Safeguarding Client Funds and Calibrating Sanctions for Single-Matter Misconduct: Commentary on Lawyer Disciplinary Board v. Thomas H. Evans, III

Supreme Court of Appeals of West Virginia, Memorandum Decision, November 5, 2025 (No. 24-92)

I. Introduction

This memorandum decision of the Supreme Court of Appeals of West Virginia in Lawyer Disciplinary Board v. Evans addresses serious attorney misconduct arising from a single, protracted property dispute. The Court affirms a three‑month suspension, automatic reinstatement, and a year of supervised practice, along with ethics-focused continuing legal education (CLE) and costs.

The decision is particularly significant for three reasons:

It illustrates how multiple, serious violations of the Rules of Professional Conduct arising from one “matter” are analyzed under Rule 3.16 of the Rules of Lawyer Disciplinary Procedure.
It clarifies sanctioning when an attorney mishandles client/third‑party funds (keeping them in a safe instead of a trust account) without sufficient proof of misappropriation.
It explicitly underscores the Office of Disciplinary Counsel’s (ODC) duty to thoroughly investigate allegations of mishandling client funds, even when older financial records are difficult to obtain.

Parties:

Petitioner: Lawyer Disciplinary Board (through the ODC).
Respondent: Attorney Thomas H. Evans, III, admitted 2005, practicing in Oceana, West Virginia.

The misconduct centers on a 2014 partition suit involving siblings Margaret Shields, Steve Rife, and Dale Rife, a subsequent 2017 civil action filed by Dale, and Mr. Evans’s conduct toward clients, opposing party, and the disciplinary authorities.

II. Summary of the Opinion

A. Outcome

The Court adopts the Hearing Panel Subcommittee’s (HPS) recommended sanctions:

Suspension: Three (3) month suspension from the practice of law.
Automatic reinstatement: Under Rule 3.31 of the Rules of Lawyer Disciplinary Procedure, without the need for a separate reinstatement petition, after the suspension period, assuming compliance.
Supervised practice: One (1) year of supervised practice by an active attorney in Mr. Evans’s geographic area, in good standing, approved by the ODC.
Additional CLE: Six (6) hours of CLE in legal ethics and law office management during the 2024–2026 reporting period.
Costs: Payment of the costs of the disciplinary proceedings under Rule 3.15.

B. Core Findings of Misconduct

The Court accepts the HPS’s conclusion that Mr. Evans violated multiple provisions of the West Virginia Rules of Professional Conduct, including:

Rule 1.3 – Diligence
Failure to act with reasonable diligence in representing Margaret Shields and Steve Rife.
Rule 1.4 – Communication
Failure to keep clients reasonably informed and to explain matters sufficiently to permit informed decisions (Margaret Shields and Steve Rife).
Rule 1.15(a), (d) – Safekeeping Property
- Failure to keep $13,000 (due to Dale Rife) in a client trust account; instead placing it in a safe in his office.
- Failure to promptly notify Dale Rife of funds in which he had an interest or to make those funds available.
Rule 3.4(f) – Fairness to Opposing Party and Counsel
Advising Margaret Shields and Steve Rife (who were not his clients in the 2017 case) not to testify at an April 2022 hearing.
Rule 8.1(b) – Bar Admission and Disciplinary Matters
Twice failing to respond to lawful demands for information from the ODC (complaints by Joshua Thompson and by Dale Rife).
Rule 8.4(c), (d) – Misconduct
- Engaging in dishonesty, fraud, deceit, or misrepresentation (forging clients’ signatures on pleadings and having false verifications notarized).
- Engaging in conduct prejudicial to the administration of justice (dilatory tactics and prolonged deprivation of property rights).

Applying Rule 3.16’s sanctioning factors, the Court concludes that although the misconduct is serious, it occurred within the context of a single, though long‑running, property dispute. Balancing aggravating and mitigating circumstances, the Court holds that a three‑month suspension with supervised practice appropriately protects the public and the integrity of the profession.

III. Background and Factual Context

A. The 2014 Partition Suit

The dispute concerns 0.42 acres in Wyoming County, West Virginia, jointly owned in one‑third undivided interests by siblings:
- Margaret Shields
- Steve Rife
- Dale Rife
Margaret and Steve retained Mr. Evans to file a partition action against Dale, who opposed a sale to a third party.
Service on Dale (in North Carolina) was attempted by mail and process server but failed; Mr. Evans sought service by publication in North Carolina newspapers.
Commissioners valued the property at $36,000 and found it not capable of partition in kind.
The circuit court entered a default judgment against Dale:
- Margaret and Steve were awarded Dale’s one‑third interest.
- Quiet title entered in their favor.
- Order required that one‑third of the value (about $12,000, plus a gratuitous $1,000—$13,000 total) be deposited in an interest‑bearing account with the circuit clerk for Dale’s benefit.
On September 2, 2015, the circuit court denied Dale’s motion for reconsideration.
On October 15, 2015, Mr. Evans recorded a deed conveying Dale’s one‑third interest to Margaret and Steve.
On October 16, 2015, Dale filed a notice of intent to appeal.
During the pendency of the appeal, Margaret and Steve sold the property to Timothy and Erma Mutters, using a deed prepared by Mr. Evans (December 4, 2015).
The $13,000 due to Dale was not deposited with the clerk as ordered and was never made available to Dale.

B. The 2016 Supreme Court Reversal – Rife v. Shields

In November 2016, the Supreme Court of Appeals reversed the default judgment in Rife v. Shields, 2016 WL 6819045 (No. 15‑0975). The Court held the circuit court lacked personal jurisdiction over Dale, making the default judgment void and unenforceable. The case was remanded for vacation of the default judgment.

Key practical consequences:

The August 2015 default judgment was not actually vacated in the circuit court until January 30, 2018—over a year after the Supreme Court’s remand—and only after Dale filed a new suit.
The Mutters remained record owners until January 3, 2022, when the circuit court voided the October 2015 and December 2015 deeds.
Dale was effectively deprived of the use and enjoyment of his property for approximately seven years.

C. The 2017 Civil Action by Dale Rife

In 2017, Dale sued:

Mr. Evans (individually and his law practice),
Margaret Shields and her husband,
Steve Rife, and
Timothy and Erma Mutters.

Claims included:

Negligence
Civil conspiracy
Fraud
Intentional infliction of emotional distress
Slander of title

The circuit court ultimately:

Found that Dale had been deprived of his property for seven years.
Entered judgment against Mr. Evans, Margaret Shields, and the Mutters (Steve was later dismissed for lack of personal jurisdiction).
Awarded:
- $13,000 in sanctions against Mr. Evans, payable to Dale.
- $23,867.50 in attorney’s fees and costs (post‑appeal).
- $10,000 for property loss damages.
- $10,000 in punitive damages.
Allocated 60% of the damages to Mr. Evans, for a judgment of $26,120.50, in addition to the $13,000 sanction.

Mr. Evans has not yet satisfied the circuit court judgment, although he reports attempting to sell real estate to do so.

D. The Disciplinary Complaints

Four separate complaints triggered the disciplinary process:

Margaret Shields
- Claimed she believed Mr. Evans represented her in the 2017 civil action.
- Alleged he:
  - Prepared and filed pro se answers in her name.
  - Signed her name to pleadings and verifications and had them falsely notarized.
  - Advised her not to appear at an April 2022 hearing.
  - Told her he could get the judge to “sign anything” for him and might “make the case go away” if elected judge.
  - Suggested he knew “unsavory people” who could resolve the issues with Dale for a few thousand dollars.
  - Failed to communicate effectively, including failing to provide timely appraisals.
- Reported that she and Steve gave Mr. Evans $13,000 in cash to pay Dale, but Dale never received the money.
Steve Rife
- Echoed Margaret’s allegations regarding:
  - The $13,000 cash payment to Mr. Evans.
  - Belief the 2017 case was resolved until a default notice arrived after he failed to appear at a hearing.
- Mr. Evans also:
  - Prepared a pro se answer for Steve in the 2017 case and signed Steve’s name.
  - Advised Steve not to testify.
Joshua T. Thompson (Dale’s counsel in 2017 case)
- Filed a complaint under Rule 8.3(a), which requires lawyers to report substantial professional misconduct.
- Asserted that Mr. Evans’s “fraudulent schemes” deprived Dale of his property for more than seven years.
- Noted that Mr. Evans was found liable for multiple torts and 60% of the damages.
- Emphasized that Mr. Evans’s conduct delayed restoration of Dale’s property rights.
Dale Rife
- Echoed the circuit court’s findings: “[Mr. Evans] showed a pattern of neglect, willful and repeated disregard of [Dale’s] property rights, and a willful and repeated disregard for court orders and deadlines.”
- Alleged:
  - Mr. Evans failed to provide his professional liability insurance declarations page.
  - Mr. Evans ignored a Writ of Execution and a Writ of Suggestion.
  - Belief that someone at the bank tipped off Mr. Evans, who allegedly withdrew funds to avoid attachment, leaving only $96.55 subject to the writ.
  - He recorded a notice of lis pendens against Mr. Evans’s residence.

Mr. Evans largely failed to timely respond to the complaints from Mr. Thompson and Dale. When he eventually gave a sworn statement in September 2023, he claimed he felt overwhelmed and believed he had “already answered” the allegations via his response to Margaret and Steve’s complaints.

IV. Summary of the Court’s Legal Conclusions

A. Violations of the Rules of Professional Conduct

The Court, adopting the HPS’s findings, concludes that Mr. Evans committed:

Rule 1.3 – Diligence: Against Margaret Shields and Steve Rife.
Rule 1.4(a)(3), (b) – Communication: Against Margaret and Steve.
Rule 1.15(a) – Safekeeping Property: Failing to place $13,000 in a client trust account; storing cash in his office safe instead.
Rule 1.15(d): Failing to promptly notify Dale of funds in which he had an interest or to deliver them to him or to the clerk as ordered.
Rule 3.4(f): Improperly requesting that non‑clients (Margaret and Steve in the 2017 action) refrain from voluntarily giving relevant information (testimony).
Rule 8.4(c) – Dishonesty, fraud, deceit, misrepresentation:
- Forging Margaret’s and Steve’s signatures on pleadings and verifications.
- Having those signatures falsely notarized.
Rule 8.4(d) – Conduct prejudicial to the administration of justice:
- Filing forged documents.
- Conduct contributing to a seven‑year delay in restoring Dale’s property rights.
Rule 8.1(b) – Disciplinary Matters:
- Failure to respond to the ODC regarding Joshua Thompson’s complaint.
- Failure to respond to the ODC regarding Dale’s complaint.

B. Standard of Review and the Court’s Role

The Court reiterates its established approach:

Fact‑finding: Substantial deference to the Board’s findings of fact unless not supported by “reliable, probative, and substantial evidence.” (Citing Syl. Pt. 3, McCorkle.)
Questions of law / application / sanctions: Reviewed de novo; the Court independently determines the appropriate sanction, giving “respectful consideration” to the Board’s recommendation (again referencing McCorkle).
Ultimate authority: The Court is the “final arbiter of legal ethics problems.” (Syl. Pt. 3, Blair.)

The Court accepts the HPS’s factual findings and violations as undisputed and focuses on whether the recommended three‑month suspension and related sanctions are adequate.

V. Analysis of the Court’s Legal Reasoning

A. Application of Rule 3.16 (Sanctioning Factors)

Rule 3.16 of the Rules of Lawyer Disciplinary Procedure, as summarized in Syl. Pt. 4 of Office of Lawyer Disciplinary Counsel v. Jordan, requires consideration of:

Whether the lawyer violated a duty to a client, the public, the legal system, or the profession.
Whether the lawyer acted intentionally, knowingly, or negligently.
The amount of actual or potential injury caused.
Any aggravating or mitigating factors.

1. Duties Violated

The Court emphasizes that Mr. Evans violated:

Duties to clients: Lack of diligence, poor communication, mishandling funds, and forging signatures.
Duties to the public and the legal system: Delay in restoring property rights, improper influence statements regarding the judge and later judgeship, and forged, notarized pleadings.
Duties to the profession: Dishonesty and failure to cooperate with disciplinary authorities.

2. Mental State: Intentional and Knowing Conduct

The Court finds that Mr. Evans’s conduct was intentional and knowing, not merely negligent:

Forging signatures requires purposeful action.
Having a notary notarize false verifications is an intentional misrepresentation to the court.
Keeping $13,000 in a safe instead of a trust account, and failing to notify or pay Dale, is deliberate non‑compliance with safekeeping rules.
Ignoring ODC inquiries, after a prior admonishment for similar conduct, was knowing disregard of disciplinary obligations.

3. Degree of Injury

The Court describes the injury as “great”:

Dale was deprived of his legal property interest for approximately seven years.
The partition dispute (initiated in 2014) was not finally resolved until 2023.
All parties’ trust in the legal system and in attorneys was eroded.
Mr. Evans has not satisfied the civil judgment against him, prolonging the harm.

4. Aggravating and Mitigating Factors (per Scott)

Referring to Lawyer Disciplinary Board v. Scott, the Court reiterates that:

Aggravating factors justify increasing discipline.
Mitigating factors justify reducing discipline.

Here, the parties stipulated to:

Aggravating factors:

Substantial experience: Mr. Evans had been practicing since 2005; he was not a novice.
Pattern of misconduct: Neglect of client matters and repeated disregard of obligations over several years.
Multiple offenses: Numerous rule violations (Rule 1.3, 1.4, 1.15, 3.4, 8.1, 8.4) arising out of related conduct.

Mitigating factors:

Remorse: Mr. Evans expressed remorse.
Other penalties and sanctions: Significant civil sanctions and monetary judgments were entered against him in the 2017 case (over $39,000 total exposure when including sanctions).
Absence of prior disciplinary record: Prior to this matter, Mr. Evans had no discipline, although he did receive a June 2022 admonishment under Rule 8.1(b) for failing to respond to the ODC in this very proceeding. The Court makes clear that this admonishment was not a separate, historical disciplinary record, but part of this ongoing sequence.

The Court explicitly notes it scrutinized whether these mitigating factors, especially the absence of misappropriation proof and other civil sanctions, justify staying within a three‑month suspension, rather than imposing a longer suspension or harsher measures.

B. Safekeeping of Client/Third‑Party Funds – Rule 1.15 and the “Safe in the Office” Problem

A key issue is Mr. Evans’s handling of the $13,000 intended for Dale’s share of the property:

He did not deposit the money with the circuit clerk as ordered by the court in the partition case.
He did not deposit the money into a client trust account.
Instead, he kept the funds in a safe in his office for a period of time.
He claimed that when the matter “fell apart,” he returned the cash to Margaret Shields.
Margaret’s statements were inconsistent: she told the ODC at one point that he kept the money, but testified in April 2022 that the funds had been returned to her.

The ODC ultimately concluded that there was insufficient evidence of misappropriation or theft, in part because of difficulty obtaining older bank records. The Court:

Affirms that:
- Storing client/third‑party funds in a personal safe rather than in a properly maintained trust account violates Rule 1.15(a).
- Failing to promptly notify or pay a third party (Dale) whose interest in the funds is clear violates Rule 1.15(d).
Expressly cautions the ODC that: “it is critical that the ODC thoroughly investigate all allegations of attorney misconduct” and that “a thorough investigation on the part of the ODC is an essential step in all disciplinary proceedings which serve to safeguard the public’s interest in the administration of justice.”

On sanction, the Court compares this case to Lawyer Disciplinary Board v. Haught, 233 W. Va. 185, 757 S.E.2d 609 (2014), where an attorney also purportedly kept client funds in a safe and received a one‑year suspension.

Why a lesser suspension for Evans than in Haught?

Haught involved additional, unrelated ethical violations, including false statements of material fact and misrepresentation of an attorney‑client relationship.
Mr. Evans’s violations, serious as they are, arose out of a single overarching property dispute (2014 partition suit and its 2017 fallout), albeit with multiple rule violations and multiple actors.
No clear proof of misappropriation of the $13,000 was established, only improper safekeeping and failure to comply with court orders and Rule 1.15’s procedural requirements.

C. Comparison to Other Discipline Cases Cited

The Court situates the three‑month suspension within a line of similar sanctions:

Lawyer Disciplinary Board v. Thompson, 238 W. Va. 745, 798 S.E.2d 871 (2017)
- Three‑month suspension imposed for:
  - Failure to provide competent representation.
  - Dilatory conduct.
  - Knowingly disobeying tribunal obligations.
  - Conduct prejudicial to the administration of justice.
- This case is cited as a benchmark for imposing a three‑month suspension for serious but non‑misappropriation misconduct, involving poor practice and disobedience of procedural obligations.
Lawyer Disciplinary Board v. Sturm, 237 W. Va. 115, 785 S.E.2d 821 (2016)
- Ninety‑day (three‑month) suspension for:
  - Failure to timely file a habeas petition.
  - Failure to communicate with the client.
  - Failure to properly deposit a retainer into a client trust account.
- Demonstrates that a short‑term suspension is appropriate when trust‑account violations are coupled with neglect and lack of communication but not proven theft.
Committee on Legal Ethics v. Karl, 192 W. Va. 23, 449 S.E.2d 277 (1994)
- Three‑month suspension imposed for:
  - Failure to act with reasonable diligence.
  - Failure to communicate effectively with clients.
  - Failure to respond to disciplinary authority’s repeated information requests.
- This case closely parallels Evans’s violations of Rules 1.3, 1.4, and 8.1 and supports a three‑month suspension.

By aligning Evans’s sanction with Thompson, Sturm, and Karl, while distinguishing Haught, the Court signals that:

Short‑term suspensions (around three months) are typical where there is:
- Serious neglect and communication failures, and
- Improper handling of funds without clearly proven misappropriation.
Longer suspensions are reserved for:
- Multiple unrelated matters, and/or
- More egregious dishonest conduct and clear financial exploitation.

D. The Role of Supervised Practice

The Court does more than suspend; it orders one year of supervised practice upon reinstatement, explicitly stating:

“The goal of the supervised practice will be to improve the quality and effectiveness of Mr. Evans’s law practice to the extent that Mr. Evans’s sanctioned behavior is not likely to recur.”

This reflects the Court’s view of discipline as both protective and rehabilitative, consistent with:

Committee on Legal Ethics v. Keenan – Discipline is to protect the public and the administration of justice, not solely to punish.
In re Daniel (Syl. Pt. 2) – Sanctions are not purely punitive but serve public‑protection functions.

Imposing supervision, rather than simply a suspension, indicates:

The Court views Mr. Evans as potentially rehabilitable.
There is a recognized need to improve his law office management, trust‑account handling, and overall diligence and communication.

VI. Impact and Broader Significance

A. Guidance on Sanctioning for Single‑Matter, Multi‑Rule Misconduct

The decision provides a relatively clear template for future cases where:

All misconduct arises out of a single “matter” or related set of proceedings.
There are multiple, serious rule violations (diligence, communication, honesty, trust‑account handling, and disciplinary non‑cooperation).
There is substantial harm, but not proven misappropriation.

Even though issued as a memorandum decision under Rule 21 (and thus not a full precedential opinion with syllabus points), it will likely be cited persuasively for:

Using three‑month suspensions with automatic reinstatement plus supervision as an appropriate response to this cluster of misconduct.
Distinguishing cases warranting one year or more of suspension when there is broader, multi‑matter, or more egregious conduct.

B. Reinforcement of Trust‑Account and Safekeeping Duties

The decision underscores that:

Lawyers must never treat client or third‑party funds as if they were safe to hold outside of a properly maintained trust account.
Physical custody (e.g., a safe) is not a substitute for the fiduciary structure and recordkeeping required by Rule 1.15 and State Bar Administrative Rule 10 (overdraft reporting, etc.).
Failure to follow the safekeeping rules is itself a disciplinary violation, whether or not misappropriation can be conclusively proven.

C. Strengthening ODC’s Investigative Obligations

The Court’s comments about the ODC’s difficulties in obtaining old bank records are pointed:

Even when records are “almost ten years old,” the ODC is expected to make diligent efforts to obtain and review financial documents in misappropriation or mishandling cases.
The Court describes a “thorough investigation” by ODC as “critical” and “an essential step” in safeguarding the public’s interest in the administration of justice.

This passage is effectively an institutional reminder that discipline mechanisms must be robust, particularly when public confidence in lawyers’ handling of money is at stake.

D. Emphasis on Cooperation with Disciplinary Authorities

By affirming multiple Rule 8.1(b) violations (and noting a prior admonishment for the same conduct in this very proceeding), the Court reinforces that:

Lawyers must respond promptly and fully to lawful demands from ODC.
Failure to respond is itself a separate act of misconduct, independent of the underlying complaint’s merits.
Repeated non‑cooperation, even in one overall matter, will aggravate sanction severity.

VII. Complex Concepts Simplified

1. Partition Suit

A partition suit is a civil action between co‑owners of real property. When they cannot agree on what to do with the property, one or more co‑owners can ask the court to:

Divide the property physically (partition in kind), or
Order a sale of the property and division of the proceeds (partition by sale).

Here, the commissioners found the property could not be fairly divided, so a sale was sought.

2. Default Judgment and Personal Jurisdiction

A default judgment occurs when a defendant does not respond or appear, and the court grants relief to the plaintiff by default.

However, a court can only bind a defendant if it has personal jurisdiction—the legal authority to exercise power over that person, typically requiring proper notice and sufficient connection to the state. In Rife v. Shields, the Supreme Court held that because the court lacked personal jurisdiction over Dale, the default judgment was void.

3. Client Trust Account vs. Office Safe

Under Rule 1.15, money that belongs to a client or a third person (like Dale’s share of sale proceeds) must:

Be kept in a separate account clearly designated as a “client trust account.”
Not be mixed with the lawyer’s own money.
Be fully and accurately recorded, with records kept for at least five years.

Keeping the funds in a personal office safe:

Provides no bank records or audit trail.
Bypasses overdraft notification systems meant to detect misuse.
Violates the specific requirements of Rule 1.15 and Bar Administrative Rule 10.

4. Mitigating vs. Aggravating Factors

Mitigating factors are circumstances that may justify a lesser sanction: remorse, no prior discipline, other penalties already imposed, etc.
Aggravating factors justify a harsher sanction: a pattern of misconduct, substantial experience (you should know better), multiple rule violations, etc.

The Court weighs these to craft a sanction that is neither too lenient nor overly harsh.

5. Automatic Reinstatement vs. Petition for Reinstatement

A suspension with automatic reinstatement (as under Rule 3.31 for shorter suspensions) means:

After the suspension period, the attorney may return to practice without a separate, contested reinstatement proceeding, assuming compliance with conditions (e.g., CLE, costs).

By contrast, longer or more serious suspensions or disbarments often require a formal petition for reinstatement, with an evidentiary showing of rehabilitation and fitness to practice.

6. Supervised Practice

Under supervised practice:

The attorney practices law but under the oversight of a designated supervising lawyer.
The supervising lawyer monitors:
- Docket management and deadlines.
- Client communication practices.
- Trust‑account handling and law office management.
The aim is to reduce the risk of recurrence and improve practice quality.

7. Conduct Prejudicial to the Administration of Justice

Rule 8.4(d) targets behavior that:

Undermines the fair and efficient functioning of courts and legal processes, even if it does not fit neatly into other categories of misconduct.

In this case, the prolonged deprivation of property rights, forged pleadings, and delays in returning the case to its proper posture fall under this rule.

VIII. Conclusion and Key Takeaways

This memorandum decision, though not a full precedential opinion, offers substantive guidance on West Virginia lawyer discipline in several respects:

Multi‑rule misconduct in a single matter can warrant a short‑term suspension with supervision.
Even though all violations stemmed from one property dispute, the cumulative effect of neglect, poor communication, dishonesty, improper safekeeping of funds, and non‑cooperation justified a three‑month suspension and one year of supervised practice.
Improper handling of client or third‑party funds, even without clear misappropriation, is serious.
Storing funds in a safe and failing to deposit them as ordered or in a trust account violates Rule 1.15. While lack of proof of theft spared Mr. Evans from the more severe sanctions seen in misappropriation cases, the Court still treated this as a major violation.
ODC must thoroughly investigate financial misconduct allegations.
The Court’s pointed commentary on the difficulty obtaining older bank records doubles as an institutional directive: investigations must be vigorous enough to either establish or conclusively refute misappropriation.
Cooperation with disciplinary authorities is mandatory and independently sanctionable.
Mr. Evans’s repeated failure to respond to ODC inquiries—despite an admonishment for that very conduct—was itself misconduct and an aggravating factor, reinforcing that Rule 8.1(b) is not optional.
Discipline remains focused on public protection and rehabilitation, not solely punishment.
Citing Keenan and Daniel, the Court uses supervised practice and targeted CLE to improve Mr. Evans’s practice and minimize recurrence risk, while still sending a clear signal of disapproval.

In the broader legal context, Lawyer Disciplinary Board v. Evans reinforces core principles of client protection—especially in property and trust‑account contexts—and clarifies how West Virginia calibrates sanctions in serious, yet single‑matter, misconduct cases. It underscores that even when misconduct stems from one matter, a prolonged pattern of neglect, dishonesty, and procedural defiance will draw substantial discipline, and that safeguarding client and third‑party funds remains central to the integrity of the legal profession.

Safeguarding Client Funds and Calibrating Sanctions for Single-Matter Misconduct: Commentary on Lawyer Disciplinary Board v. Evans, III