On Wednesday, June 18, 2025, the Supreme Court of the State of New York, Appellate Division: Second Judicial Department, granted a joint motion for discipline by consent concerning attorney Patrick Sylvanus Tittle. This decision follows a series of allegations against Tittle regarding the misappropriation of client funds and violations of professional conduct rules.
The case is entitled “In the Matter of Patrick Sylvanus Tittle,” with case number 2023-08035.
The Grievance Committee for the Ninth Judicial District initiated the proceedings against Tittle, who was admitted to the Bar on February 6, 1995. The committee served Tittle with a notice of petition and a verified petition on August 16, 2023. Tittle provided a verified answer by October 25, 2023, and subsequently, both parties submitted statements of disputed and undisputed facts in November 2023.
As part of the disciplinary proceedings, John J. Halloran, Jr. was appointed as Special Referee to hear and report on the matter by a decision dated December 21, 2023. Following further discussions, Tittle and the Grievance Committee reached a joint motion under 22 NYCRR 1240.8(a)(5) for discipline by consent, proposing a suspension period ranging from two to three years.
The factual basis for the motion included Tittle’s maintenance of two attorney escrow accounts at Bank of America. The first account, titled “Patrick S Tittle, P.C. Atty, IOLA Fund,” was required to have a balance of at least $173,405.35 by January 1, 2019. However, the account only had $5,424.24, resulting in a shortfall of $167,981.11.
Between February 4 and July 25, 2019, Tittle withdrew a total of $122,174.68 from the escrow account through multiple checks and one withdrawal, without sufficient funds to cover these transactions. At the time of these withdrawals, the account was already in deficit by $241,541.03.
In a separate matter, on July 11, 2019, Tittle received a deposit of $198,000 related to a client, the Wang matter. Five days later, he disbursed $24,800 to a third party and $5,000 to himself. Following a chargeback on the deposit, Tittle did not return any of the funds he had disbursed, further increasing the account’s deficit.
Additionally, on October 16, 2019, Tittle wrote a check for $2,950 from his second escrow account, “Patrick S Tittle, P.C. Atty, NY IOLA Attorney Trust Account,” despite lacking the necessary funds in the account. This action contributed to a deficit of $244,591.68 in that account.
The Grievance Committee found that Tittle failed to maintain accurate financial records and did not adequately identify his special bank accounts, violating several rules of professional conduct. Tittle admitted to misappropriating client funds and failing to maintain proper bookkeeping records.
In their joint motion, the parties requested that the court consider Tittle’s prior disciplinary history, which included a Letter of Caution in 2015 for neglecting a client matter. However, they noted Tittle’s cooperation with the investigation and the absence of client complaints regarding out-of-pocket losses due to his misconduct.
The court ultimately determined that a three-year suspension was warranted, taking into account the seriousness of Tittle’s actions and the aggravating and mitigating factors. The suspension is set to commence on July 18, 2025, and Tittle will be eligible to apply for reinstatement no earlier than February 17, 2028.
As part of the ruling, Tittle is prohibited from practicing law during the suspension period and must comply with the terms set forth for disbarred or suspended attorneys. Additionally, any secure passes issued to him by the Office of Court Administration must be returned.
According to Avvo, Mr. Tittle is an animal and dog bites lawyer in Wappingers Falls, NY. He acquired his law license in New York in 1995.
A copy of the original filing can be found here.
