Case Information
Attorney: Michelle L. Elowski (P 74608)
Case No.: 24-018-GA
City: Alpena, Michigan
Discipline: Disbarment and Restitution
Effective Date: January 30, 2026
Review Status: Petition for review pending before the Attorney Discipline Board
Quick Facts
Who is the attorney?
Michelle L. Elowski, P 74608, Alpena, Michigan.
What discipline was imposed?
Disbarment and an order of restitution totaling $266,091.90.
Why was discipline imposed?
Findings that Elowski misappropriated client funds, failed to safeguard and account for those funds, and engaged in criminal conduct resulting in felony convictions.
Did the attorney participate in the disciplinary process?
No. The matter proceeded in substantial part by default.
Is the discipline final?
A petition for review was timely filed and is currently pending before the Attorney Discipline Board.
Were costs assessed?
Yes. Costs of $3,933.69 were assessed.
Discipline Summary
The Attorney Discipline Board hearing panel ordered the disbarment of Michelle L. Elowski and imposed restitution exceeding $266,000 following findings that she misappropriated funds from multiple clients and engaged in criminal conduct related to those acts.
The order became effective January 30, 2026, subject to pending review.
Applicable Court Rules
This matter proceeded under Michigan Court Rules and Michigan Rules of Professional Conduct governing client funds, honesty, criminal conduct, and disciplinary compliance, including:
Michigan Rules of Professional Conduct
- MRPC 1.3 – Failure to act with reasonable diligence and promptness
- MRPC 1.4(a), (b) – Failure to communicate and explain matters to clients
- MRPC 1.5(b)(3) – Failure to pay or deliver funds a client is entitled to receive
- MRPC 1.15(d) – Failure to safeguard client funds
- MRPC 8.1(a) – False statements in disciplinary matters
- MRPC 8.4(a), (b) – Professional misconduct involving dishonesty or criminal conduct
Michigan Court Rules
- MCR 2.615 – Criminal law violations as grounds for discipline
- MCR 9.104(2)–(6) – Grounds for discipline
- MCR 9.118 – Petition for review
As with all attorney discipline matters, this action falls under Michigan Court Rules, Chapter 9, including the Attorney Discipline Board’s authority under MCR 9.115.
Underlying Conduct
The Grievance Administrator filed a formal complaint against Elowski alleging widespread misconduct involving client funds.
Based on Elowski’s default, corroborating witness testimony, documentary evidence, and her no contest pleas in People of the State of Michigan v Michelle Lynn Elowski, Oscoda County 23rd Circuit Court, Case Nos. 24-1953-FHand 24-1954-FH, the panel found that Elowski misappropriated funds from multiple clients in matters for which she had been retained.
The misconduct resulted in criminal convictions and substantial financial harm to clients.
Hearing Panel Findings
Based on the record and respondent’s default, the hearing panel found that Elowski committed professional misconduct by:
- Failing to act with reasonable diligence (MRPC 1.3)
- Failing to keep clients informed and explain matters (MRPC 1.4(a), (b))
- Failing to deliver funds clients were entitled to receive (MRPC 1.5(b)(3))
- Depositing client funds into her personal account (MRPC 1.15(d))
- Making false statements in connection with disciplinary proceedings (MRPC 8.1(a))
- Engaging in dishonesty, fraud, deceit, or misrepresentation reflecting adversely on fitness to practice (MRPC 8.4(b))
- Engaging in conduct exposing the profession to reproach (MCR 9.104(2))
- Engaging in conduct contrary to justice, ethics, honesty, or good morals (MCR 9.104(3))
- Violating professional standards adopted by the Supreme Court (MRPC 8.4(a); MCR 9.104(4))
- Engaging in conduct violating criminal laws (MCR 9.104(5); MCR 2.615)
- Making knowing misrepresentations during a disciplinary investigation (MCR 9.104(6))
Sanction
The hearing panel ordered that Michelle L. Elowski be disbarred, effective January 30, 2026.
The panel further ordered that Elowski pay restitution totaling $266,091.90 and costs of $3,933.69.
Elowski’s Michigan law license had been continuously suspended since January 16, 2025, pursuant to an automatic interim suspension issued in Grievance Administrator v Michelle L. Elowski, Case No. 25-15-AI.
On January 29, 2026, Elowski timely filed a petition for review pursuant to MCR 9.118, which remains pending before the Attorney Discipline Board.
Why This Matters
Misappropriation of client funds is among the most serious forms of attorney misconduct and almost invariably results in disbarment.
This case illustrates the scale of harm that can occur when fiduciary duties are breached, as well as the role of restitution in attempting to address client losses. It also underscores that disciplinary outcomes may remain subject to review, even after severe sanctions are imposed.
