In re Disciplinary Action Against Harrigan, 841 N.W.2d 624

OLPR filed a petition for disciplinary action against Thomas G. Harrigan for misappropriation and misrepresentation related to two clients, L.S. and N.W., and for failure to cooperate during investigation.
Harrigan deposited L.S.'s CNA IRA proceeds into his trust account and paid herself $100,857.35 without L.S.'s knowledge or consent, without providing an accounting.
Harrigan received and deposited a Vanguard redemption check for L.S.'s benefit and again disbursed funds to himself without authorization or accounting.
Harrigan falsely claimed a claim froze the CNA account and delayed distributions; failed to respond adequately to substitute counsel and OLPR requests for information.
For N.W., Harrigan deposited $72,000 settlement funds into his trust account, paid himself $48,000, and later paid an additional amount to himself, withholding about $24,000 from N.W.
The referee found misappropriation totaling over $130,000, misrepresentations, and noncooperation; Harrigan did not participate in the proceedings and did not restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Harrigan's misappropriation violates professional conduct.	Harrigan misappropriated client funds.	Harrigan disputes misappropriation or its extent.	Yes; misappropriation occurred and supports disbarment.
Whether Harrigan's misrepresentations to clients and the OLPR constitute professional misconduct.	Misrepresentations violated Rule 4.1 and related norms.	Harrigan denied specifics or offered defenses but failed to cooperate.	Yes; misrepresentations and noncooperation constitute professional misconduct.
Whether Harrigan's failure to cooperate with the disciplinary process justifies a harsher sanction.	Noncooperation aggravated the misconduct and sanction.	Harrigan did not participate; any defense was lacking.	Yes; noncooperation increases severity of sanction.
Whether the cumulative weight and circumstances justify disbarment.	Multiple, substantial violations with significant harm require disbarment.	No defense offered; argument rests on misconduct details.	Yes; cumulative violations and harm support disbarment.
Whether aggravating factors (vulnerability of clients, experience, lack of restitution, selfish motive) support disbarment.	Aggravating factors are present and severe.	No mitigating factors; Harrigan acknowledges none.	Yes; aggravating factors support disbarment.

In re Fru, 829 N.W.2d 379 (Minn. 2013) (guides discipline standards and weight of aggravating/mitigating factors)
In re Rebeau, 787 N.W.2d 168 (Minn. 2010) (substantial experience as aggravating factor)
In re Jones, 834 N.W.2d 671 (Minn. 2013) (misappropriation extent informs presumptive punishment)
In re Wentzel, 711 N.W.2d 516 (Minn. 2006) (misappropriation analyzed as multiple incidents affects discipline)
In re Rooney, 709 N.W.2d 263 (Minn. 2006) (misappropriation harms public confidence; failure to cooperate noted)
In re Ruttger, 566 N.W.2d 327 (Minn. 1997) (misappropriation breaches fiduciary duty and harms profession)
In re Ulanowslci, 834 N.W.2d 697 (Minn. 2013) (disciplinary process integrity and cooperation)