NY Attorney Patrick Mbonu Chukwu Censured for Neglect and Lack of Diligence in Immigration Cases

On Thursday, March 5, 2026, the New York Supreme Court, Appellate Division, Third Judicial Department censured attorney Patrick Mbonu Chukwu following a motion brought by the Attorney Grievance Committee for the Third Judicial Department. The censure stems from Chukwu’s professional conduct in handling immigration matters.

The case is entitled “In the Matter of Patrick Mbonu Chukwu,” with case number PM-34-26.

Chukwu, admitted to practice in New York in 2006, operates an immigration law practice in Texas, despite not being admitted to the bar in that state. The disciplinary action arose from allegations of incompetent representation of two clients in separate immigration cases. The Attorney Grievance Committee filed a petition of charges verified on September 9, 2025, seeking public discipline against Chukwu.

The court’s decision followed a period of review, including Chukwu’s response on October 20, 2025, and the petitioner’s statement of facts filed on November 6, 2025. The court granted adjournments to allow both parties to prepare a joint motion for discipline by consent.

The joint motion included a stipulation of facts, aggravating and mitigating factors, and an agreement on the ultimate sanction. Chukwu provided an affidavit conditionally admitting to several rule violations, including failure to provide competent representation, failure to act with reasonable diligence, and neglect of client matters. He also admitted to freely and voluntarily consenting to the joint motion and the agreed-upon sanction.

While the parties agreed to a censure, the court considered whether such a sanction was commensurate with similar cases and sufficient to protect the public, maintain the honor and integrity of the profession, and deter others from similar misconduct. The court noted that misconduct pertaining to inadequate representation in immigration matters has generally resulted in either censure or suspension.

In aggravation, the petitioner cited Chukwu’s prior disciplinary history of an admonition for similar misconduct and his representation of vulnerable clients involved in immigration proceedings. Chukwu cited his contrition, cooperation with the petitioner’s investigation, and efforts to rectify the consequences of his misconduct as mitigating factors.

The justices concurred with the decision to grant the parties’ joint motion and censure Chukwu.

A copy of the original filing can be found here.