Department of Justice
Executive Office for Immigration Review
||Tuesday, October 25, 2011
EOIR Announces Latest Disciplinary Actions Under Rules of Professional Conduct
Two Attorneys Immediately Suspended; Two Receive Final Orders
FALLS CHURCH, Va. - The Executive Office for Immigration Review (EOIR) has recently taken disciplinary action against four attorneys for violations of the Rules of Professional Conduct for immigration attorneys and representatives.
EOIR announces these disciplinary actions to inform the public about attorneys and representatives who are no longer authorized to represent clients before an immigration tribunal. These names will be added to the list of disciplined immigration attorneys and representatives, which is available at http://www.justice.gov/eoir/profcond/chart.htm. The list includes links to immediate suspension orders, final orders, and reinstatement orders issued in each disciplinary case.
Disciplinary proceedings begin when the Office of the General Counsel of either EOIR or the Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services, files a Petition for Immediate Suspension and/or a Notice of Intent to Discipline with EOIR's Board of Immigration Appeals (BIA). The disciplinary action can result in the public censure, suspension, or expulsion of an attorney or representative before the immigration courts, the BIA, and DHS. Before a suspended or expelled attorney can resume the practice of law before the immigration courts, the BIA, or DHS, the BIA must reinstate that attorney.
EOIR has recently taken the following disciplinary actions:
The BIA ordered the immediate suspension of the following attorneys:
- Ronald Grady Finch: The Supreme Court of California suspended Mr. Finch from the practice of law for one year for violating the conditions of his probation. The BIA granted the government's petition for immediate suspension on Oct. 6, 2011, based on Mr. Finch’s suspension in California and pending final disposition of his case.
- Samson Mparaganda: The Supreme Judicial Court for Suffolk County, Massachusetts, administratively suspended Mr. Mparaganda from the practice of law in that state. The BIA granted the government's petition for immediate suspension on Sept. 28, 2011, based on Mr. Mparaganda’s administrative suspension in Massachusetts and pending final disposition of his case.
Final Orders of Discipline
- Axel Heydasch: A final order of Oct. 6, 2011, suspends Mr. Heydasch from practice before immigration tribunals for three years, effective Aug. 29, 2011, based on his suspension in Florida.
- Joseph Angel Silva, Jr.: A final order of Oct. 6, 2011, suspends Mr. Silva from practice before immigration tribunals for five years, effective Sept. 1, 2011, based on his resignation from the practice of law in Texas while disciplinary proceedings were pending.
The Rules of Professional Conduct appear in Title 8 of the Code of Federal Regulations
(8 C.F.R. '' 1003 and 1292). They include provisions specifying grounds for disciplinary action, requirements for receiving and investigating complaints, and procedures for conducting hearings. The rules also authorize the BIA to suspend immediately an attorney or representative who has been subject to disbarment, suspension or resignation with an admission of misconduct as imposed by a federal or state court, or who has been convicted of a serious crime, pending a summary proceeding and final sanction. The Rules of Professional Conduct are available at
Additional information about the Attorney Discipline Program can be found at http://www.justice.gov/eoir/press/00/profcond.htm and http://www.justice.gov/eoir/press/09/AttorneyDisciplineFactSheet.pdf.
- EOIR -
The Executive Office for Immigration Review (EOIR) is an agency within the Department of
Justice. Under delegated authority from the Attorney General, immigration
judges and the Board of Immigration Appeals interpret and adjudicate
immigration cases according to United States immigration laws. EOIR’s
immigration judges conduct administrative court proceedings in immigration
courts located throughout the nation. They determine whether foreign-born
individuals—whom the Department of Homeland Security charges with
violating immigration law—should be ordered removed from the United States or
should be granted relief from removal and be permitted to remain in this
country. The Board of Immigration Appeals primarily reviews appeals of
decisions by immigration judges. EOIR’s Office of the Chief Administrative
Hearing Officer adjudicates immigration-related employment cases. EOIR is
committed to ensuring fairness in all of the cases it adjudicates.