July 24, 2025 | Grand Rapids, MI
Wayne F. Crowe (P77374), a practicing attorney based in Grand Rapids, Michigan, has been suspended from the practice of law in Michigan for a period of 90 days, effective July 19, 2025. This disciplinary action comes as a result of reciprocal discipline proceedings, following a prior suspension in the state of New York.
The proceedings stemmed from a March 7, 2022 suspension imposed by the Supreme Court of New York in the matter titled In the Matter of Wayne F. Crowe, an Attorney, Case No. 2021‑03603. The New York court suspended Crowe’s license to practice law for three months.
Under Michigan Court Rule 9.120(C), which governs reciprocal discipline, the Grievance Administrator submitted a certified copy of the New York order to initiate comparable proceedings in Michigan. Crowe was served with notice of the potential reciprocal discipline on August 18, 2023, and subsequently filed a timely objection. The matter was reviewed by Kent County Hearing Panel #6.
After reviewing briefs from both parties, the panel determined that Crowe failed to demonstrate that the original New York proceedings had violated his due process rights or that imposing similar discipline in Michigan would be clearly inappropriate. As a result, the panel ordered a 90-day suspension—mirroring the original New York sanction.
Crowe petitioned for a review and was granted a temporary stay under MCR 9.115(K). After additional proceedings under MCR 9.118, the Attorney Discipline Board upheld the panel’s decision. Crowe’s motion for reconsideration was denied on March 10, 2025, and his application for leave to appeal to the Michigan Supreme Court was similarly denied on June 27, 2025.
In addition to the suspension, costs totaling $1,720.23 were assessed.
This case highlights the wide-reaching implications of attorney misconduct across state lines and reinforces the principle that professional accountability extends beyond jurisdictional borders.
