On Thursday, July 17, 2025, the District of Columbia Court of Appeals suspended attorney Steven Villarreal from practicing law for 30 days due to violations of professional conduct rules. The suspension is stayed, meaning it will not take effect unless Villarreal fails to meet the conditions of a one-year unsupervised probation period, which includes completing eight hours of continuing legal education (CLE).
The case is entitled “In the Matter of Steven Villarreal,” with case no. 24-BG-0581.
The court’s decision follows a report from the Board on Professional Responsibility, which found that Villarreal violated several rules while representing a client in an immigration case. The case involved Adriana Hernandez, who sought to reopen removal proceedings to adjust her immigration status under Section 245(i) of the Immigration and Naturalization Act. This section allows certain immigrants who entered the U.S. without inspection to seek lawful permanent resident status if they meet specific criteria, including proof of physical presence in the U.S. on December 21, 2000, and that the individual is the beneficiary of an immigrant visa petition, such as a Form I-130 filed before April 30, 2001.
Villarreal was hired to file a motion to reopen Hernandez’s case, but did not gather essential documents, such as evidence of Hernandez’s mother’s lawful status, a copy of the visa petition, or proof of Hernandez’s presence in the U.S. An expert testified that these documents were necessary for the motion.
The immigration judge denied the motion due to the lack of supporting evidence. When Hernandez asked Villarreal to explain the denial, he did not acknowledge his error or accept responsibility for it. Instead, he advised her to collect the documents and retain him for another motion. Hernandez declined, hired new counsel, and was awaiting her green card at the time the disciplinary report was issued.
The Hearing Committee concluded that Villarreal violated D.C. Rules of Professional Conduct 1.1(a) and 1.1(b) for failing to provide competent representation and exercise due skill and care. The committee also found a violation of Rule 1.3(a) for not representing Hernandez diligently, as he had sufficient time to collect the required documents but failed to do so. However, the committee determined there was insufficient evidence to prove a violation of Rule 1.3(c) for lack of promptness.
The Hearing Committee noted that Villarreal did not attend the disciplinary hearing, citing his inability to afford an attorney and his reluctance to represent himself. He informed the Office of Disciplinary Counsel (ODC) of his absence in advance. The committee viewed his non-attendance as an aggravating factor, indicating a lack of remorse, but also considered his clean disciplinary record and absence of fraudulent conduct as mitigating factors. The Board adopted the committee’s findings and recommended the 30-day suspension, stayed in favor of probation with CLE requirements.
The court upheld the Board’s recommendation, noting that Villarreal cooperated with the ODC’s investigation and provided a reason for his absence. The court found the sanction consistent with similar cases, balancing the seriousness of Villarreal’s misconduct and the prejudice to his client against his lack of prior disciplinary issues and cooperation with the investigation.
During probation, Villarreal must complete eight hours of CLE, including two hours on ethics, within the first six months and certify compliance within 14 days of completion. He is not required to notify clients of his probation, but risks revocation if he violates its terms.
The Disposition states:
“Accordingly, respondent Steven Villarreal is hereby suspended from the practice of law for thirty days, stayed in favor of one year of unsupervised probation with the following conditions.”
A copy of the original filing can be found here.
