Skip to content
A Member of the Law Professor Blogs Network

Captive Clients

The Wisconsin Supreme Court imposed reciprocal discipline based on an Arizona suspension of six months and a day.

Attorney Manion communicated with an inmate client in a criminal matter almost exclusively through another inmate who was serving a sentence for criminal fraud. Attorney Manion’s client suffered financial harm at the hands of the inmate who Attorney Manion used as the intermediary. Attorney Manion also transferred funds, at the direction of multiple inmates, in a manner that allowed the inmates to circumvent prison policy thereby violating multiple Arizona trust account rules including ER 1.4, ER 1.15(a), ER 8.4(d), Rule 43(b)(1)(A), Rule 43(b)(a)(C) and Rule 43(b)(5).

In addition, Attorney Manion assisted an inmate client in collecting a share of an inheritance. Attorney Manion distributed the money at the client’s direction in a manner that allowed the client to circumvent prison policy. The client also suffered financial harm due to the fraudulent actions of the same inmate Attorney Manion used as the intermediary in Count One. By these actions Attorney Manion violated ER 1.4, ER 1.6, ER 1.7, and ER 8.4(d).

The court imposed a six-month suspension. (Mike Frisch)