Introduction

In In re: Salvador Randazzo, No. 2025-B-0772 (La. Sept. 10, 2025) (per curiam), the Louisiana Supreme Court imposed a three-year suspension, with eighteen months deferred, on a lawyer-litigant who repeatedly engaged in improper ex parte communications with a trial judge’s staff and filed pleadings laced with unsubstantiated, disparaging assertions impugning the integrity of multiple judges and appellate courts. The case arises from three disciplinary complaints filed by Judge Darren Roy of the 34th Judicial District Court and presents a focused application of core professional duties governing ex parte contact (Rule 3.5), statements about judicial officers (Rule 8.2), and conduct prejudicial to the administration of justice (Rule 8.4(d)), reinforced by Louisiana Supreme Court civility rules governing filings in the state’s appellate courts.

The decision is significant for two reasons. First, it expressly frames “disbarment” as the baseline sanction under the ABA Standards for intentional misconduct of this sort. Second, it delineates a sanctioning boundary: where the attorney’s false and disparaging attacks are largely confined to judicial officers and staff (rather than broadcast to the public), a lengthy suspension may be appropriate—here, the top end of the suspension range—rather than disbarment. Justice Crain dissented, deeming the sanction too lenient.

Summary of the Opinion

The Office of Disciplinary Counsel (ODC) formally charged attorney Salvador Randazzo with violations stemming from:

• Repeated ex parte calls and voicemails to Judge Roy’s chambers in an active case in which Randazzo was a party, including attempts to discuss merits, probe likely rulings, and make disparaging statements about opposing parties and judges (Rules 3.5(a)–(b), 8.4(a), 8.4(d)).
• Pleadings asserting that Judge Roy maliciously withheld an order to thwart appellate rights, and other accusations made without factual support (Rule 8.2(a), 8.4(a), 8.4(d)).
• Additional filings in the Fourth Circuit and Louisiana Supreme Court containing insulting, discourteous, and unfounded claims about Judge Roy, Judge Hans Liljeberg (serving ad hoc), and the Fourth Circuit, in violation of Supreme Court Rule VII, § 7 and General Administrative Rule, Part G, § 11 (as well as Rules 8.2(a), 8.4(a), 8.4(d)).

A hearing committee found all charges proved by clear and convincing evidence, credited testimony from Judge Roy and multiple staff members, identified multiple aggravating factors and no mitigation, and recommended a three-year suspension with eighteen months deferred. The Supreme Court, exercising original jurisdiction and applying manifest error review to the committee’s fact findings, agreed that the record established intentional violations causing actual harm. Noting that disbarment is the baseline sanction under the ABA Standards, but that similar Louisiana cases typically result in suspensions from one year and a day up to three years, the Court distinguished In re McCool (disbarment) because Randazzo’s audience was essentially limited to court staff and judges. Adopting the committee’s recommendation, the Court suspended Randazzo for three years with eighteen months deferred and assessed costs. Justice Crain dissented, finding the discipline too lenient.

Factual and Procedural Background

The misconduct arose out of a long-running property and succession dispute pending in Division “D” of the 34th JDC. While acting as a litigant (and as a lawyer), Randazzo:

• Placed at least eight calls to chambers between May 5–26, 2021, leaving voicemails or engaging staff in one-sided presentations, asking how the judge would rule, predicting actions he would take depending on rulings, and making disparaging remarks about participants and judges.
• Ignored a May 27, 2021 court order directing all parties to contact the court only by email, and sent emails containing ex parte information and statements calculated to influence (“I need the transcript … to attach to my complaint against Darren Roy with the Judicial Commission”).
• Filed pleadings accusing the judge of intentionally withholding service of an order to sabotage appellate rights—claims later shown false by court records—and submitted multiple filings in the Fourth Circuit and Louisiana Supreme Court imputing bias, corruption, or incompetence to judges and courts using insulting language. The Supreme Court had previously refused to consider a writ because of discourteous language under Rule VII, § 7 and General Administrative Rule, Part G, § 11.

Randazzo did not appear at the February 24, 2025 hearing on the formal charges. Although a purported family member contacted the disciplinary board to report illness or hospitalization, the committee chair invited submission of medical proof or a motion to transfer to disability inactive status; none was submitted. The ODC presented documentary evidence (phone records, transcripts, emails, pleadings) and testimony from Judge Roy, Judge Liljeberg, and three members of Judge Roy’s staff. The committee found the witnesses credible and the misconduct proven.

Counts and Rule Violations

• Count I (Ex parte and influence attempts):
  • Rules violated: 3.5(a), 3.5(b), 8.4(a), 8.4(d).
  • Conduct: Calls and voicemails with chamber staff about the merits, anticipated rulings, other judges, threats to complain to disciplinary authorities, and accusations of favoritism, followed by emails containing ex parte content despite a court order.
• Count II (False accusations in pleadings regarding service of order):
  • Rules violated: 8.2(a), 8.4(a), 8.4(d).
  • Conduct: Pleadings asserting that Judge Roy executed an order but withheld service to let deadlines lapse and stifle an appeal, claims unsupported by facts and disproved by the record.
• Count III (Wider pattern of disparagement in appellate filings):
  • Rules violated: 8.2(a), 8.4(a), 8.4(d), Supreme Court Rule VII, § 7; General Administrative Rule, Part G, § 11.
  • Conduct: Repeated filings accusing judges and the Fourth Circuit of bias, corruption, and incompetence in vulgar or insulting terms; the Supreme Court previously declined to consider one writ based on discourteous language.

Analysis

Precedents Cited and Their Influence

• In re Banks, 18 So. 3d 57 (La. 2009): Reaffirms the Court’s original jurisdiction over disciplinary matters, its independent duty to review the record, and the clear-and-convincing standard of proof. This frames the Court’s de novo legal review in Randazzo.
• In re Caulfield, 683 So. 2d 714 (La. 1996), and In re Pardue, 633 So. 2d 150 (La. 1994): Establish that hearing committee fact findings are reviewed for manifest error. The Court relies on the committee’s credibility determinations in upholding the violations here.
• Louisiana State Bar Ass’n v. Reis, 513 So. 2d 1173 (La. 1987), and Louisiana State Bar Ass’n v. Whittington, 459 So. 2d 520 (La. 1984): Articulate the purposes of discipline—protect the public, preserve the integrity of the profession, deter misconduct—and the case-by-case nature of sanctions. These principles guide sanction selection.
• In re McCool, 172 So. 3d 1058 (La. 2015): Disbarment imposed where an attorney used a lengthy social media campaign to influence a pending case, encouraged ex parte communications from the public, and disseminated false and misleading information about the presiding judge. The Court treats McCool as the high-water mark for this category and distinguishes Randazzo because his audience was largely confined to courts and judicial staff.
• In re Klein, 362 So. 3d 392 (La. 2023): One year and one day suspension for unsubstantiated disparagement of a judge and opposing counsel, ex parte contact with a law clerk, defiance of court orders, and abusive removal to federal court. Klein demonstrates that ex parte contact with court staff is sanctionable and informs the lower bound of the range.
• In re Abadie, 320 So. 3d 1073 (La. 2021): One year and one day suspension for a false statement impugning a judge’s integrity and procedural abuses. Affirms that Rule 8.2(a) violations warrant meaningful suspension, even for single-incident falsehoods.
• In re Mire, 197 So. 3d 656 (La. 2016): One year and one day, largely deferred, for filings accusing judges of incompetence/corruption and political motives. Illustrates calibrated suspensions where speech misconduct is serious but has less aggravation than here.
• In re Cook, 932 So. 2d 669 (La. 2006): Three-year suspension with 18 months deferred for repetitive, unwarranted filings and discovery abuses. This decision anchors the top of the suspension range and mirrors the ultimate sanction in Randazzo.
• LSBA v. Karst, 428 So. 2d 406 (La. 1983): One-year suspension for publicly accusing a judge of dishonesty and corruption, with publication in the local press. Karst shows that public dissemination aggravates, yet still yielded a suspension pre-dating the modern Standards; McCool reflects the contemporary disbarment endpoint when public campaigns attempt to sway pending cases.

Legal Reasoning

The Court’s reasoning proceeds in three steps: proof of violations, baseline sanction with aggravation/mitigation analysis, and calibration by reference to jurisprudence.

1. Proof of Rule Violations.
   • Rule 3.5(a)–(b) (influence and ex parte communications): Randazzo repeatedly contacted the judge’s chambers, pressing merits, fishing for likely rulings, and disparaging parties and judges. Court staff testified to the content and tone of calls. Even after a specific order directing email-only contact, he injected ex parte merits content into written communications. This is textbook ex parte conduct that offends the neutrality of decision-making and the integrity of court processes.
   • Rule 8.2(a) (false statements about judicial officers): The pleadings accused the trial judge of deliberately withholding service of an order to sabotage an appeal, among other impugning statements. When asked at a sworn statement to provide facts, Randazzo offered only beliefs and conjecture. Court records contradicted his claims. 8.2(a) bars statements a lawyer knows are false or made with reckless disregard for truth; the record supports both knowledge and recklessness.
   • Rule 8.4(d) (conduct prejudicial to the administration of justice) and Rule 8.4(a) (derivative violation): The cumulative pattern—pressuring chambers through ex parte contact, attempting to influence rulings, lacing filings with attacks on integrity, and ignoring civility directives—caused actual harm to the administration of justice and violated Rule 8.4(d). The specific rule breaches also support an 8.4(a) derivative violation.
   • Supreme Court Rule VII, § 7 and General Administrative Rule, Part G, § 11 (civility requirements): The Supreme Court had previously refused to consider one of Randazzo’s writs due to discourteous and insulting content. Those same civility expectations apply throughout appellate practice. Violating them, particularly after admonition, aggravates culpability and reinforces Rule 8.4(d).
2. Baseline Sanction, Aggravation, Mitigation.
   • Baseline: Applying the ABA Standards for Imposing Lawyer Sanctions, the committee and Court identified disbarment as the baseline for intentional acts that subvert the legal process and impugn judicial integrity through false statements and ex parte communications.
   • Aggravating factors: The Court adopted the committee’s findings: dishonest or selfish motive; bad-faith obstruction by failing to comply with disciplinary processes (non-appearance, no medical substantiation); refusal to acknowledge wrongful conduct; and substantial experience in practice (admitted 1982).
   • Mitigation: None. The record contains no mitigating evidence; the committee left the record open to consider medical or disability submissions, but none were provided.
3. Calibration via Jurisprudence.

   Although disbarment is the baseline, Louisiana’s recent discipline for analogous misconduct has most frequently produced suspensions ranging from one year and a day to three years. McCool stands as the disbarment precedent due to the breadth and public nature of the campaign to influence a pending case. Here, the Court found a critical limiting factor: Randazzo’s audience was “essentially limited to judicial staff and presiding judges.” That distinction justified a sanction at the top end of the suspension range—three years, with half deferred—rather than disbarment.

Impact and Prospective Significance

• Ex parte contact with court staff is treated as contact with the court. Asking staff how a judge will rule, pressing merits arguments, or attempting to influence outcomes via chambers is prohibited. Orders that channel communications (e.g., email only) do not authorize ex parte merits content.
• Rule 8.2(a) demands facts, not beliefs. Lawyers may argue for recusal or criticize decisions, but accusations impugning a judge’s integrity must be tethered to facts. An attorney’s “beliefs and opinions” do not suffice and, if unfounded, constitute discipline-worthy falsehoods.
• Civility rules in appellate practice have teeth. The Supreme Court may refuse to consider filings that violate Rule VII, § 7 and Part G, § 11. Persisting in discourteous, insulting filings after such an admonition compounds Rule 8.4(d) exposure.
• Sanctioning framework clarified: The Court reaffirms disbarment as the baseline for intentional false attacks on judges and ex parte attempts to influence. However, where dissemination is confined to the courts, a lengthy suspension can be appropriate. Public campaigns to influence pending cases (as in McCool) heighten the risk of disbarment.
• Pro se lawyers are not exempt. Attorneys acting as parties remain bound by all professional rules in their “personal” cases. The decision underscores that professional obligations do not yield to personal stakes.
• Noncooperation aggravates. Failing to participate in disciplinary proceedings, ignoring opportunities to demonstrate mitigation (e.g., medical issues), and refusing to acknowledge wrongdoing all drive sanctions upward.
• Top-of-range suspension as guidance: By imposing three years with 18 months deferred, the Court signals that repeated, intentional judicial attacks and ex parte conduct—absent public amplification—will be met with the maximum suspension historically imposed for similar categories, short of disbarment.
• Dissent as cautionary note: Justice Crain’s view that the discipline is too lenient will likely be cited in future cases to argue for disbarment where aggravators multiply or dissemination widens.

Complex Concepts Simplified

• Ex parte communication: Any direct or indirect communication with a judge or court staff about a pending matter without the other parties present or copied, unless expressly permitted by law or court order. Even seemingly innocuous inquiries (“How will the judge rule?”) cross the line.
• Rule 8.2(a) standard: Lawyers may not make statements they know are false, or state accusations with reckless disregard for their truth, about a judge’s qualifications or integrity. Reckless disregard means speaking without any reasonable factual basis or ignoring contrary evidence.
• Clear and convincing evidence: A high standard of proof requiring the fact-finder to be firmly convinced of the truth of the allegations, but not as stringent as proof beyond a reasonable doubt.
• Manifest error review: Appellate deference to a fact-finder’s credibility and fact determinations unless clearly wrong. In discipline, the Supreme Court independently reviews, but respects committee fact findings unless manifestly erroneous.
• Baseline sanction and calibration: Under the ABA Standards, certain categories of intentional misconduct start at disbarment. The actual sanction is then adjusted for aggravating and mitigating factors and compared to similar cases to promote consistency.
• “One year and a day” vs. longer suspensions: In Louisiana, suspensions over one year typically require formal proceedings for reinstatement, ensuring proof of current fitness to practice.
• Deferred suspension: A portion of the suspension is stayed on conditions. Any misconduct during the deferral period can trigger making the deferred time executory or the imposition of additional discipline.
• Supreme Court Rule VII, § 7 and General Administrative Rule, Part G, § 11 (civility): Appellate filings must be courteous and free from insulting criticism. Lawyers must speak and write civilly and respectfully in all communications with the court.

Practical Takeaways for Practitioners

• Never contact chambers about the merits or likely rulings. Scheduling and purely administrative matters should go through proper channels, and even then, avoid any substantive discussion.
• When seeking recusal or complaining of bias, stick to verifiable facts. Avoid conclusory, accusatory rhetoric; let the record speak.
• Observe appellate civility rules. Strong advocacy is not incompatible with respectful language; discourtesy can result in both procedural and disciplinary consequences.
• If health or other issues impede participation in disciplinary proceedings, submit timely documentation or seek disability inactive status where appropriate.
• Remember that conduct as a party is still lawyer conduct. Your license travels with you into your own case.

Conclusion

In re Randazzo reinforces a firm disciplinary message: intentional ex parte contacts with judicial staff and unfounded attacks on judicial integrity are grave professional violations. While disbarment is the baseline under the ABA Standards, Louisiana’s sanctioning tradition calibrates penalties based on the scope and audience of the misconduct. By distinguishing public campaigns to influence cases (McCool) from attacks confined to the courts, the Supreme Court placed Randazzo at the apex of the suspension range—three years with eighteen months deferred—underscored by multiple aggravators and the absence of mitigation. The decision strengthens the state’s commitment to courtroom civility, the integrity of judicial processes, and the principle that lawyers—whether advocating for clients or themselves—must not erode public confidence in the administration of justice.

Justice Crain’s dissent signals that, as similar cases accumulate or where dissemination broadens, the Court may edge closer to disbarment. For now, Randazzo stands as a clear, structured warning: respect the barriers to ex parte influence, ground accusations in facts, and maintain civility—or face severe professional consequences.

Case Disposition

• Sanction: Three-year suspension, with eighteen months deferred.
• Conditions: Misconduct during the deferral period may make the deferred portion executory or result in additional discipline.
• Costs: Assessed with legal interest beginning thirty days after finality of judgment.
• Dissent: Crain, J., would reject as too lenient.