Disciplinary Counsel v. Laurence Parnoff

Summary

The court held that mandatory disbarment under Practice Book § 2-47A requires an attorney to knowingly and intentionally misappropriate client funds, meaning to steal or take them wrongfully, dishonestly, or illegally. Because the defendant knowingly transferred disputed escrow funds but acted under an unreasonable, nondeceptive belief that he was entitled to them, his conduct did not constitute knowing misappropriation requiring disbarment. The court therefore affirmed the Appellate Court's judgment upholding a reprimand.