On Wednesday, May 21, 2025, the Supreme Court of Wyoming publicly censured attorney Letitia C. Abromats for violating professional conduct rules during her representation of the Ellerbee Heirs in a property dispute. The court found clear and convincing evidence that Abromats breached Rules 1.3 (diligence) and 1.4(b) (communication) of the Wyoming Rules of Professional Conduct.
The case is entitled “Board of Professional Responsibility, Wyoming State Bar v. Letitia C. Abromats,” with case no. D-25-0001.
The case stemmed from Abromats’s representation of Curt Ellerbee and his co-heirs, who inherited properties in Basin, Wyoming, from John Ellerbee. The heirs sought to enforce agreements related to two properties, one occupied by the Tepperts and another comprising two parcels occupied by Curt and Nicole Earl.
In March 2022, Curt Ellerbee hired Abromats to pursue forcible entry and detainer actions against the occupants, who were in default on loans from John Ellerbee. Abromats received documents from Curt, including a 2012 Warranty Deed and Mortgage for one parcel and a 2015 agreement involving both parcels. After reviewing these, she advised foreclosure proceedings instead of forcible entry, and the heirs signed a fee agreement for foreclosure services, paying $2,000, $1,000 of which pertained to the case against the Earls.
In May 2022, Abromats informed Curt of two judgment liens against the Earls’ parcel filed by Collection Professionals, Inc., totaling over $8,787.54. However, she did not investigate further liens, missing two additional ones: a $23,233.72 lien by Chetan Patel and a $4,909.98 lien by Rocky Mountain Recovery Systems, Inc. Notably, Abromats had previously represented Patel in a related action, creating a conflict of interest she failed to address initially.
In July 2022, without discussing other options with Curt, Abromats recorded a quitclaim deed for the Earls’ parcels, believing it was appropriate due to a 2015 agreement she interpreted as creating a contract for deed. She then served the Earls with a notice to quit, and they vacated the property.
In August 2022, Curt sought Abromats’s help to remove the Patel and Rocky Mountain liens, which hindered the sale of the property. In November, Curt requested a refund of the $2,000 fee, but Abromats declined, stating she had earned the fee. She also claimed the liens were unenforceable due to the Earls’ equitable interest, a position contradicted by a title company, which determined the Earls held legal title to one parcel, making the liens valid. The heirs paid over $13,000 to clear these liens to complete the sale.
The Wyoming State Bar investigated a complaint against Abromats, leading to formal charges in March 2024. The Board of Professional Responsibility (BPR) held a hearing and recommended public censure, finding Abromats failed to diligently investigate the property’s title, recognize the Earls’ legal title, check for additional liens, and inform her clients of their legal options and consequences.
The Supreme Court upheld these findings, noting Abromats’s negligence caused the heirs to lose the opportunity to make informed decisions, resulting in financial harm.
The court ordered Abromats to complete three hours of continuing legal education on deeds, mortgages, and real estate transactions by June 2, 2025. She must also pay $2,616.15 in disciplinary proceeding costs and a $750 administrative fee to the Wyoming State Bar.
The Disposition states:
“IT IS, THEREFORE, ORDERED THAT: Letitia C. Abromats is hereby publicly censured for her violations of Rules 1.3 and 1.4(b).”
According to Avvo.com, Ms. Abromats is a litigation attorney in Greybull, Wyoming. She acquired her law license in Wyoming in 2014.
A copy of the original filing can be found here.
