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Attorney Licensing


Attorney Licensing


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7th Circuit Court of Appeals

Case Name: Maurice Salem v. Illinois Attorney Registration and Disciplinary Com

Case No.: 22-3222

Officials: Easterbook, Rovner, Pryor, Circuit Judges.

Focus: Attorney Licensing

In 2003, Salem obtained a license to practice law in New York. Although he applied for a license to practice in Illinois, where he lived, he was denied. Nonetheless, from 2004 to 2019, he continued to practice law in Illinois by obtaining special permission to appear in court on specific cases (“pro hac vice”). However, this led to legal trouble when the Illinois Attorney Disciplinary and Registration Commission (IARDC) accused him of falsely claiming to be licensed in Illinois. As a result, they successfully requested that the Illinois Supreme Court prohibit him from appearing pro hac vice for 90 days. Salem responded by filing a lawsuit under 42 U.S.C. 1983.

The Seventh Circuit upheld the dismissal of Salem’s lawsuit and ordered him to explain why he shouldn’t face sanctions. Firstly, the court rejected Salem’s argument that all Illinois district judges should be disqualified and the case should be moved to Michigan. Secondly, the court ruled that the Illinois Supreme Court’s decision could not be challenged in this civil litigation. They pointed out that the IARDC, the defendant in the case, had not deprived Salem of his liberty or property, and there was a reasonable basis for the Supreme Court’s decision. The court described Salem’s lawsuit as frivolous and highlighted his history of engaging in “preposterous” behavior in federal court. Salem has 14 days to show cause why he should not be subject to sanctions, No. 22-3222 11 including an order to pay the defendants’ attorneys’ fees.


Decided 09/28/23

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