New York Appellate Division Disbars Attorney for Converting $184,600 in IOLA Client Funds

Published Nov. 6, 2026. Case status is current as of that date.

An IOLA attorney trust account exists to hold client money, not to float the lawyer’s cash needs. On March 19, 2024, the Appellate Division, First Department accepted the resignation of Bryan A. McKenna (admitted as Bryan Aaron McKenna; OCA Reg. No. 2590974) and disbarred him, effective nunc pro tunc to Nov. 20, 2023, after he acknowledged converting and misappropriating $184,600 in client funds from his IOLA account in a real-estate matter [1].

Status: Matter of McKenna, 2024 NY Slip Op 01514 (1st Dept). The court directed restitution of $188,100 ($184,600 converted/misappropriated funds plus $3,500 in legal fees) under Judiciary Law § 90(6-a). McKenna attested he could not successfully defend the Attorney Grievance Committee’s allegations [1].

What the disciplinary order says

According to the First Department’s per curiam opinion [1]:

1. McKenna was admitted March 23, 1994, and maintained a First Department registered address.
2. In a Nov. 20, 2023 resignation affidavit under 22 NYCRR § 1240.10, he acknowledged AGC allegations that he converted $184,600 from his IOLA in a real-estate client matter and consented to $188,100 restitution.
3. The court granted the resignation, struck his name from the roll, and ordered the restitution.

The person disbarred

Bryan A. McKenna (Bryan Aaron McKenna), New York. OCA Reg. No. 2590974. Disbarred effective Nov. 20, 2023 (Matter of McKenna, 2024 NY Slip Op 01514) [1].

Case status (as of Nov. 6, 2026)

Respondent	Court	Status	Source
Bryan A. McKenna (OCA 2590974)	N.Y. App. Div., 1st Dept., Case No. 2023-06260 / Motion No. 2023-05409	Disbarred nunc pro tunc to Nov. 20, 2023; restitution $188,100 ordered March 19, 2024	[1]

Disciplinary status can change only through further court action.

Sources

1. Matter of McKenna, 2024 NY Slip Op 01514 (1st Dept Mar. 19, 2024) (Justia republication of the slip opinion). https://law.justia.com/cases/new-york/appellate-division-first-department/2024/motion-no-2023-05409-case-no-2023-06260.html