Michigan Attorney Discipline Report — May/June 2026

Underlying Conduct

The Grievance Administrator filed a formal complaint against Elowski. When Elowski failed to respond, the panel proceeded on default. The record before the panel included witness testimony, documentary evidence, and Elowski’s no-contest plea to the criminal charges in Oscoda County Circuit Court.

The panel found that Elowski misappropriated funds from multiple clients in matters for which she had been retained. Specifically, the panel found she failed to keep client funds separate from her own property by depositing those funds into her personal account. Her conduct resulted in criminal conviction on two felony charges.

Panel Findings and Rule Violations

Based on the default, testimony, and documentary record, the panel found violations of MRPC 1.3 (diligence), MRPC 1.4(a) and (b) (client communication), MRPC 1.5(b)(3) (failure to deliver funds), MRPC 1.15(d) (safekeeping of client property), MRPC 8.1(a) (false statement in a disciplinary matter), MRPC 8.4(b) (dishonesty, fraud, deceit, or misrepresentation), MCR 9.104(2) (conduct exposing the profession to contempt), MCR 9.104(3) (conduct contrary to justice, ethics, honesty, or good morals), MRPC 8.4(a) and MCR 9.104(4) (violation of professional conduct standards), MCR 9.104(5) (violation of criminal law), and MCR 9.104(6) (misrepresentation in connection with a request for investigation or complaint).

Sanction

The panel ordered disbarment effective January 30, 2026, and restitution of $266,091.90. Costs of $3,933.69 were assessed. Elowski timely filed a petition for review under MCR 9.118 on January 29, 2026. Following Board proceedings, the Attorney Discipline Board affirmed the disbarment and reduced the restitution to $201,591.90. No additional costs were assessed at the review stage.

Underlying Conduct

Bland and the Grievance Administrator filed an Amended Stipulation for Consent Order of Discipline under MCR 9.115(F)(5). Bland admitted to the factual allegations in paragraphs 5 through 22 of the formal complaint and entered a no-contest plea to the professional misconduct allegations in subparagraphs 23(a) through (e).

The admitted conduct: Bland entered into a romantic and sexual relationship with a client during the course of representing her in a divorce matter.

Panel Findings and Rule Violations

Based on the admissions set forth in the parties’ amended stipulation, the panel found that Bland represented a client where the representation was materially limited by his own interests, in violation of MRPC 1.7(b). The panel further found violations of MRPC 8.4(c) and MCR 9.104(1) (conduct prejudicial to the administration of justice), MCR 9.104(2) (conduct exposing the profession or courts to obloquy, contempt, censure, or reproach), MCR 9.104(3) (conduct contrary to justice, ethics, honesty, or good morals), and MRPC 8.4(a) and MCR 9.104(4) (violation of professional conduct standards).

Sanction

In accordance with the amended stipulation, the panel ordered a 45-day suspension effective May 26, 2026. Total costs of $931.87 were assessed.

Underlying Conduct

Tucker and the Grievance Administrator filed a Stipulation for Consent Order of Discipline under MCR 9.115(F)(5). Tucker admitted to the factual allegations in the formal complaint, with the exception of paragraphs 5 and 10, to which she entered a no-contest plea. She admitted to all allegations of professional misconduct.

The conduct at issue arose after the death of a law firm’s principal attorney. Tucker assumed management of the firm and, in that role, failed to adequately supervise staff and client matters. That failure resulted in a missed appellate filing deadline. Tucker later obtained a liability release from a family member of the affected client without advising that person to seek independent legal counsel before signing.

Panel Findings and Rule Violations

Based on Tucker’s admissions, no-contest plea, and the parties’ stipulation, the panel found violations of MRPC 1.1(c) (neglect of a legal matter), MRPC 1.2(a) (failure to pursue lawful client objectives through reasonably available means), MRPC 1.3 (diligence), MRPC 1.8(h)(2) (failure to advise an unrepresented client or former client in writing that independent representation is appropriate before settling a malpractice-related claim), MRPC 3.2 (failure to expedite litigation), MRPC 5.3(a) (failure as a partner to ensure the firm has measures giving reasonable assurance that nonlawyer conduct is compatible with professional obligations), and MRPC 5.3(b) (failure as a supervising attorney to ensure nonlawyer conduct is compatible with professional obligations). The panel also found violations of MRPC 8.4(c) and MCR 9.104(1) through (4).

Sanction

In accordance with the parties’ stipulation, the panel ordered a reprimand with a condition relevant to the established misconduct. Costs of $1,310.59 were assessed.

Background

On April 21, 2026, the Attorney Discipline Board issued an Order of Reprimand against Lenney in Case No. 26-10-RD. That order required payment of $1,524.84 in assessed costs on or before May 20, 2026.

On May 21, 2026, the Board served a certified report on Lenney and the State Bar of Michigan confirming that the costs had not been paid within the prescribed period, as required under MCR 9.128(C).

Automatic Suspension

In accordance with MCR 9.128(D), Lenney’s Michigan license was automatically suspended effective May 29, 2026. The suspension remains in effect until the outstanding costs are paid or the Board approves a suitable payment plan, and until Lenney complies with the requirements of MCR 9.119 and MCR 9.123(A).

Underlying Conduct

Hallman and the Grievance Administrator filed a Stipulation for Consent Order of Reprimand under MCR 9.115(F)(5), approved by the Attorney Grievance Commission and accepted by Tri-County Hearing Panel #3. Hallman admitted that on December 16, 2024, he was convicted by guilty plea in People v. Hallman, 43rd Circuit Court, Case No. 24-37691-FY, of Improper Possession of a Firearm, a misdemeanor under MCL 750.227d, and that his conviction constitutes professional misconduct.

Panel Findings and Rule Violations

Based on Hallman’s conviction, admission, and the parties’ stipulation, the panel found that Hallman engaged in conduct violating a criminal law of the state or the United States, an ordinance, or tribal law pursuant to MCR 2.615, in violation of MCR 9.104(5). The case number designation (26-027-JC) reflects that this matter was initiated as a judgment of conviction filing rather than a general complaint action.

Sanction

In accordance with the parties’ stipulation, the panel ordered a reprimand. Costs of $760.25 were assessed.