In Re: Parks

CourtUnited States Court of Federal Claims
DecidedJune 2, 2026
Docket25-11281
StatusPublished

This text of In Re: Parks (In Re: Parks) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Parks, (uscfc 2026).

Opinion

In the United States Court of Federal Claims Nos. 25-11281, 25-11282 (Filed: June 2, 2026)

************************* * In re: Diana M. Parks * In re: Hadeel Masseoud * * *************************

MEMORANDUM OPINION AND ORDER ON PETITION FOR REHEARING

On March 31, 2026, the Standing Panel on Attorney Discipline (“Standing Panel”) issued a Final Order imposing discipline on Respondents, Diana M. Parks and Hadeel Masseoud. Final Order, In re Masseoud, No. 25-11282 (Fed. Cl. Apr. 1, 2026), ECF No. 11; see also In re Parks, No. 25-11281, 2026 WL 890145 (Fed. Cl. Mar. 31, 2026) (consolidated cases). The Standing Panel found that Respondents engaged in conduct unbecoming a member of this Court’s bar under Rule 83.2(c)(5) of the Rules of the United States Court of Federal Claims (“RCFC”). Final Order at 13. Specifically, the Standing Panel determined that Ms. Masseoud knowingly made false statements regarding her bar admission status, failed to correct false statements made by Ms. Parks on her behalf regarding her bar admission status, and made false statements concerning her services in her biography on her law firm’s website. See id. at 7–11. With respect to Ms. Parks, the Standing Panel determined that she knowingly made false statements about Ms. Masseoud’s bar admission status, made false statements regarding her law firm’s legal services on its website, and, as a law firm partner, failed to provide proper oversight over Ms. Masseoud. Id. at 11–13. The Standing Panel, therefore, suspended Respondents from the practice of law before the United States Court of Federal Claims for six months and required that they notify their clients and all other jurisdictions in which they are licensed of the imposed discipline. Id.

Respondents have filed a Petition for Rehearing with the Standing Panel. ECF No. 12. For the reasons set forth below, after carefully considering the Petition for Rehearing and the material provided in support thereof, the Standing Panel modifies the discipline imposed on Respondents.

I. RESPONDENTS’ PETITION FOR REHEARING

On April 2, 2026, the Standing Panel received a motion from Respondents, styled as a motion for reconsideration under RCFC 59(a)(1). Id. at 1. However, RCFC 59 is not the correct rule under which to request review of a disciplinary decision. Rather, “reconsideration” of a final order in an attorney disciplinary proceeding is accomplished through a petition for rehearing under RCFC 83.2(j). Accordingly, the Standing Panel construes Respondents’ motion as a petition for rehearing. 1

In their petition, Respondents “expressly acknowledge their wrongdoing and that sanctions are appropriate” and state that they “do not seek to relitigate the [Standing Panel’s] findings of misconduct.” Id. Instead, Respondents “request reconsideration of the severity and practical effect of the sanction[s] imposed.” Id. Respondents assert that “[d]epriving them of the ability to practice for six months will not only disrupt their clients’ claims but will also place th[eir] small boutique and fully woman-owned firm at substantial risk of closure.” Id. at 5. According to Respondents, “[t]he firm’s client base, revenue, and ongoing matters are inextricably tied to Respondents’ ability to appear before this Court and continue to practice law,” and “[a] sustained inability to do so for fully six months . . . will immediately disrupt active representations, erode client relationships, halt all work, and eliminate the firm’s primary source of revenue.” Id. at 6. In sum, Respondents contend that, “[w]hen combined with reciprocal discipline in Georgia and New York, the sanction will likely prevent Respondents from practicing law,” and that this “outcome far exceeds what is necessary to serve the purposes of attorney discipline . . . particularly where there has been no finding of client harm and where Respondents have undertaken substantial corrective measures.” Id. at 7. For relief, Respondents request that the Standing Panel “impose a reduced form of discipline, such as a public reprimand, probation[,] or a short suspension conditioned on compliance measures,” which Respondents posit “would reflect the seriousness of the issues identified, account for Respondents’ remorse and corrective actions, align with governing precedent, and avoid disproportionate and practice- ending consequences.” Id. at 12.

Incongruously, despite expressly acknowledging their wrongdoing, accepting that sanctions are warranted, and stating that they do not seek to relitigate the Standing Panel’s findings, see id. at 1, only a few days later, Respondents filed a supplement to their petition in which they challenge the Standing Panel’s procedures and findings, ECF No. 14. Therein, Respondents first argue that they “were not afforded a meaningful opportunity to prepare and present evidence addressing [the website] issue” because “the website issue was not identified in the referral or disclosed prior to the hearing.” ECF No. 14 at 2. Consequently, Respondents allege a due process violation and assert that they “were deprived of a fair opportunity to develop the record on a matter that the [Standing Panel] ultimately relied upon in assessing an aggravating factor affecting the severity of the sanction.” Id. at 3. Second, Respondents contend that the Standing Panel improperly found that their conduct was undertaken with a self-interested motive and that such a finding lacks evidentiary support. Id. at 4–8. In sum, Respondents argue that “[t]he findings that Respondents engaged in a pattern of misconduct and acted with a dishonest or selfish motive were central to the [Standing Panel’s] sanctions analysis and

1 In addition to their petition for rehearing, Respondents filed an emergency motion to stay or, in the alternative, extend the deadlines for client notification and reporting obligations. ECF No. 13. The Standing Panel granted Respondents’ motion to stay the client notification and reporting obligations on April 8, 2026. ECF No. 15. Thereafter, in response to a letter from Respondents’ counsel received on April 15, 2026, ECF No. 16, the Standing Panel retroactively stayed Respondents’ suspensions to allow for meaningful consideration of Respondents’ motion for reconsideration and supporting documents, ECF No. 17 at 1.

2 materially increased the severity of the discipline imposed,” and “[b]oth findings are affected by the procedural and evidentiary deficiencies.” Id. at 8. According to Respondents, “[w]ithout the website material, the record does not support a finding of a sustained pattern over time,” and “[w]ithout evidentiary support for a dishonest or selfish motive, the basis for that aggravating factor is not established.” Id. The Standing Panel will address Respondents’ due process, motive, and proportionality arguments in turn before addressing modification of the discipline imposed.

A. Due Process

Respondents’ due process arguments are unpersuasive. In support of their challenge relating to the website issue, Respondents rely on a United States Supreme Court case, In re Ruffalo, 390 U.S. 544 (1968), to argue that the Standing Panel was required to inform Respondents of the website issue before the hearing and “that introducing [the website issue] during the hearing itself [was] inconsistent with fundamental fairness.” ECF No. 14 at 3. But the present case is readily distinguishable from In re Ruffalo.

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Related

In Re Ruffalo
390 U.S. 544 (Supreme Court, 1968)
Peer v. Lewis
606 F.3d 1306 (Eleventh Circuit, 2010)
In Re Reines
771 F.3d 1326 (Federal Circuit, 2014)

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Bluebook (online)
In Re: Parks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-parks-uscfc-2026.