The Maryland Court of Special Appeals has upheld the Client Protection Fund trustees’ denial of a man’s initial $3.1 million claim for misappropriated funds, finding an attorney who was convicted of embezzling the money from an escrow account was not acting in a fiduciary capacity that is “traditional and customary in the practice of law in Maryland.”

Steven J. Grebow, an experienced lender in development projects, challenged the trustees’ final decision denying his claim for reimbursement from the fund, which is meant to reimburse members of the public for attorneys’ misappropriation of funds, according to the Maryland Court of Special Appeals’ opinion filed June 29.