SPARROW

Citations

• 20 I. & N. Dec. 920

Syllabus

SPARROW, 20 I&N Dec. 920 (BIA 1994) ID 3237 (PDF) (1) Because the Noticeof Entry of Appearance as Attorney or Representative (Form G-28) is designedto determine whether an individual is an attorney within the meaning of8 C.F.R. § 1.1(f) (1994), an attorney filing this form has a dutyto disclose disciplinary actions or other restrictions on his practiceof law in the bars of courts in jurisdictions other than those in whichhe claims to be in good standing. (2) Where an attorneyin disciplinary proceedings under 8 C.F.R. § 292.3(a)(10) (1994)is charged with willfully making false and material statements or representationswith respect to his qualifications or authority to represent others inany case, his false statement or representation is deemed material ifit has a tendency to influence, or is capable of influencing, the decisionof the decision-making body to which it was addressed. (3) A 10-year suspensionfrom the practice of law before the Immigration and Naturalization Serviceand the Executive Office for Immigration Review is appropriate where therespondent has a conviction which involved a conspiracy to violate immigrationlaws through a sham marriage scheme, making false statements to the Service,suborning perjury, and stealing government property the respondent isunder suspension from the practice of law in three states the respondentmisrepresented his qualifications or authority to represent others inimmigration proceedings on Notices of Entry of Appearance and the respondentdid not report his conviction to the Executive Office for ImmigrationReview or state bar authorities.