Attorney Michelle L. Elowski Disbarred and Ordered to Pay Over $266,000 in Restitution Following Client Fund Misappropriation

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. Elowski’s Michigan law license had been continuously suspended since January 16, 2025, pursuant to an automatic interim suspension in Case No. 25-15-AI.

Underlying Conduct

The Grievance Administrator filed a formal complaint alleging widespread misconduct involving client funds. The matter proceeded in substantial part by default — Elowski did not meaningfully participate in the disciplinary process. Based on her 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-FH and 24-1954-FH, the panel found that Elowski misappropriated funds from multiple clients across matters for which she had been retained. The misconduct resulted in criminal convictions and substantial financial harm to clients.

Hearing Panel Findings

The panel found violations across multiple professional conduct and court rules. On the conduct side: Elowski failed to act with reasonable diligence (MRPC 1.3), failed to keep clients informed and explain matters (MRPC 1.4(a), (b)), failed to deliver funds clients were entitled to receive (MRPC 1.5(b)(3)), deposited client funds into her personal account in violation of safeguarding requirements (MRPC 1.15(d)), made false statements in connection with disciplinary proceedings (MRPC 8.1(a)), and engaged in dishonesty and conduct reflecting adversely on fitness to practice (MRPC 8.4(b)). The panel further found violations of MCR 9.104(2) through (6) — covering conduct exposing the profession to reproach, conduct contrary to justice and honesty, violation of professional standards adopted by the Supreme Court, criminal law violations, and knowing misrepresentations during a disciplinary investigation — and MCR 2.615 for criminal conduct.

Sanction

The panel ordered disbarment effective January 30, 2026, restitution of $266,091.90, and costs of $3,933.69. On January 29, 2026, Elowski filed a timely 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 — and the role of restitution in attempting to address client losses. The pending review serves as a reminder that even severe sanctions remain subject to the disciplinary appellate process until that process concludes.