Given the government’s focus on immigration enforcement, lawyers in the immigration area should expect to see more disciplinary enforcement. What would draw the interest of the disciplinary authorities are cases where the lawyer neglected immigration cases or took funds from clients and did not complete the work. The ARDC review board recommended a two-year suspension of an attorney. This decision is from the Review Board. It is a recommendation. The Review Board reviews recommendations of the ARDC Hearing Board. The Illinois Supreme Court has the final say on all disciplinary matters.
Summary: In re Mahdis Azimi — ARDC Review Board Report (Feb. 2026)
Background
Mahdis Azimi, an Illinois immigration attorney admitted in 2015, faced a ten-count disciplinary complaint arising from misconduct in ten client matters between September 2021 and October 2023. She operated a solo practice while simultaneously holding a full-time administrative position at Loyola University School of Law.
Misconduct Found
The Hearing Board found violations across all ten counts, including:
- Failing to file immigration petitions in seven matters
- Making false representations to clients in multiple cases (claiming filings had been made when they had not)
- Ignoring client communications
- Failing to refund unearned fees in six cases
- Failing to surrender client files in four cases
- Depositing client funds into her operating account rather than a trust account
- Failing to comply with the Administrator’s subpoena for four client files
- Making a false statement during a sworn statement to the Administrator
- Providing false testimony at the disciplinary hearing itself
Key Aggravating Factors
- Prior discipline for nearly identical misconduct (90-day suspension in 2022), with the current misconduct beginning while that prior case was pending
- A persistent pattern of dishonesty, not attributable to her mental health diagnoses (ADHD, PTSD, anxiety, depression) per the Administrator’s unrebutted psychiatric expert, Dr. Rone
- Failure to accept full responsibility
- Lack of credibility as a witness on key issues
- No restitution made; no trust account ever opened
Mental Health
Azimi raised mental health as a mitigating factor. Dr. Rone acknowledged her diagnoses could explain disorganization but concluded the pattern of dishonesty was not a symptom of those conditions. Dr. Rone recommended years of dialectical behavioral therapy and found Azimi’s current treatment inadequate and her prognosis for ethical practice poor absent significant intervention. Azimi presented no rebuttal expert, having been barred from doing so after missing disclosure deadlines.
Procedural Rulings Affirmed
The Review Board upheld the Hearing Board Chair’s rulings barring Azimi’s expert witness (due to non-compliance with disclosure deadlines), allowing Dr. Rone’s testimony, and permitting the Administrator’s closing argument on lack of remorse. No due process violation was found.
One Exception — Count VII
The Review Board found the Administrator failed to prove Azimi cashed the client money orders at issue in Count VII, and therefore vacated the Rule 1.15(a) (misuse of funds) finding on that count only. All six other violations in Count VII were affirmed.
Sanction
- Hearing Board recommended: 3-year suspension, UFO
- Review Board recommended: 2-year suspension, UFO (until further order of court)
The Review Board found a three-year suspension unnecessarily long, but agreed a UFO provision was essential given Azimi’s recidivism, dishonesty pattern, and the psychiatric expert’s conclusion that she remains unfit to practice. To seek reinstatement, she must affirmatively demonstrate rehabilitation, ethical fitness, restitution, and that her mental health treatment has been effective.
Comment: in the immigration area, the client may be vulnerable to deportation. Few of these clients will have the ability to file a legal malpractice lawsuit if they have been deported. For that reason, disciplinary authorities will view these cases as good targets for enforcement. Please keep this in mind if you do this type of work.