Way Out West

A censure from the New York Appellate Division for the Third Judicial Department

Respondent was admitted to practice by this Court in 2004. She lists a business address in Arizona with the Office of Court Administration. Although respondent is not admitted to practice in Arizona, she maintains an immigration practice in that state on the strength of her New York license.

Between 2014 and 2018, disciplinary orders were separately imposed upon respondent in the form of, among other things, a reprimand, probation and an informal admonition by, respectively, the Supreme Court of Arizona, the United States Court of Appeals for the Ninth Circuit and the Executive Office for Immigration Review for sustained acts of professional misconduct in a variety of matters. Notably, in the course of these proceedings, respondent was found guilty of, among other things, engaging in conduct lacking competence and diligence, commencing frivolous litigation, neglecting the interests of a client and making misleading statements.

Sanction

Turning to the issue of the appropriate disciplinary sanction, we take note of the nature of respondent’s sustained misconduct in the course of her immigration practice in Arizona serving a very vulnerable clientele, which included, among other things, a sustained charge that she failed to act with reasonable diligence in performing a service for a client

…we find that, under the circumstances, respondent should be censured.

(Mike Frisch)