The Michigan Attorney Discipline Board has issued a reprimand with conditions against Brandon T. Wolfe (P82421) of Troy, Michigan, following findings that he mishandled funds held in his client trust account.
The reprimand is effective November 13, 2025, and was imposed pursuant to a consent discipline agreement between Wolfe and the Grievance Administrator.
Background: Consent Discipline and Stipulated Findings
According to the notice, Wolfe and the Grievance Administrator filed a Stipulation for Consent Order of Discipline under Michigan Court Rule 9.115(F)(5). The stipulation was approved by the Attorney Grievance Commission and accepted by Tri-County Hearing Panel #65.
Based on the parties’ stipulation and Wolfe’s pleas of no contest, the hearing panel found that Wolfe committed professional misconduct related to the handling of funds in his IOLTA trust account.
Misconduct Findings
The panel found that Wolfe:
- Failed to hold property of clients or third persons separate from his own property, in violation of MRPC 1.15(d).
- Deposited his own funds into a client trust account in excess of the limited amount permitted to cover bank service charges or obtain a fee waiver, in violation of MRPC 1.15(f).
The panel further concluded that this conduct violated Michigan Court Rule 9.104(2) through (4), which address conduct exposing the legal profession to reproach, conduct contrary to justice or ethics, and violations of professional conduct standards adopted by the Michigan Supreme Court.
Panel Order and Sanctions
In accordance with the consent stipulation, the hearing panel ordered that:
- Wolfe be reprimanded.
- Wolfe comply with conditions related to the established misconduct.
- Wolfe pay costs in the amount of $761.82.
No suspension was imposed as part of this discipline.
What This Means
Trust account rules exist to protect client funds and preserve confidence in the legal profession. Even where misconduct is resolved by consent and without suspension, violations involving IOLTA accounts are treated as serious ethical failures.
This case underscores the obligation of attorneys to strictly segregate client funds and adhere to trust account requirements, regardless of intent or outcome.
