2024 WI 7

SUPREME COURT OF WISCONSIN

CASE NO.: 2022AP41-D

COMPLETE TITLE: In the Matter of Disciplinary Proceedings 

Against John O. Ifediora, Attorney at Law:

Office of Lawyer Regulation,

 Complainant,

 v.

John O. Ifediora,

 Respondent.

DISCIPLINARY PROCEEDINGS AGAINST IFEDIORA

OPINION FILED: January 26, 2024 

SUBMITTED ON BRIEFS: 

ORAL ARGUMENT: 

SOURCE OF APPEAL:

COURT: 

COUNTY: 

JUDGE: 

JUSTICES:

Per curiam. 

ATTORNEYS:
2024 WI 7

NOTICE

This opinion is subject to further 

editing and modification. The final 

version will appear in the bound 

volume of the official reports. 

No. 2022AP41-D

STATE OF WISCONSIN : IN SUPREME COURT

In the Matter of Disciplinary Proceedings 

Against John O. Ifediora, Attorney at Law:

Office of Lawyer Regulation,

 Complainant,

 v.

John O. Ifediora,

 Respondent.

FILED

JAN 26, 2024

Samuel A. Christensen

Clerk of Supreme Court

ATTORNEY disciplinary proceeding. Attorney's license 

revoked. 

¶1 PER CURIAM. We review the recommendation of Referee 

James D. Friedman that the license of Attorney John O. Ifediora 

to practice law in Wisconsin be revoked due to professional 

misconduct. The referee also recommends that Attorney Ifediora 

pay the full costs of this proceeding, which are $12,305.23 as 

of July 12, 2023. Although Attorney Ifediora initially filed a 

notice of appeal of the referee's decision, he voluntarily 

dismissed the appeal before any briefs were filed. Therefore, 
No. 2022AP41-D 

2

our review of the referee's recommendation proceeds pursuant to 

Supreme Court Rule (SCR) 22.17(2).1

¶2 Upon careful review of the matter, we adopt the 

referee's findings of fact and conclusions of law and agree that 

the seriousness of Attorney Ifediora's professional misconduct 

warrants the revocation of his license to practice law. We 

further agree that he should pay the full costs of this 

proceeding.

¶3 Attorney Ifediora is a naturalized American citizen 

who was born in Nigeria. He was admitted to practice law in 

Wisconsin in 2003. He is a retired professor of economics at 

the University of Wisconsin-Platteville. For some years, 

Attorney Ifediora maintained a law office in Madison. His 

license to practice law has been suspended since 2016 for 

failure to comply with continuing legal education requirements, 

failure to pay State Bar dues, and non-compliance with trust 

account certification requirements. Attorney Ifediora currently 

resides in Virginia. He has no previous disciplinary record.

¶4 On January 10, 2022, the Office of Lawyer Regulation 

(OLR) filed a complaint against Attorney Ifediora alleging 

twelve counts of misconduct. All counts arose out of Attorney 

Ifediora's representation of his first cousin, O.A., a Nigerian 

 

1 SCR 22.17(2) provides: "If no appeal is filed timely, the 

supreme court shall review the referee's report; adopt, reject 

or modify the referee's findings and conclusions or remand the 

matter to the referee for additional findings; and determine and 

impose appropriate discipline. The court, on its own motion, 

may order the parties to file briefs in the matter."
No. 2022AP41-D 

3

citizen, who sought Attorney Ifediora's assistance in becoming a 

permanent resident in the United States. At that time, Attorney 

Ifediora was employed as an economics professor at UWPlatteville. Attorney Ifediora told OLR that he had retired 

from the practice of law but wanted to assist O.A. in becoming a 

permanent U.S. resident merely on a "familial basis."

¶5 In pursuit of accomplishing O.A.'s goal of becoming a 

permanent U.S. resident, Attorney Ifediora referred O.A. to the 

Immigrant Investor Program, which is also known as the "EB-5" 

Program, administered by the U.S. Citizenship and Immigration 

Services (USCIS). Under this program, a person who invests 

$500,000 in a new commercial enterprise that creates ten or more 

permanent full-time jobs will have a path to permanent residency 

in the United States. The investment may be either a direct 

investment in a business or an indirect investment in a USCISdesignated "EB-5 regional center."

¶6 Attorney Ifediora became aware of a startup 

pharmaceutical manufacturer in Madison, Wisconsin called U.S. 

Foods and Pharmaceuticals (USFP). USFP had been working with a 

USCIS-approved EB-5 regional center in Detroit, Michigan called 

the Detroit Immigrant Investor Regional Center (DIIRC). 

Attorney Ifediora contacted representatives of both USFP and 

DIIRC and told them that he had a potential investor. In 

addition, Attorney Ifediora contacted an immigration lawyer, 

Attorney Ebere Ekechukwu, to facilitate the filing of the 

associated I-526 Petition necessary to establish eligibility for 

the EB-5 program.
No. 2022AP41-D 

4

¶7 In October 2014 Attorney Ifediora advised O.A. to 

invest $500,000 with USFP, working in conjunction with DIIRC, as 

part of an EB-5 petition. Attorney Ifediora also advised O.A. 

that in addition to the $500,000 investment, the DIIRC charged a 

nonrefundable $57,000 processing fee. Attorney Ifediora 

coordinated with representatives of USFP and DIIRC, as well as 

Attorney Ekechukwu, to obtain all necessary documents to start 

the EB-5 petition process.

¶8 In an August 22, 2014 email to O.A., Attorney Ifediora 

said, "As your attorney in your pending transactions, I would 

advise that funds for the purchase of property be sent to my law 

office Trust Account from where the funds would be used for your 

intended investment."

¶9 In a September 29, 2014 letter to Attorney Ekechukwu, 

written on his Madison office letterhead, Attorney Ifediora 

said, "I am enclosing in this letter a retainer and part of the 

agreed upon fee for your legal service. The rest shall be 

remitted with the filing fee as the process moves along. I will 

facilitate things from my end, and shall keep you updated."

¶10 Attorney Ifediora obtained O.A.'s signature on a 

Subscription Agreement and Power of Attorney authorizing the 

investment in USFP. Pursuant to the Subscription Agreement, 

O.A. agreed to pay "$500,000 plus a processing fee of $57,000, 

which shall be payable as follows: (i) $557,000 shall be 

payable in cash/check or wire concurrently with delivery of this 

Agreement."
No. 2022AP41-D 

5

¶11 Following Attorney Ifediora's advice, O.A. sent 

Attorney Ifediora two checks, one in the amount of $50,000 

payable to "Ifediora Law Office" to cover the processing fee for 

DIIRC, and one in the amount of $500,000 made payable to "US 

Foods and Pharmaceuticals."

¶12 Attorney Ifediora also held himself out as O.A.'s 

legal representative to R.V., the managing member of USFP. R.V. 

testified in subsequent federal litigation over the failed EB-5 

petition that Attorney Ifediora was "the agent of [O.A.]" and 

that "we trusted [Attorney Ifediora] to represent not only 

[O.A.] but also USFP in the cause of getting this petition 

approved and bringing in additional investment into the 

company."

¶13 Attorney Ifediora's actions on behalf of O.A. during 

the EB-5 petition process demonstrated that Attorney Ifediora 

was acting as O.A.'s attorney. Attorney Ifediora expressly said 

he was O.A.'s attorney. Attorney Ifediora gave specific legal 

advice to O.A. and represented to third parties that he was 

O.A.'s agent or representative. Attorney Ifediora handled 

significant client funds in connection with the representation. 

On October 20, 2014, Attorney Ifediora deposited the funds he 

received from O.A. into his law firm's operating account, rather 

than into a trust account. Attorney Ifediora communicated with 

multiple individuals on behalf of O.A. using email and office 

letterhead containing his law office address and website.

¶14 Attorney Ifediora did not notify DIIRC, the intended 

beneficiary of the funds, in writing that he had received 
No. 2022AP41-D 

6

$50,000 in client funds associated with DIIRC's processing fee, 

nor did he promptly deliver to DIIRC the processing fee agreed 

to in the Subscription Agreement.

¶15 After depositing the $50,000 in processing fees into 

his law firm operating account, Attorney Ifediora transferred 

those proceeds into other bank accounts he owned. He 

subsequently converted the entire $50,000 for his personal use, 

leaving his law firm operating account with a balance under 

$200.

¶16 Attorney Ifediora failed to provide O.A. and DIIRC an 

accounting of the final distribution of the $50,000. Those 

funds should have been held in trust for O.A. and DIIRC.

¶17 In November 2014 O.A.'s $500,000 payment was deposited 

in a USFP checking account at Wells Fargo Business Bank in 

Madison, Wisconsin. Wells Fargo sent USFP written confirmation 

of the deposit.

¶18 On November 10, 2014, R.V. wrote a check in the amount 

of $200,000 from the Wells Fargo account to "John Ifediora Law 

Firm." R.V. said the purpose of the check was to repay a loan 

Attorney Ifediora purportedly made to O.A. in the amount of 

$200,000 as part of the initial $500,000 EB-5 petition. R.V. 

testified in the subsequent federal litigation that Attorney 

Ifediora promised the $200,000 payment would be placed in an 

escrow account.

¶19 Attorney Ifediora deposited the $200,000 into his 

business account, rather than in an escrow account as he had 
No. 2022AP41-D 

7

promised. He did not notify O.A. that he had received the 

$200,000 associated with the EB-5 petition from USFP.

¶20 Attorney Ifediora transferred the funds into bank 

accounts he owned. He made two payments totaling $10,600 to 

Attorney Ekechukwu toward her legal fees related to the EB-5 

petition. Attorney Ifediora subsequently converted nearly 

$190,000 for his own personal purposes, including paying himself 

more than $121,000 over a three-year period. He failed to 

provide an accounting to O.A. of the $200,000 after distributing 

the funds. 

¶21 In November 2017 USCIS informed Attorney Ifediora and 

USFP that it intended to deny the Form I-526 that had been filed 

on behalf of O.A.

¶22 Attorney Ifediora continued to represent O.A. by 

coordinating with R.V. and Attorney Ekechukwu on how to respond 

to the USCIS Notice of Intent to Deny, despite the fact that his 

Wisconsin law license had been administratively suspended in 

2016.

¶23 In January 2018 USCIS denied O.A.'s I-526 petition. 

O.A. informed Attorney Ifediora that he wanted to discontinue 

all further efforts on the EB-5 petition, and he asked Attorney 

Ifediora to refund the funds he had set aside for the 

investment. Attorney Ifediora failed to respond to O.A.'s 

request and failed to surrender any property belonging to O.A.

¶24 In May 2018 Attorney Ifediora received a $6,000 

interest payment from USFP for the money O.A. had invested with 
No. 2022AP41-D 

8

them. Attorney Ifediora failed to notify O.A. of his receipt of 

the funds and subsequently converted them for his personal use.

¶25 O.A. initiated a federal civil lawsuit in United 

States District Court for the Western District of Wisconsin 

against Attorney Ifediora, USFP, and others, seeking the refund 

of all of his investment money. Attorney Ifediora subsequently 

reached a settlement with all parties. The terms of the 

settlement are confidential, but OLR states that it believes 

that all funds, including the $50,000 processing fee, the 

$200,000 in funds received from USFP, and the $6,000 interest 

payment, have been repaid pursuant to the settlement. As a 

result, OLR is not seeking restitution. 

¶26 In January 2020 O.A. filed a grievance against 

Attorney Ifediora with OLR. In response, Attorney Ifediora 

claimed he did not act as O.A.'s attorney, stating, "I never 

provided any legal services to [O.A.]"

¶27 OLR's complaint alleged the following counts of 

misconduct with respect to Attorney Ifediora's representation of 

O.A.:

Count one: By failing to place in trust the $50,000 

associated with the DIIRC processing fee, [Attorney] 

Ifediora violated former SCR 20:1.15(b)(4).2

 

2 Effective July 1, 2016, substantial changes were made to 

Supreme Court Rule 20:1.15, the "trust account rule." See S. Ct. 

Order 14-07, (issued Apr. 4, 2016, eff. July 1, 2016). Because 

the conduct that involved Attorney Ifediora's handling of client 

funds arose prior to July 1, 2016, unless otherwise indicated, 

all references to the supreme court trust account rules will be 

those in effect prior to July 1, 2016.
No. 2022AP41-D 

9

Count two: By failing to provide notice to DIIRC of 

his receipt of $50,000 associated with the DIIRC 

processing fee, [Attorney] Ifediora violated former 

SCR 20:1.15(d)(1).3

Count three: By failing to provide an accounting of 

the $50,000 associated with the DIIRC processing fee 

after distributing the funds, [Attorney] Ifediora 

violated former SCR 20:1.15(d)(2).4

Count four: By converting the $50,000 associated with 

the DIIRC processing fee, [Attorney] Ifediora violated 

SCR 20:8.4(c).5

Count five: By failing to place in trust $200,000 in 

client funds associated with [O.A.'s] EB-5 petition, 

[Attorney] Ifediora violated former SCR 20:1.15(b)(4).

 

Former SCR 20:1.15(b)(4) provided: "Except as 

provided in par. (4m), unearned fees and advanced 

payments of fees shall be held in trust until earned 

by the lawyer, and withdrawn pursuant to sub. (g). 

Funds advanced by a client or 3rd party for payment of 

costs shall be held in trust until the costs are 

incurred."

3 Former SCR 20:1.15(d)(1) provided: "Upon receiving funds 

or other property in which a client has an interest, or in which 

the lawyer has received notice that a 3rd party has an interest 

identified by a lien, court order, judgment, or contract, the 

lawyer shall promptly notify the client or 3rd party in writing. 

Except as stated in this rule or otherwise permitted by law or 

by agreement with the client, the lawyer shall promptly deliver 

to the client or 3rd party any funds or other property that the 

client or 3rd party is entitled to receive.

4 Former SCR 20:1.15(d)(2) provided: "Upon final 

distribution of any trust property or upon request by the client 

or a 3rd party having an ownership interest in the property, the 

lawyer shall promptly render a full written accounting regarding 

the property."

5 SCR 20:8.4(c) provides: "It is professional misconduct 

for a lawyer to engage in conduct involving dishonesty, fraud, 

deceit or misrepresentation."
No. 2022AP41-D 

10

Count six: By failing to provide an accounting of the 

$200,000 in funds associated with [O.A.'s] EB-5 

petition after distributing those funds, [Attorney] 

Ifediora violated former SCR 20:1.15(d)(2).

Count seven: By converting $200,000 in funds 

associated with [O.A.'s] EB-5 petition, [Attorney] 

Ifediora violated SCR 20:8.4(c).

Count eight: By failing to place in trust $6,000 in 

interest received in connection with [O.A.'s] EB-5 

petition, [Attorney] Ifediora violated former SCR 

20:1.15(b)(4).

Count nine: By failing to provide notice to [O.A.] of 

the receipt of $6,000 in interest received in 

connection with O.A.'s EB-5 petition, [Attorney] 

Ifediora violated former SCR 20:1.15(d)(1).

Count ten: By failing to provide an accounting of the 

$6,000 in interest he received in connection with 

[O.A.]'s EB-5 petition after distributing the funds, 

[Attorney] Ifediora violated former SCR 20:1.15(d)(2).

Count eleven: By converting the $6,000 in funds in 

interest he received in connection with [O.A.'s] EB-5 

petition, [Attorney] Ifediora violated SCR 20:8.4(c).

Count twelve: By engaging in the practice of law or 

otherwise acting in a manner purporting to be 

authorized or qualified to practice law while his law 

license was suspended, [Attorney] Ifediora violated 
No. 2022AP41-D 

11

SCR 10.03(4)(a),6 as enforced via SCR 20:8.4(f)7 and 

SCR 23.02(1).8

¶28 The referee was appointed on February 17, 2022. An 

evidentiary hearing was held before the referee in March 2023. 

The referee issued his report and recommendation on June 22, 

2023. The referee found that OLR had met its burden of proof as 

to all of the counts of misconduct alleged in the complaint. 

The referee agreed with OLR that revocation of Attorney 

Ifediora's license to practice law would be an appropriate 

sanction for his misconduct. The referee also agreed that 

Attorney Ifediora should bear the full costs of this proceeding.

¶29 The referee found numerous aspects of Attorney 

Ifediora's testimony at the evidentiary hearing to be 

incredible. For example, while Attorney Ifediora claimed that 

he was merely acting as O.A.'s agent and not as his attorney, 

 

6 SCR 10.03(4)(a) provides: "No individual other than an 

enrolled active member of the state bar may practice law in this 

state or in any manner purported to be authorized or qualified 

to practice law provided however, that an inactive or emeritus 

member may provide pro bono legal services consistent with SCR 

10.03(3)(am)."

7 SCR 20:8.4(f) provides: "It is professional misconduct 

for a lawyer to violate a statute, supreme court rule, supreme 

court order or supreme court decision regulating the conduct of 

lawyers."

8 SCR 23.02(1) provides: "A person who is duly licensed to 

practice law in this state by the Wisconsin Supreme Court and 

who is an active member of the State Bar of Wisconsin may 

practice law in Wisconsin. No person may engage in the practice 

of law in Wisconsin, or attempt to do so, or make a 

representation that he or she is authorized to do so, unless the 

person is currently licensed to practice law in Wisconsin by the 

Wisconsin Supreme Court and is an active member of the State Bar 

of Wisconsin."
No. 2022AP41-D 

12

the referee noted that in emails that Attorney Ifediora sent to 

O.A., he expressly said he was acting as O.A.'s lawyer. The 

referee also found that Attorney Ifediora represented to third 

parties that he was O.A.'s attorney. 

¶30 In addition, the referee said that Attorney Ifediora's 

actions clearly indicated he was acting on behalf of O.A. as his 

lawyer. The referee said, "The EB-5 program is not for the 

faint of heart. It is extremely complicated and difficult. 

[Attorney] Ifediora had no immigration law experience and no 

familiarity with this program and yet he tried to lead someone 

through it——that is primarily what caused [O.A.'s] losses here." 

The referee also said:

In addition to representing [O.A.] in a complicated 

immigration process in which he had no experience, his 

response to a question of why he maintained a law 

office is equally troubling:

"Well, you know, it's--it's the exuberance and the 

idea to have a law degree and I don't know. It was --

it was a very exciting prospect. And of course, at 

the point in time, I also wanted to provide services 

to Wisconsin inmates and so the idea of having -- of 

having a law -- a law practice was appealing, even 

though I knew deep down I wouldn't have the time to do 

that.["] Clearly, he liked to show the badge of being

a lawyer.

¶31 The referee had no difficulty concluding that Attorney 

Ifediora mishandled and converted over $250,000 of O.A.'s funds. 

The referee noted that client money that was intended to be paid 

to a third party was required to be placed into a trust account, 

but Attorney Ifediora did not have a trust account. The referee 

commented on "the ease with which [Attorney] Ifediora lied to 
No. 2022AP41-D 

13

this Referee about not paying himself out of [O.A.'s] $50,000 

for his services." The referee found that Attorney Ifediora 

failed to notify O.A. that he had received $200,000 of O.A.'s 

money from USFP, and he failed to provide O.A. with an 

accounting of the $200,000 after he had distributed those funds. 

The referee found that Attorney Ifediora converted the $200,000 

when he spent it on a conference he put on in Africa. 

Similarly, the referee found that Attorney Ifediora converted 

the $6,000 interest payment to his personal use and never 

provided O.A. with an accounting.

¶32 The referee also found that Attorney Ifediora 

practiced law after his license had been administratively 

suspended. The referee noted that throughout 2017 and into 

2018, Attorney Ifediora was still using his law office 

letterhead in communications with O.A. 

¶33 The referee found that O.A. "relied on [Attorney] 

Ifediora's advice and entrusted him to hold and allocate 

substantial funds according to that required by the Subscription 

Agreement with USFP. Instead, [Attorney] Ifediora proceeded to 

convert [O.A.'s] funds, which ultimately resulted in [O.A.] 

suing [Attorney] Ifediora [and others] in federal court, 

resulting in a confidential settlement." Based on these 

findings, the referee recommended that Attorney Ifediora's 

license to practice law in Wisconsin be revoked and that he be 

assessed the full costs of this proceeding.

¶34 We will affirm a referee's findings of fact unless 

they are found to be clearly erroneous. We review a referee's 
No. 2022AP41-D 

14

conclusions of law de novo. See In re Disciplinary Proceedings 

Against Inglimo, 2007 WI 126, ¶5, 305 Wis. 2d 71, 740 N.W.2d 

125. The court may impose whatever sanction it sees fit 

regardless of the referee's recommendation. See In re 

Disciplinary Proceedings Against Widule, 2003 WI 34, ¶44, 261 

Wis. 2d 45, 660 N.W.2d 686.

¶35 Based upon our review of the record, we accept the 

referee's findings of fact and conclusions of law. We agree 

that the seriousness of Attorney Ifediora's misconduct warrants 

the revocation of his license to practice law. Conversion of 

client funds is a very serious offense, and we have frequently 

revoked attorneys' licenses in similar cases. For example, in 

In re Disciplinary Proceedings Against Runyon, 2020 WI 74, 393 

Wis. 2d 612, 948 N.W.2d 62, we revoked the license of an 

attorney who converted over $135,000. In In re Disciplinary 

Proceedings Against Sweeney, 2019 WI 13, 385 Wis. 2d 407, 922 

N.W.2d 850, we found it appropriate to revoke the license of an 

attorney who converted more than $420,000. Attorney Ifediora's 

misconduct is readily comparable to that of Runyon and Sweeney. 

The seriousness of that misconduct demonstrates that his license 

to practice law must be revoked to protect the public, courts, 

and the legal system from the repetition of the misconduct; to 

impress upon Attorney Ifediora the seriousness of his 

misconduct; and to deter other attorneys from engaging in 

similar misconduct. As is our usual custom, we further agree 

with the referee's recommendation that Attorney Ifediora pay the 

full costs of this proceeding.
No. 2022AP41-D 

15

¶36 IT IS ORDERED that the license of John O. Ifediora to 

practice law in Wisconsin is revoked, effective the date of this 

order.

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

of this order John O. Ifediora pay to the Office of Lawyer 

Regulation the costs of this disciplinary proceeding, which are 

$12,305.23 as of July 12, 2023.

¶38 IT IS FURTHER ORDERED that, to the extent he has not 

already done so, John O. Ifediora comply with the provisions of 

SCR 22.26 concerning the duties of a person whose license to 

practice law has been revoked. 

¶39 IT IS FURTHER ORDERED that the administrative 

suspensions of John O. Ifediora to practice law in Wisconsin, 

due to non-compliance with continuing legal education 

requirements, failure to pay bar dues, and non-compliance with 

trust certification requirements, will remain in effect until 

each reason for the administrative suspension has been 

rectified, pursuant to SCR 22.28(1).
No. 2022AP41-D.akz

1

¶40 ANNETTE KINGSLAND ZIEGLER, C.J. (concurring). I 

concur in the court's order revoking Attorney Ifediora's license 

to practice law in Wisconsin. I write separately to point out 

that in Wisconsin the "revocation" of an attorney's law license 

is not truly revocation because the attorney may petition for 

readmittance after a period of five years. See SCR 22.29(2). I 

believe that when it comes to lawyer discipline, courts should 

say what they mean and mean what they say. We should not be 

creating false perceptions to both the public and to the lawyer 

seeking to practice law again. See In re Disciplinary 

Proceedings Against Moodie, 2020 WI 39, 391 Wis. 2d 196, 942 

N.W.2d 302 (Ziegler, J., dissenting). And, as I stated in my 

dissent to this court's order denying Rule Petition 19-10, In 

the Matter of Amending Supreme Court Rules Pertaining to 

Permanent Revocation of a License to Practice Law in Attorney 

Disciplinary Proceedings, I believe there may be rare and 

unusual cases that would warrant the permanent revocation of an 

attorney's license to practice law. See S. Ct. Order 19-10 

(issued Dec. 18, 2019) (Ziegler, J., dissenting).

¶41 I am authorized to state that Justices REBECCA GRASSL 

BRADLEY, BRIAN HAGEDORN, and JILL J. KAROFSKY join this 

concurrence.
No. 2022AP41-D.akz

1