Nov. 12, 2025 – Your client says you stole from them – and they’ve told the
Wisconsin Lawyers’ Fund for Client Protection. A WLFCP allegation of misconduct is serious, yet not every claim proves wrongdoing.
Here is how the process unfolds and how to respond effectively.
What is the Fund for Client Protection?
The WLFCP, established by the Wisconsin Supreme Court, helps clients who have suffered a financial loss due to the dishonest conduct of their attorney.
Dishonest conduct is defined by
Supreme Court Rule 12.045 to include a willful act to embezzle; an intentional taking or conversion of money, property, or other thing of value; or the failure to refund an unearned advanced fee.
The fund is administered by the State Bar of Wisconsin. Claims are reviewed by the Wisconsin Lawyers' Fund for Client Protection Committee, which has five lawyer members and two non-lawyer members. The committee’s task is to pay back funds taken dishonestly from clients by their lawyer.
Over the past fiscal year (2024-25) the committee approved 32 claims involving nine attorneys, amounting to reimbursements totaling $72,387. The fund is an important and vital way to restore faith in the legal system.
How Are Claims Processed?
The WLFCP program processes every claim. A copy of the claim application and any supporting materials are sent to the named attorney by certified mail.
Attorneys have 45 days to respond or request an extension. The committee meets 3-4 times per year to review claims, making a decision to reimburse or deny each claim.
While attorneys are not required under SCR chapter 12 to respond or cooperate, an attorney response helps guide the committee’s decision. Attorneys should respond, especially if they believe the claim is ineligible for reimbursement. Common responses from attorneys include evidence that paid fees were earned, such as invoices showing billing statements, communication with the claimant regarding billing details, copies of work product, or any other materials the attorney wishes to include.
The program shares information with the Office of Lawyer Regulation relating to the alleged loss detailed by claimants.
You’ve Been Named in a Claim – Now What? Tips from a Committee Member
Here are tips from Stacie Rosenzweig, a member of the WLFCP committee:
I have a claim against me and I’m panicking!
First, deep breaths. The mere existence of a claim does not mean you did anything wrong – clients file claims for a variety of reasons, and it often has nothing to do with the lawyer's performance of their duties or use of their money. They are sometimes upset that legal services cost money at all, or that their case did not end up the way they wanted.
How long does this process take?
It can take several months. Once a claim is filed, staff need to investigate and reach out to the lawyer and get their input. Staff may also need to go back to the person who made the claim for more information before there is enough to present to the committee. The committee typically meets only a few times a year, and a matter may be discussed at more than one meeting.
Is there a hearing? How do I dispute this claim?
There is no hearing process. Lawyers are invited to respond – and should respond. The committee will only approve claims when clients have suffered a financial loss due to the dishonest conduct of their attorney (which can include a willful or intentional act of misappropriation or conversion, or the failure to refund an unearned advanced fee). That means that the committee does not approve claims that are based in malpractice or a fee dispute. So, responding with the fee agreement, invoices, proof of payment, and proof of the work performed will go a long way.
How should attorneys lessen their chances of having a claim against them?
Sometimes claims are unavoidable, and most claims are closed without payment – anyone can file a claim, and when attorneys use the alternative protections for funds not kept in trust (SCR 1.5(g)), they have to provide their clients with information about how to make a Fund claim, making it statistically more likely that those clients will avail themselves of that information.
That said, communication with your clients about fees and costs is key – if you have an hourly matter, invoicing monthly rather than quarterly or ad hoc can go a long way. For all kinds of fees, clear communication about when a fee is earned and when payments must be refunded is key. For contingency cases, a detailed settlement statement and timely disbursement of funds will help.
Another important activity is planning for succession and emergencies – a good number of the claims the committee reviews arise because a lawyer has become incapacitated or died, and they did not make plans (or share plans) for what would happen in the event they could not continue practicing.
Approved Claims for 2024-25
Between July 1, 2024, and June 30, 2025, the Wisconsin Lawyers' Fund for Client Protection Committee approved 32 claims involving nine attorneys, amounting to reimbursements totaling $72,386.71.
The approved claims against these attorneys are for failing to refund unearned advanced fees:
- Jair Alvarez: $2,000 for two claims
- Michael Padden: $3,000 for one claim
- George Pappas Jr: $4,200 for two claims
- David Patton: $10,500 for three claims
- Jevon Jaconi: $29,981.71 for 17 claims*
- Harold Block: $1,405 for one claim*
- Victor Bayata: $5,000 for one claim*
- Steven Sarbacker: $3,300 for two claims*
- Michael Bishop: $13,000 for three claims*
*These attorneys died during representation and with active practices. SCR chapter 12 permits the WLFCP to reimburse claimants who experienced financial loss in the form of a failure to refund an unearned advanced fee due to the death of their attorney. For resources and support to create a succession plan for your law practice – and thus avoid such claims – visit
the succession planning page on WisBar.org
