A disbarred New Jersey lawyer accused of helping himself to large sums of client funds has succeeded in defeating one of the most serious charges against him—and in the process prompted an appeals court to shed some light on how the money laundering statute applies to attorney account misuse.

The Appellate Division said evidence that Joseph Talafous Jr. used his trust and business accounts to facilitate the alleged thefts by itself didn't support the charge of money laundering—the only first-degree offense among the 19 counts with which he is charged.

“The State presented no evidence that the theft was concealed (as opposed to committed) through placement of the money in defendant's accounts,” the Appellate Division said Tuesday in State v. Talafous.