On Wednesday, December 7, 2022, the Attorney Discipline Board of the State of Michigan, issued a Notice of Suspension (By Consent) relating to the charges for attorney discipline against Southfield attorney Michael D. Langnas for IOLTA violations.

The case was brought by the Michigan Attorney Grievance Commission, Case Nos. 22-48-GA.

The charges cited Langnas’ violation of the Michigan Rules of Professional Conduct specifically rules 1.15(a)(3), 1.15(f), and 8.4(a).

The Michigan Rules of Professional Conduct can be found here.

The following are as alleged and summarized from the filing:

The complaint alleged that the Attorney Grievance Commission received a notice that a check presented against Langnas’s IOLTA account was rejected due to insufficiency of funds and resulted in an overdraft. During a grievance investigation, Langnas admitted that he transferred future payroll funds into his IOLTA to secure funds from levy and possible garnishment. Langnas further admitted that he deposited earned fees to his IOLTA, and used it to make premium payments for his legal malpractice insurance.

According to the filing:

“Respondent and the Grievance Administrator filed a Stipulation for Consent Order Discipline, in accordance with MCR 9.115(F)(5), which was approved by the Attorney Grievance Commission and accepted by the hearing panel. The stipulation contained respondent’s admissions to the factual allegations of professional misconduct set forth in the formal complaint in its entirety.”

Correspondingly, in accordance with the stipulation of the parties, the hearing panel ordered that respondent’s license to practice law in Michigan be suspended for 30 days, effective December 12, 2022. Costs were assessed in the amount of $759.17.

The Board, in its Notice of Suspension (By Consent), stated:

“Michael D. Langnas, P 42357, Southfield, Michigan, by the Attorney Discipline Board Tri-County Hearing Panel #56

Suspension – 30 days, Effective December 12, 2022”

Prior to the suspension, Mr. Langnas practiced in Southfield, Michigan. He is the owner of Langnas & Associate, P.C. Langnas earned his Juris doctorate from the University of Detroit in 1989. He has been licensed in Michigan. His info can be found on Avvo,

A copy of the original filing can be found here.