Wisconsin Court System
Wisconsin Attorneys' Professional Discipline Compendium
2026-06 Public Reprimand of Alf Langan
2026-06
Attorney Alf Langan was admitted to the practice of law in Wisconsin on September 19, 1999, State Bar No. 1001838.
In or about February 2020, a woman hired Langan to represent her in a matter seeking grandparent visitation rights of her two minor grandchildren while their biological parents were incarcerated and the children were living with their stepmother. The fee agreement provided Langan would deposit the advanced fees into his business account rather than his trust account. Accordingly, Langan was required to comply with all the provisions of SCR 20:1.5(g), the alternative protection for advanced fees.
Pursuant to an agreement between his client and the children's parents, Langan petitioned for temporary guardianship of each of the minor children on behalf of his client, which petitions were granted in October 2020. If not extended by the court, the temporary guardianships would expire in April 2021. Langan did not check in with the client or file for extensions of the temporary guardianships, which expired on April 13, 2021.
After realizing that the guardianships had expired, on June 19, 2021, Langan filed motions to extend the guardianships, which the court denied. Therefore, on August 4, 2021, Langan filed new petitions for temporary guardianship. By that point, the parents were no longer incarcerated. The court set a hearing on the new guardianship petitions for September 20, 2021.
Because he had a scheduling conflict, on September 15, 2021, Langan sent the court a letter requesting to reschedule the hearing to a later date. Langan emailed the client to inform her he had requested the court re- schedule the hearing.
Thereafter, Langan never followed up with the court to see if the hearing had been rescheduled, reschedule the hearing, or otherwise proceed with the petitions for temporary guardianship. On February 7, 2022, the court dismissed the guardianship petitions for inactivity. By that point, the children had returned to the custody of their father and stepmother.
Aside from one brief phone call in December 2021, Langan did not communicate with his client about the status of the guardianship petitions or her rights regarding her grandchildren. In February 2023, the client emailed Langan asking for an update. On February 20, 2023, Langan responded and informed her the guardianship petitions had been dismissed. He told her, "Procedurally we're at the beginning." The client did not pursue the guardianships further. Instead, she filed her grievance with OLR.
At the conclusion of the representation, Langan did not provide the client with an accounting or the notices required by SCR 20: l .5(g)(2), including notice that the client could dispute the fee or that Langan would be required to submit any fee dispute to binding arbitration.
In pursuing a public reprimand, OLR took into consideration in mitigation that Langan did not appear to have any dishonest of selfish motive. By failing to diligently pursue his client's interests, resulting in the dismissal of her cases, Langan violated SCR 20:1.3, which states: "A lawyer shall act with reasonable diligence and promptness in representing a client."
By failing to timely communicate with the client regarding the status of her cases and her rights regarding her grandchildren, Langan violated SCR 20:1.4(a)(3), which states, "A lawyer shall keep the client reasonably informed about the status of the matter."
At the conclusion of the representation, by failing to provide his client with an accounting and all of the notices required by SCR 20:1.5(g)(2), Langan violated SCR 20:1.5(g)(2), which states, "Upon termination of the representation, the lawyer shall deliver to the client in writing all of the following: a. A final accounting, or an accounting from the date of the lawyer's most recent statement to the end of the representation, regarding the client's advanced fee payment. b. A refund of any unearned advanced fees and costs. c. Notice that, if the client disputes the amount of the fee and want􀀬 that dispute to be submitted to binding arbitration, the client must provide written notice of the dispute to the lawyer within 30 days of the mailing of the accounting. d. Notice that, if the lawyer is unable to resolve the dispute to the satisfaction of the client within 30 days after receiving notice of the dispute from the client, the lawyer shall submit the dispute to binding arbitration."
Langan has prior discipline. Langan was publicly reprimanded in 2020 for failure to provide post- termination notices, in violation of SCR 20:1.5(g)(2); failure to refund unearned fees, in violation of SCR 20:1.16(d); and depositing earned fees and other personal funds into his trust account, in violation of SCR 20:1.15(b) (3). In 2015, Langan was privately reprimanded for depositing advanced fees to his business account without providing clients the proper notices, in violation of former SCR 20:1.15(b) (4m); failing to refund unearned fees, in violation of SCR 20:1.16(d); and failing to provide fee and accounting notices, in violation of former SCR 20:1.15(b)(4m). In 2011, Langan was publicly reprimanded for lack of diligence, in violation of SCR 20:1.3; failure to refund unearned fees, in violation of former SCR 20:1.16(d); by representing the client with regard to the sale of her structured settlement payments for the purpose of paying his own legal fees, without obtaining the client's written consent after consultation, in violation of former SCR 20:1.7(a); failure to comply with the advertisement rule, in violation of former SCR 20:7.3(b); failure to consult about a potential conflict of interest, in violation of former SCR 20:1.7(b); and failure to advise a client to seek independent representation, in violation of former SCR 20: 1.8(h).
Despite Langan's three prior reprimands, OLR and the Referee considered as a mitigating factor that Langan was experiencing significant personal issues at the time of the misconduct, having suddenly and unexpectedly lost his son the year before.
In accordance with SCR 22.09(3), Attorney Alf Langan is hereby publicly reprimanded.
Dated this 1st day of June, 2026.