Minnesota Lawyer
The Minnesota Supreme Court disbarred Ignatius Chukwuemeka Udeani on Jan. 25 for multiple instances of misconduct over nine years and against multiple clients. Udeani had been practicing law for over two decades in Minnesota, specializing in immigration law.
In May 2000, Udeani was admitted to practice in Minnesota. From 2007 on, however, Udeani has acquired a lengthy disciplinary history. He was placed on private probation in 2007, admonished in 2012, admonished in 2013, suspended for 30 days in 2017, and indefinitely suspended in 2020.
The petition for Udeani’s disbarment was filed in 2021. The director of the Office of Lawyers Professional Responsibility alleged nine separate rule violations involving five clients, including failure to return unearned fees to two clients (one of which was an instance of misappropriation), creation of costly and time-consuming delays for clients, and incompetent representation of clients in immigration-related matters. Two of Udeani’s clients were placed at risk for deportation. Udeani also did not cooperate with the investigation as the office looked into seven complaints.
The court also considered many aggravating factors. Most critical to the court’s analysis was Udeani’s disciplinary record, which it noted was “extensive” and “involves misconduct similar to his current misconduct.”
Jennifer Peterson, senior assistant director of the OLPR, asked the court to consider the “utter lack of remorse and accountability from Mr. Udeani” and “all of the harm that he has caused to very vulnerable immigrants over the years.” Peterson stated, “It’s time for him to be disbarred.”
“His actions caused extensive harm to several clients and their families and damaged the legal profession,” the court wrote. “When the weight of these violations is combined and considered in light of Udeani’s prior professional discipline for similar misconduct, the other aggravating factors found by the referee, and the lack of mitigating factors, we hold that the appropriate discipline in this case is disbarment.”
Back in 2020, when the Minnesota Supreme Court indefinitely suspended Udeani, Justice Anne McKeig and former Justice David Lillehaug sounded the alarm about Udeani. They dissented, maintaining that the “case cries out for disbarment.” McKeig, who authored the dissent, wrote, “[T]he risk is too great to leave open the possibility that this attorney might practice again.”
They noted that Udeani’s misconduct — which included 16 counts of misconduct and 29 different rule violations — not only occurred while under the supervision of a well-qualified immigration attorney but also happened while Udeani knew that his law license was at stake.
Finding it “difficult to overstate the harm that Udeani has caused,” Justice McKeig wrote that Udeani inflicted “incalculable harm” upon his clients. “Udeani’s clients made significant sacrifices to save the necessary funds to retain him. They worked multiple jobs, opened their homes to renters, borrow from family members, and even went without medication and treatment. They placed this money, and their trust, in Udeani’s care.” As a result of Udeani’s conduct in that time period, one client was deported and another was unable to secure a kidney transplant as a result of not having a U-Visa due to Udeani’s inaction.
However, the Minnesota Supreme Court gave Udeani an indefinite suspension in July 2020 with no right to petition for reinstatement for three years. Although it stated that it understood how Udeani’s behavior could warrant disbarment, it ultimately accepted the OLPR director’s recommendation. Disbarment was on the table for Udeani at one point; however, the director ultimately decided against recommending disbarment because the misconduct did not involve a felony conviction, serious dishonesty, or personal misappropriation.
As the court noted, much of Udeani’s misconduct in the most recent proceeding happened at the same time as the misconduct that caused Udeani’s suspension in 2020. However, Udeani did not cooperate with the director, causing two different proceedings.
Udeani, who had represented himself in past disciplinary proceedings, did not appear on Oct. 6, 2022, in front of the Minnesota Supreme Court. He also did not file a brief with the court. Minnesota Lawyer was unable to reach Udeani for comment.
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