A Wappingers Falls lawyer who misappropriated client funds has been suspended from the practice of law for three years.
The New York Second Appellate Court in Brooklyn concluded on June 18 that Patrick Sylvanus Tittle “engaged in conduct adversely reflecting on his fitness as a lawyer.”
A lawyers’ grievance committee petitioned the court in 2023 to discipline Tittle. He did not dispute the facts and he consented to the sanction.
Tittle was admitted to the New York Bar in 1995. He developed a diverse practice that included criminal, real estate, personal injury and family law.
Tittle held two bank accounts for handling client funds and disbursements.
As of Jan. 1, 2019, he was required to maintain at least $173,405 in one account, on behalf of six clients. The balance, however, was $5,424.
From February through July 2019, he wrote 27 checks totaling $122,175. The disbursements cleared, in part, with funds received for unrelated matters, but the account ran up a deficit of $241,541.
In one client matter, for instance, he received $198,000. He wired $24,800 to a third party involved in the matter and $5,000 to himself. When the bank issued a chargeback, or refund, that removed the funds from the account, Tittle did not return the money he had disbursed.
Tittle claimed that he was the victim of a scam, according to the appellate court decision, and that he had taken steps to recuperate the loss of funds.
In October 2019, Tittle wrote a $2,950 check on another bank account, when the account had a deficit of $244,592.
Tittle admitted to the appellate court that he misappropriated funds and failed to keep track of financial transactions.
In reaching its decision, the appellate court weighed the duration of the improper banking practices and the size of the deficits, as well as a previous discipline in 2015 for neglecting a client matter.
The court also considered Tittle’s cooperation with the investigation and the absence of complaints or claims about losses, from clients and others, due to his misconduct.
Tittle may apply for reinstatement in February 2028.
