In People v. Keeffe, 50 N.Y.2d 149 (1980) Keeffe, an attorney, established a special account in which funds from a client's judgment in a medical malpractice action were held, and he depleted the account before paying the fee owed to his client's former attorney. Because there was no lien or order giving the former attorney an interest in the funds, the Court of Appeals held that the former attorney was not an "owner" of the funds, and that Keeffe could thus not be convicted of stealing them from him.