2020 WI 87

SUPREME COURT OF WISCONSIN

CASE NO.: 2020AP131-D

COMPLETE TITLE: In the Matter of Disciplinary Proceedings 

Against Ann T. Bowe, Attorney at Law:

Office of Lawyer Regulation,

 Complainant,

 v.

Ann T. Bowe,

 Respondent.

DISCIPLINARY PROCEEDINGS AGAINST BOWE

OPINION FILED: November 24, 2020 

SUBMITTED ON BRIEFS: 

ORAL ARGUMENT: 

SOURCE OF APPEAL:

COURT: 

COUNTY: 

JUDGE: 

JUSTICES:

Per Curiam. 

NOT PARTICIPATING:

 

ATTORNEYS:
2020 WI 87

NOTICE

This opinion is subject to further 

editing and modification. The final 

version will appear in the bound 

volume of the official reports. 

No. 2020AP131-D

STATE OF WISCONSIN : IN SUPREME COURT

In the Matter of Disciplinary Proceedings 

Against Ann T. Bowe, Attorney at Law:

Office of Lawyer Regulation,

 Complainant,

 v.

Ann T. Bowe,

 Respondent.

FILED

NOV 24, 2020

Sheila T. Reiff

Clerk of Supreme Court

ATTORNEY disciplinary proceeding. Attorney publicly 

reprimanded.

¶1 PER CURIAM. We review the report of Referee Robert 

E. Kinney which concluded that Attorney Ann T. Bowe's 

professional misconduct warrants a public reprimand. The 

referee further recommends that the full costs of this 

proceeding, which are $6,482.86 as of September 1, 2020, be 

assessed against Attorney Bowe. 

¶2 No appeal has been filed from the referee's report and 

recommendation, so we review the matter pursuant to Supreme 

Court Rule (SCR) 22.17(2). Upon consideration of the referee's 
No. 2020AP131-D 

2

report, the parties' stipulation, and the record in this matter, 

we agree that a public reprimand is an appropriate sanction for 

Attorney Bowe's misconduct. We also require her to pay the full 

costs of this proceeding.

¶3 Attorney Bowe was admitted to practice law in 

Wisconsin in 1980 and practices in Milwaukee. In 1993 she was 

the subject of a consensual private reprimand. The misconduct 

at issue in that case involved neglecting two matters for the 

same client; failing to keep the client reasonably informed; and 

making a misrepresentation to the Board of Attorneys 

Professional Responsibility. Private Reprimand No. 1993-24

(electronic copy available at https://compendium.wicourts.

gov/app/raw/000110.html). In 2011, Attorney Bowe was publicly 

reprimanded for misconduct consisting of failing to act with 

reasonable diligence and promptness; failing to advise the court 

of a jurisdictional defect; filing a certificate of compliance 

with statutory requirements which contained false information; 

having ex parte communications with the court; and making a 

false statement to a tribunal. In re Disciplinary Proceedings 

Against Bowe, 2011 WI 48, 334 Wis. 2d 360, 800 N.W.2d 367.

¶4 On January 22, 2020, the Office of Lawyer Regulation 

(OLR) filed a complaint alleging two counts of misconduct. 

Attorney Bowe filed an answer on February 25, 2020. On July 2, 

2020, the OLR filed an amended complaint which also alleged two 

counts of misconduct. On July 3, 2020, the OLR and Attorney 

Bowe filed a stipulation whereby she agreed that the facts 

alleged in the amended complaint formed a basis for the 
No. 2020AP131-D 

3

imposition of a public reprimand. The following facts are taken 

from the stipulation and the amended complaint.

¶5 On December 6, 2016, L.W., Jr. was charged with hiding 

a corpse in a Dodge County case. The charge arose from the 

death of S.D., L.W.'s girlfriend and his first cousin. S.D.'s 

body was found in L.W.'s vehicle, which was parked in the garage 

of a house owned by L.W. in which M.J., L.W.'s biological 

mother, resided.

¶6 On December 6, 2016, M.J. was charged with harboring 

or aiding a felon which was related to L.W.'s case. 

¶7 On December 8, 2016, the circuit court in L.W.'s 

criminal case ordered conditions of his bond that included him 

having no direct contact with M.J. or the immediate family of 

the victim. In addition, L.W. was to have no third-party 

contact with those persons except through an attorney or 

investigator.

¶8 On December 14, 2016, S.J., S.D.'s biological father, 

filed a wrongful death action against L.W. S.J. and M.J. are 

biological siblings.

¶9 At the preliminary hearing in L.W.'s criminal case, 

held on December 22, 2016, the court found probable cause and 

bound L.W. over for trial. An arraignment was scheduled for 

February 15, 2017.

¶10 On January 20, 2017, the Dodge County District 

Attorney filed an Information in the L.W. case charging firstdegree intentional homicide-domestic abuse modifier; hiding a 
No. 2020AP131-D 

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corpse; incest; and two counts of possession of a firearm by a 

felon. 

¶11 On February 14, 2017, Attorney Jason Richard on behalf 

of S.J. and the estate of S.D., filed a motion for a temporary 

restraining order in the wrongful death action restraining L.W. 

and/or his agents from transferring or dissipating any of L.W.'s 

assets, real or personal.

¶12 The arraignment in L.W.'s criminal case was 

rescheduled several times and ultimately was set for June 8, 

2017. 

¶13 On February 17, 2017, in the wrongful death action, 

the circuit court granted the temporary injunction restraining 

L.W. and/or his agents from transferring or dissipating assets 

for 90 days, with the exception of allowing the expenditure of 

up to $150,000 for legal fees. The circuit court issued its 

findings of fact and conclusions of law on February 24, 2017. 

That meant the temporary injunction would expire on or about May 

25, 2017. Attorney Richard did not request a hearing to renew 

the temporary restraining order when it expired.

¶14 On May 26, 2017, Attorney Bowe met with L.W. at the 

Dodge County jail, at which time L.W. and Attorney Bowe signed a 

representation agreement. Attorneys Donna Kuchler and Aaron 

Nelson had been representing L.W. in his criminal case up to 

that point.

¶15 On May 29, 2017, L.W. sent a letter to Attorney Bowe 

in which he stated that the statements by witnesses with respect 

to the gun possession charges were "highly inconsistent" and 
No. 2020AP131-D 

5

that DNA evidence on the guns was "inconclusive." L.W. said the 

charge of hiding a corpse was vague and there was "no prelim or 

showing proof of any probably cause to restrain his liberty." 

L.W. also wrote there was "no standing for a tenant or guest to 

override sole owner's consent or challenge of a search" which 

referred to M.J. and M.V., who were living at the house owned by 

L.W., where M.J. resided and where the corpse was found. L.W. 

concluded the letter by saying that "A good position we are in 

Ann is I am a Pre-trial detainee held in violation of U.S. 

Constitution. Pre-arraigned at that!"

¶16 On May 31, 2017, Attorney Bowe deposited $149,397.81 

into her trust account. These were funds belonging to L.W., 

which were obtained from Attorney Kuchler. 

¶17 On June 2, 2017, Attorney Bowe met with L.W. at the 

Dodge County jail. During that meeting L.W. signed a motion for 

substitution of counsel, which substituted Attorney Bowe and 

Attorney Michael Steinle for Attorneys Kuchler and Nelson. 

¶18 On June 3, 2017, at L.W.'s request, Attorney Bowe 

wrote the following trust account checks from L.W.'s funds:

M.J. (L.W.'s mother) $ 3,000.00

M.J. (L.W.'s grandmother) $ 1,000.00

D.M. (L.W.'s cousin) $ 1,197.81

D.P. (D.M.'s daughter) $ 200.00

S.J. (S.D.'s father) $10,000.00

T.J. (S.D.'s mother) $ 7,500.00

G.C. (L.W.'s friend) $ 2,500.00

¶19 At the time Attorney Bowe wrote the checks, she knew 

that S.J. and T.J. were S.D.'s parents. S.J. and T.J. were 

potential State witnesses. Attorney Bowe also knew that M.J. 
No. 2020AP131-D 

6

was a co-defendant in a criminal case and was a potential 

witness against L.W. in his criminal case.

¶20 On June 3, 2017, L.W. telephoned D.M. to ask him to 

pick up checks from Attorney Bowe's law office. D.M. was out of 

state at the time and instructed his daughter, D.P., to go to 

Attorney Bowe's law office to retrieve the checks. D.P. went to 

Attorney Bowe's law office that day and Attorney Bowe gave her 

checks made out to D.P., D.M., S.J., and T.J. D.P. left the 

check for T.J. at D.M.'s house and he subsequently gave that 

check to T.J.

¶21 On June 3, 2017, L.W. also telephoned G.C. to ask her 

to pick up checks from Attorney Bowe's law office. G.C. went to 

Attorney Bowe's law office that day and Attorney Bowe gave her 

checks made out to G.C., M.J., and M.J. (L.W.'s grandmother).

¶22 On June 8, 2017, a motion hearing was held in L.W.'s 

criminal case, at which time the circuit court dismissed 

Attorneys Kuchler and Nelson and allowed Attorneys Bowe and 

Steinle to serve as L.W.'s co-counsel. The arraignment was 

rescheduled for July 20, 2017.

¶23 On June 8, 2017, L.W. signed Attorneys Bowe's and 

Steinle's fee agreement. L.W. agreed to pay a flat fee of 

$100,000 for representation in the criminal case. Attorney Bowe 

wrote a trust account check in the amount of $50,000, dated 

June 2, 2017, payable to Attorney Steinle for his half of the 

flat fee.

¶24 On or about June 13, 2017, T.J. notified the Dodge 

County District Attorney's Office that she had received a check 
No. 2020AP131-D 

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for $7,500 from Attorney Bowe's law office and that S.J. had 

received a similar check for $10,000.

¶25 On June 27, 2017, Attorneys Bowe and Steinle met with 

L.W. at the Dodge County jail.

¶26 On July 10, 2017, Attorney Steinle filed a motion to 

withdraw from representing L.W., citing a breakdown in 

communication.

¶27 On July 14, 2017, the district attorney filed an 

"other acts" motion and a motion to disqualify Attorney Bowe in 

L.W.'s criminal case based on a conflict of interest likely to 

result in ineffective assistance of counsel. The "other acts" 

motion identified S.J., T.J., and M.J. as State witnesses. In 

the motion, the district attorney argued:

The transfer of large amounts of money to State 

witnesses is designed to influence their testimony and 

their cooperation with the State in its prosecution. 

It is most telling that the mother and father of the 

victim are in receipt of the largest sums of money. 

The next largest documented amount is to his mother 

who is a witness to the events surrounding the 

homicide. All three are witnesses against him.

¶28 On July 17, 2017, Attorney Steinle was allowed to 

withdraw from representing L.W.

¶29 On July 13, 2017, Attorney Bowe wrote a trust account 

check payable to cash for $250. L.W. had instructed Attorney 

Bowe to deposit this amount into the account of an incarcerated 

female friend. On July 17, 2017, Attorney Bowe wrote a trust 

account check payable to cash for $5,000. On August 4, 2017, 

she wrote a trust account check payable to cash for $2,500. The 
No. 2020AP131-D 

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checks totaled $7,500, which is the fee amount L.W. and Attorney 

Bowe agreed that Attorney Bowe had earned out of the $50,000 

flat fee.

¶30 On July 20, 2017, a motion hearing in L.W.'s criminal 

case was held, at which time Attorney Bowe was provided copies 

of the "other acts" motion and motion to disqualify her. 

Attorney Bowe agreed to withdraw from L.W.'s case, and the 

circuit court allowed her to do.

¶31 In the stipulation, Attorney Bowe agreed that her 

conduct in writing checks on behalf of L.W. to potential state 

witnesses carried a significant risk that her representation of 

L.W. would be materially limited by her personal interests.

¶32 By entering into the stipulation, Attorney Bowe 

admitted the following counts of misconduct alleged in the OLR's 

amended complaint:

Count 1: By issuing checks from her trust account to 

potential State witnesses against her client, Attorney 

Bowe violated SCR 20:1.7(a)(2).1

Count 2: By making three trust account checks payable 

to cash, Attorney Bowe violated SCR 20:1.15(f)(2)a.2

 

1 SCR 20:1.7(a)(2) provides: 

(a) Except as provided in par. (b), a lawyer 

shall not represent a client if the representation 

involves a concurrent conflict of interest. A 

concurrent conflict of interest exists if:

(2) there is a significant risk that the 

representation of one or more clients will be 

materially limited by the lawyer's responsibilities to 

another client, a former client or a third person or 

by a personal interest of the lawyer.
No. 2020AP131-D 

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¶33 The parties state that the stipulation did not result 

from plea bargaining. Attorney Bowe represents that she fully 

understands the allegations; that she fully understands the 

ramifications should this court impose the stipulated level of 

discipline; that she fully understands her right to contest the 

matter; that that she fully understands her right to consult 

with counsel and that she has consulted with counsel; that her 

entry into the stipulation is made knowingly and voluntarily; 

that she has read the amended complaint and the stipulation and 

her entry into the stipulation represents her decision not to 

contest the allegations in the amended complaint or the level 

and type of discipline sought by the OLR's director.

¶34 The referee agreed that by issuing checks from her 

trust account to potential State witnesses in L.W.'s criminal 

case, Attorney Bowe engaged in conduct that created a 

significant risk that her representation of L.W. would be 

materially limited by her personal interest. The referee 

commented that at a July 14, 2020 hearing, Attorney Bowe 

explained the reason for writing the checks. Attorney Bowe said 

L.W. had settled a large personal injury case and had a large 

amount of money at his disposal. She said at the time the 

criminal charges were filed, there were various actions seeking 

to freeze or seize those funds. She said at the time L.W. 

 

2 SCR 20:1.15(f)(2)a. provides: "No withdrawal of cash 

shall me made from a trust account or from a deposit to a trust 

account. No check shall be made payable to "Cash." No 

withdrawal shall be made from a trust account by automated 

teller or cash dispensing machine."
No. 2020AP131-D 

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retained her in the criminal case none of those actions had been

successful, but L.W. feared that he would soon not have access 

to that money and while he still had it he wanted to make gifts 

to a number of people, using her to disburse the funds. The 

referee commented, "one need not dwell on the possible 

hypothetical problems that this could have created; the details 

of this case are living proof that this was a bad idea." The 

referee said to Attorney Bowe's credit, she realized she could 

not defend against the district attorney's motion to remove her 

from the case and she immediately stepped aside. The referee 

noted that Attorney Bowe's counsel commented that Attorney Bowe, 

"perceived as a necessity the appeasing of a difficult client, 

as [L.W.] most certainly was."

¶35 The referee concluded that a public reprimand was an 

appropriate sanction for Attorney Bowe's misconduct. 

¶36 This court will affirm a referee's findings of fact 

unless they are found to be clearly erroneous, but we review the 

referee's conclusions of law de novo. In re Disciplinary 

Proceedings Against Inglimo, 2007 WI 126, ¶5, 305 Wis. 2d 71, 

740 N.W.2d 125. We determine the appropriate level of 

discipline independent of the referee's recommendation, but 

benefitting from it. In re Disciplinary Proceedings Against 

Widule, 2003 WI 34, ¶44, 261 Wis. 2d 45, 660 N.W.2d 686.

¶37 There is no showing that any of the referee's findings 

of fact, which are largely derived from the parties' 

stipulation, are clearly erroneous, so we adopt them. We also 
No. 2020AP131-D 

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adopt the referee's conclusions of law with respect to the 

alleged misconduct. 

¶38 With respect to the sanction, we agree that a public 

reprimand is an appropriate sanction. While no two cases are 

preciously identical, we find that Public Reprimand of Kristin 

Schrank, No. 2018-08 (electronic copy available at 

https://compendium.wicourts.gov/app/raw/003045.html) is somewhat 

analogous. Attorney Schrank was an assistant district attorney. 

Her responsibilities included answering questions and assisting 

law enforcement during non-business hours. While working at a 

different part-time job, Attorney Schrank asked a friend, who 

was a former assistant district attorney but who was not 

authorized to answer the duty district attorney phone at that 

time, to respond to any calls from law enforcement. 

¶39 During that time, officers from a police department 

attempted to contact Attorney Schrank about an arrestee's 

refusal to consent to a blood draw following an operating while 

intoxicated arrest with injuries. Attorney Schrank's friend 

answered the call and advised the officer to obtain a search 

warrant. The friend represented himself as an intern at the 

district attorney's office and gave the name of an intern. 

Attorney Schrank subsequently appeared in court on the matter 

and dismissed the case without providing any reason. Following 

an investigation into her conduct, Attorney Schrank was 

convicted of misdemeanor attempted misconduct in public office. 

Her personal interest presented a conflict of interest. Like 

Attorney Schrank, Attorney Bowe made poor decisions in writing 
No. 2020AP131-D 

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checks to potential witnesses in L.W.'s case, which ultimately 

created a conflict of interest that impacted the administration 

of justice. A public reprimand is warranted.

¶40 IT IS ORDERED that Ann T. Bowe is publicly reprimanded 

for her professional misconduct.

¶41 IT IS FURTHER ORDERED that within 60 days of the date 

of this order, Ann T. Bowe shall pay to the Office of Lawyer 

Regulation the costs of this proceeding, which total $6,482.86 

as of September 1, 2020.
No. 2020AP131-D 

1