On Friday, January 12, 2024, the U.S. Department of Justice Executive Office for Immigration Review Board of Immigration Appeals upheld the six-month suspension of Ronald Salomon from practicing law before the Board of Immigration Appeals, the Immigration Courts, and the Department of Homeland Security.

The case is entitled “In the Matter of Ronald Salomon.”

The case stemmed from an incident in September 2018 when Salomon had a verbal altercation with a legal assistant in the courtroom of Immigration Judge Marie Lurye. According to witnesses, Salomon approached the assistant during a recess in a master calendar hearing and accused her of being racist and anti-Semitic in a loud, raised voice.

An investigation was launched by the Disciplinary Counsel for the Executive Office for Immigration Review. In December 2018, Salomon was charged with engaging in “contumelious or otherwise obnoxious conduct” that would constitute contempt of court. This charge was based on his behavior toward the legal assistant during the incident.

The case was referred to an Adjudicating Official, who held a hearing on the matter in May 2021. In addition to testimony from witnesses, the Official reviewed affidavits and letters of support submitted regarding the incident. In an August 2021 written decision, the Official found that Salomon’s conduct would have been punishable as contempt.

As a sanction, the Official suspended Salomon from practicing before immigration courts and agencies for six months, citing Salomon’s prior disciplinary history as an aggravating factor. Salomon had received an informal admonition in 2016 for a separate incident of inappropriate conduct toward an immigration court staff member.

Salomon appealed the decision to the Board of Immigration Appeals. However, in its January 2024 ruling, the Board fully upheld the Official’s factual findings, legal conclusions, and six-month suspension. The Board dismissed Salomon’s claims that his speech was protected, that his due process rights were violated, and allegations of bias against the adjudicators.

The Board found clear and convincing evidence that Salomon’s behavior qualified as sanctionable conduct. It affirmed that a six-month suspension was warranted given Salomon’s disciplinary record, which now includes two incidents of disrespectful behavior toward immigration court personnel.

The Disposition states:

“The respondent’s appeal is dismissed. FURTHER ORDER: The Board hereby suspends the respondent from practice before the Board of Immigration Appeals, the Immigration Courts, and DHS for 6 months, effective 15 days from the date of this order.”

A copy of the original filing can be found here.