23(29)(a)(3), 23(29)(a)(4), and 23(29)(a)(5).
  2. The Court approved a six-month suspension from the practice of law, stayed subject to completion of at least two years of probation, with certified-public-accountant trust-account monitoring and quarterly reports to the Disciplinary Commission.

Factual background

Respondent represented a client in a personal-injury matter and retained settlement proceeds in his trust account while pursuing underinsured-motorist claims and resolving Medicare's lien. He acknowledged insufficient diligence and communication and delayed delivering the client's share of the settlement until the client retained new counsel. From 2009 through 2015, respondent also failed to withdraw earned fees, failed to maintain individual client ledgers, made checks payable to cash, and made trust-account transfers without written authorization, although the account balance was always sufficient to cover client obligations.

Procedural history

The Disciplinary Commission and respondent stipulated to facts, rule violations, aggravating and mitigating circumstances, and proposed discipline. The Indiana Supreme Court approved the agreement, suspended respondent from practicing law for six months with the suspension stayed subject to at least two years of probation, and assessed proceeding costs against respondent.

Court Document

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