ESQ HQNEW YORK LAW WATCH

Appellate Division, First Department · October 15, 2026 · 2026 NY Slip Op 06014

Matter of Sokolski

Read the official decision: 2026 NY Slip Op 06014

Holding The court affirmed the finding of professional misconduct for failure to maintain bookkeeping records, rejecting the argument that rule 1.15(d) applies only to the attorney who personally conducts transactions. The court imposed a three-month suspension, determining that the respondent’s prolonged neglect of fiduciary duties despite warning signs warranted a sanction more severe than the recommended public censure.

The court’s words

The fiduciary obligations imposed by rule 1.15 are personal and non-delegable.

2026 NY Slip Op 06014, at the official text

such absolute reliance on another is not a viable defense to these charges

2026 NY Slip Op 06014, at the official text

Few, if any, of an attorney's professional obligations are as crystal clear as the duty to safeguard client funds

2026 NY Slip Op 06014, at the official text

respondent's inattention persisted for years, while he remained an owner and escrow signatory

2026 NY Slip Op 06014, at the official text
CourtAppellate Division, First Department
DecidedOctober 15, 2026
Citation2026 NY Slip Op 06014
Area of lawAttorney Discipline and Professional Responsibility
WeekWeek ending October 17, 2026
Official textOfficial decision: 2026 NY Slip Op 06014
Publication statusSlip opinions are uncorrected and subject to revision before publication in the Official Reports.
Source feedNew York slip opinion page
Law Watch record id1270

Recommended citation

ESQ HQ, New York Law Watch, Matter of Sokolski, 2026 NY Slip Op 06014 (Appellate Division, First Department, October 15, 2026), https://esqhq.com/decisions/2026-ny-slip-op-06014/

How this record was made

Holding drafted by Law Watch’s in-house model, graded by three reviewers; every quotation verified word for word against the official text.

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Published October 15, 2026. Updated October 15, 2026.