This Time It’s Permanent

Permanent disbarment has been imposed by the Tennessee Supreme Court after two prior disbarment orders

After a hearing upon the disciplinary petition consisting of five (5) separate disciplinary complaints, the Hearing Panel determined by a preponderance of the evidence that Mr. Sams—who had been disbarred on November 26, 2014, and again on August 5, 2016—engaged in the unauthorized practice of law by providing services requiring the professional judgment of a lawyer to five separate clients. Mr. Sams provided these services, which he advertised as “immigration consulting” services (including “form selection” and “strategy”), through S2 Consulting, LLC—a limited liability company created by Mr. Sams. The Hearing Panel further found that Mr. Sams failed to notify his clients of his disbarment status; misrepresented himself as a licensed attorney when, in fact, he was not; prepared “ghostwritten” immigration forms (which, in some instances, contained material factual inaccuracies) for signature by other licensed attorneys; misrepresented the status of certain immigration cases; failed to notify clients of deadlines for certain submissions; violated provisions of the Code of Federal Regulations; and knowingly disobeyed obligations to the Federal Immigration Court and the Tennessee Supreme Court. In certain instances, Mr. Sams’ conduct resulted in irreparable injury.

The Panel found Mr. Sams’ conduct violated Tennessee Rules of Professional Conduct 3.4 (knowingly disobeying an obligation under the rules of a tribunal), 5.5 (unauthorized practice of law), and 8.4 (misconduct)and warranted permanent disbarment.

(Mike Frisch)