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IN RE: DISCIPLINE OF JEROME R. BOWEN, BAR NO. 4540.
ORDER APPROVING CONDITIONAL ADMISSION AGREEMENT
This is an automatic review of a Southern Nevada Disciplinary Board hearing panel's recommendation that this court approve, pursuant to SCR 113, a conditional admission agreement in exchange for a stated form of discipline for attorney Jerome R. Bowen. Under the agreement, Bowen admitted to violating RPC 1.3 (diligence); RPC 1.15(a), (d), and (e) (safekeeping property); RPC 5.3(a) (responsibilities regarding nonlawyer assistants); and SCR 78(1)(b) (maintenance of trust funds in approved financial institutions; overdraft notification). Bowen agreed to a three-year suspension, stayed for two years subject to certain conditions.
Bowen admitted to mismanaging an IOLTA trust account by commingling and misappropriating funds, unreasonably delaying the distribution of settlement funds to clients, unreasonably delaying payments to lienholders, failing to respond to lienholder requests for information, and failing to properly maintain IOLTA trust account records. At one point, $126,761.74 of client funds were missing or misappropriated. Bowen also admitted to nonlawyer support staff using Bowen's own funds to cover potential problems with insufficient funds in the IOLTA trust account. Bowen further admitted to overly delegating responsibilities to nonlawyer support staff, whom he failed to adequately supervise. Bowen has since repaid the missing client funds.
The issue for this court is whether the agreed-upon discipline sufficiently protects the public, the courts, and the legal profession. See In re Discipline of Arabia, 137 Nev. 568, 571, 495 P.3d 1103, 1109 (2021) (stating the purpose of attorney discipline). In determining the appropriate discipline, we weigh four factors: “the duty violated, the lawyer's mental state, the potential or actual injury caused by the lawyer's misconduct, and the existence of aggravating or mitigating factors.” In re Discipline of Lerner, 124 Nev. 1232, 1246, 197 P.3d 1067, 1077 (2008); see also SCR 102.5(1).
Bowen admitted to knowingly violating duties owed to clients (safekeeping property and diligence) and duties owed as a professional (responsibilities regarding nonlawyer assistants). Bowen further admitted the conduct caused moderate actual injury to clients, third parties, and the integrity of the legal profession. The baseline for such violations, before considering the aggravating or mitigating circumstances, is suspension. See Standards for Imposing Lawyer Sanctions, Compendium of Professional Responsibility Rules and Standards, Standard 4.12 (Am. Bar Ass'n 2023) (providing that suspension is appropriate “when a lawyer knows or should know that he is dealing improperly with client property and causes injury or potential injury to a client”); Standard 4.42 (providing that suspension is appropriate when “a lawyer knowingly fails to perform services for a client and causes injury or potential injury to a client” or “engages in a pattern of neglect and causes injury or potential injury to a client”); Standard 7.2 (providing that suspension is appropriate “when a lawyer knowingly engages in conduct that is a violation of a duty owed as a professional and causes injury or potential injury to a client, the public, or the legal system”). The record supports four aggravating circumstances (pattern of misconduct, multiple offenses, multiple victims, and substantial experience in the practice of law) and six mitigating circumstances (absence of a prior disciplinary record, absence of a dishonest or selfish motive, timely good faith effort to make restitution or to rectify the consequences of misconduct, full and free disclosure to disciplinary authority or cooperative attitude toward proceeding, character or reputation, and remorse). Considering all four Lerner factors, we conclude that the agreed-upon discipline is appropriate.
Accordingly, we hereby suspend attorney Jerome R. Bowen from the practice of law in Nevada for three years, with the suspension stayed for two years from the date of this order, subject to the conditions outlined in the conditional admission agreement. Those conditions include requirements that Bowen read the “Trust Accounting in Nevada” publication available on the State Bar of Nevada's website; complete nine additional continuing legal education credits in the areas of practice management, IOLTA/trust accounting, and/or ethics each year of the stay period; engage in no misconduct involving client funds for which a reprimand is issued or a complaint is filed by the Office of Bar Counsel; and prepare monthly IOLTA reconciliation reports and provide them to the Office of Bar Counsel on a quarterly basis. Bowen shall also pay the cost of the disciplinary proceedings, including $2,500 under SCR 120, within 30 days from the date of this order. The State Bar shall comply with SCR 121.1.
It is so ORDERED.
Bell, J.
Stiglich, J.
Cadish, J.
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Docket No: No. 92118
Decided: May 15, 2026
Court: Supreme Court of Nevada.
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FindLaw’s Learn About the Law features thousands of informational articles to help you understand your options. And if you’re ready to hire an attorney, find one in your area who can help.
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