review of the report of the Iowa Supreme Court Grievance
commission recommends revocation of an attorney's license
to practice law for violations of ethical rules.
van Brederode and Crystal W. Rink, Des Moines, for
L. Earley, Grinnell, pro se.
admitted Iowa attorney received retainers to handle family
law matters, did essentially no work on those matters, and
used the funds instead for personal purposes. The Iowa
Supreme Court Attorney Disciplinary Board sought revocation
of the attorney's license, and the attorney did not
contest revocation or argue he had a colorable future claim
to the funds when he converted them. A division of the Iowa
Supreme Court Grievance Commission held a hearing and
concluded that most of the alleged ethical violations had
occurred and that revocation was the proper sanction. On our
review, we agree with the commission and therefore revoke the
attorney's license to practice law.
Facts and Procedural History.
Earley graduated from law school in 2017 and was admitted to
the Iowa bar that same year. At relevant times, he maintained
a solo private practice in Grinnell. This disciplinary
proceeding concerns Earley's representation of two
Ryan Patterson Matter.
2018, Earley began representing Ryan Patterson in a
dissolution of marriage action. Patterson agreed to pay
Earley $250 per hour with a cap of $1500. Patterson also
agreed to pay $300 for anticipated expenses. On April 27,
Patterson's mother gave Earley a check in the amount of
$1800 for the representation. Earley deposited this check
into his client trust account the same day. Thereafter,
Earley drafted a petition for dissolution that he did not
file. He performed no other work on the case.
March 14 and July 25, Earley moved $5910 from his client
trust account into his business checking account. He also
moved $2590 from his client trust account into his personal
checking account. By July 31, these account transfers left $2
remaining in Earley's client trust account. The unearned
portion of the funds received for the Patterson dissolution
matter were among those transfers. Earley did not notify
Patterson of the time, amount, or purpose of the withdrawals
or furnish an accounting.
12, in a responsive letter to the Office of Professional
Regulation, Earley self-reported his conversion of client
The main purpose of this letter . . . is to self-report
multiple ethics violations regarding my trust account
management. I'm not sure where to start, so I will start
at the beginning.
went on to describe a variety of challenges he faced as he
began his legal career as a solo practitioner. He explained
that due to financial strain, he took on cases that were
beyond his realm of expertise. He began experiencing
depression and anxiety. Earley described his ongoing
resentment toward his father. He noted that his father, an
attorney, had committed ethical violations of his own before
ultimately being disbarred. Earley continued,
With respect to my violations, I don't have the specifics
at the moment. I just know that I've taken money from my
trust account before I earned it, multiple times. If I were
to estimate, I would say at least 5 times. I will fully
cooperate with your Office however. I will release my trust
account records and give you my compensation agreement
I am deeply sorry for my actions. I am ashamed and
embarrassed. I am completely lost at the moment. I honestly
don't know what I want, or how I want this situation to
play out. But I know that I'm not in a good place,
mentally right now. And that I need help. So, I'm asking
August 7, Earley sent a letter to Patterson admitting he had
taken Patterson's $1800 without earning the funds:
I apologize for taking so long to respond to you. The truth
is that I've been avoiding this conversation because I am
ashamed of my actions.
There's really no easy way to say this, so I'll just
say it. I no longer have your $1800, nor can I represent you
in your divorce case.
For what it's worth, I am GENUINELY
sorry for my actions. Eventually, I will make this right. You
have my word as a man. But I realize that doesn't really
mean much at this point in time.
I figure that I at least owe you an explanation. So, here it
Several months ago I began to experience crippling anxiety,
which coincided with mounting financial difficulties. I
attempted to get treatment, but nothing helped. I have since
made the decision to quit the ...