On Thursday, January 25, 2024, the Supreme Court of Florida reprimanded attorney Frank Carvajal for misconduct in an immigration matter.

The case is entitled “The Florida Bar v. Frank Carvajal” with case number SC2023-1193.

The reprimand stems from a Complaint filed by The Florida Bar in August 2023, alleging Carvajal violated several ethics rules in his representation of a client in an immigration matter. According to the Complaint, in July 2016 Carvajal was hired and paid $1,000 by Ramon Martinez Mandujano to represent him in an appeal of his removal proceedings before the Board of Immigration Appeals.

However, the Complaint alleges Carvajal filed the appeal pro se on Mandujano’s behalf, even though he submitted a form indicating he would be filing a brief as the attorney of record. The Board dismissed the appeal after Carvajal failed to file the promised brief or explain his failure to do so. This meant Mandujano lost the chance for the Board to review the denial of his case and potentially appeal further.

The Florida Bar argued in the Complaint that Carvajal never intended to file an appellate brief and should not have indicated otherwise on the filing form. It alleged Carvajal failed to properly communicate with Mandujano, gave ineffective legal representation, and engaged in conduct prejudicial to the administration of justice. As a result, the Complaint asserted Carvajal violated Bar rules regarding diligence, fees, declining representation, meritorious claims, and conduct prejudicial to the justice system.

In response, Carvajal claimed his actions did not affect the outcome of Mandujano’s case. However, he provided no evidence substantiating this claim.

The case was referred to a Bar referee, who issued an uncontested report finding Carvajal committed the violations as alleged in the Complaint. The Supreme Court approved this report in its Disposition Order, reprimanding Carvajal and ordering him to pay $1,250 to cover the Bar’s costs.

According to Avvo, Mr. Carvajal is an immigration attorney in Santa Ana, California. He graduated from the University of San Diego School of Law in 1994. He obtained his law license in Florida in 1995.

A copy of the original filing can be found here.