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
| Court | Appellate Division, First Department |
|---|---|
| Decided | October 15, 2026 |
| Citation | 2026 NY Slip Op 06014 |
| Area of law | Attorney Discipline and Professional Responsibility |
| Week | Week ending October 17, 2026 |
| Official text | Official decision: 2026 NY Slip Op 06014 |
| Publication status | Slip opinions are uncorrected and subject to revision before publication in the Official Reports. |
| Source feed | New York slip opinion page |
| Law Watch record id | 1270 |
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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