Disciplinary Counsel v. Parnoff, 324 Conn. 505

Yuille won a ~$1.1M arbitration award; Parnoff (her attorney) had a 40% contingency fee agreement but Yuille disputed the fee and allocation to a prior lawyer, Mooney.
Parnoff placed the disputed portion ($313,413.17) into a Chase CD as escrow in 2004 and later took $125,000 earlier; after a jury verdict in 2010 resolving some claims, Parnoff allowed the CD to mature and transferred the disputed funds to his personal account in July 2010.
Yuille filed a grievance; a reviewing committee found Parnoff violated Rule 1.15(f) (holding disputed client property separate) by clear and convincing evidence.
Disciplinary Counsel filed a presentment under Practice Book § 2-47A seeking mandatory disbarment (minimum 12 years) based on a judge’s finding that Parnoff had "knowingly misappropriated" client funds.
The trial court found Parnoff knowingly appropriated the funds but concluded he lacked intent to steal or deceive (acted negligently/unreasonably), and issued a formal reprimand instead of disbarment.
The Appellate Court affirmed; the Supreme Court affirmed the Appellate Court, holding § 2-47A requires both knowledge and wrongful intent (i.e., theft) to trigger mandatory disbarment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of "knowingly misappropriated" under Practice Book § 2-47A	§ 2-47A requires only that an attorney knowingly appropriate disputed client funds; intent to steal is irrelevant	"Misappropriated" requires wrongful/dishonest intent; knowledge alone is insufficient	"Knowingly misappropriated" requires both actual knowledge and intent to wrongfully take (i.e., theft); mere knowing appropriation without intent to steal does not trigger mandatory disbarment
Application to Parnoff's conduct	Parnoff knowingly removed escrowed funds → mandatory disbarment required regardless of his subjective belief	Parnoff believed (albeit unreasonably) he was entitled to the funds and lacked intent to steal; discipline short of disbarment appropriate	Parnoff knowingly appropriated the funds but did not act with intent to steal; therefore § 2-47A's mandatory disbarment did not apply; reprimand upheld

In re Wilson, 81 N.J. 451 (N.J. 1979) (broad definition of misappropriation as any unauthorized use of client funds, often resulting in mandatory disbarment)
Potvin v. Lincoln Service & Equipment Co., 298 Conn. 620 (Conn. 2010) (use dictionary meaning when statutory or rule terms are undefined)
State v. Pulley, 46 Conn.App. 414 (Conn. App. Ct. 1997) (larceny requires specific intent to deprive or misappropriate)
Disciplinary Counsel v. Parnoff, 158 Conn.App. 454 (Conn. App. Ct. 2015) (Appellate Court affirmed trial court’s interpretation that intent matters for § 2-47A)