STATE OF MICHIGAN
Attorney Discipline Board
GRIEVANCE ADMINISTRATOR,
Attorney Grievance Commission,
Petitioner/Appellee,
AMINE R. BEYDOUN, Case No. 24-89-GA
Complainant/Appellant,
v
ISSA FAWAZ, P 83664,
Respondent/Appellee.
/
ORDER AFFIRMING HEARING PANEL ORDER OF REPRIMAND
WITH CONDITIONS AND RESTITUTION
Issued by the Attorney Discipline Board
333 W. Fort St., Ste. 1700, Detroit, MI
Tri-County Hearing Panel #6 of the Attorney Discipline Board issued an order on June 16, 2025, reprimanding respondent and imposing conditions and restitution (by consent). Complainant filed a petition for review, arguing that the panel erred in approving the parties' stipulation for consent order of discipline because the panel misapplied several mitigating factors and approved discipline that is contrary to precedent. Both respondent and the Grievance Administrator disagreed, asserting that complainant’s argument is based on facts and allegations outside of those asserted in the formal complaint, and that a reprimand is consistent with the ABA Standards as well as Board precedent.
The Attorney Discipline Board has conducted review proceedings in accordance with MCR
9.118, including review of the evidentiary record before the panel and consideration of the briefs
and arguments presented by the parties at a virtual review hearing conducted on September 10, 2025. For the reasons discussed below, we affirm the decision of the hearing panel approving the parties’ amended stipulation for consent order of discipline and imposing a reprimand with conditions and restitution.
In a review proceeding initiated by a complainant's petition following the entry of an order of discipline by consent pursuant to MCR 9.115(F)(5), the Board's role is quite limited. Ordinarily, the Board has broad authority to “review and, if necessary, modify a hearing panel's decision as to the level of discipline” in light of its “responsibility to ensure a level of uniformity and continuity” in disciplinary matters. Grievance Administrator v Brent S. Hunt, 12‑10‑GA (ADB 2012), p 7, citing Grievance Administrator v August, 438 Mich 296, 304; 475 NW2d 256 (1991); MCR 9.110(E)(4). However, when a complainant seeks review of an order of discipline agreed to by the Attorney Grievance Commission and a respondent that has been approved by a hearing panel, the Board does not consider allegations not admitted, nor does the Board adjust the level of discipline imposed by the panel based upon a stipulation of the parties. Rather, the Board's function in these cases is only to assess whether the discipline agreed to and imposed is appropriate for the misconduct admitted to by respondent. Grievance Administrator v Barry Bess, 14‑16‑GA (ADB 2015). If we find that it is inappropriate, the Board is limited to either referring the matter to another hearing panel for hearing, or remanding to the panel below for further consideration. Id.
This case involves allegations that respondent committed professional misconduct while providing various legal services to the complainant, Amine Beydoun, and his father, Robert Beydoun, with regard to properties they managed, as well as some personal matters. Specifically, respondent was retained to handle blight tickets, evictions, and other matters related to a series of properties managed by the Beydouns.
The matter was assigned to Tri‑County Hearing Panel #6, and on December 12, 2024, the parties submitted a Stipulation for Consent Order of Discipline. A copy of the stipulation was served on complainant as required by MCR 9.115(F)(5). Complainant objected, asserting that the stipulation misstated mitigating factors and that a reprimand was too lenient. After providing written responses to complainant’s objections at the request of the panel, a status conference was held in April 2025. At the status conference, complainant, respondent’s counsel, and counsel for the Grievance Administrator addressed the panel and their concerns regarding the stipulation. Thereafter, the parties submitted an Amended Stipulation for Consent Order of Discipline, which provided for a reprimand, significant restitution, and several specifically tailored conditions.[1] On June 16, 2025, the panel accepted the amended stipulation and, in accordance with the stipulation of the parties, ordered that respondent be reprimanded, with conditions and restitution, effective July 8, 2025. Complainant petitioned for review, asserting that the panel erred in accepting the stipulation by applying incorrect standards, improperly considering mitigation, and imposing a sanction inconsistent with precedent. The Grievance Administrator and respondent filed responsive briefs requesting that the order of the hearing panel be affirmed.
The Board acknowledges that this matter is personal for complainant, and we recognize his frustration with the disciplinary process thus far. However, complainant’s arguments rely on numerous facts, allegations, and materials that were either not included in the formal complaint or were dismissed by the parties’ stipulation. He attaches multiple documents to his brief that are either outside the record or pertain to allegations never charged. These allegations and materials are not properly before the Board and have not been considered here. The Board has long held that the Attorney Grievance Commission exercises prosecutorial discretion in determining which rule violations to charge and retains authority to withdraw a complaint or particular charges deemed unworthy of prosecution. See Grievance Administrator v Kurt A. O’Keefe, 90‑13‑GA (ADB 1992). The Board has likewise recognized that it lacks authority to order the Commission to investigate or prosecute allegations that were not charged. See Grievance Administrator v David E. Christensen, 18‑71‑GA (ADB 2019).
The issue before the Board is whether the hearing panel properly concluded that the sanction in the amended stipulation is appropriate given the nature of the uncontested misconduct and under the relevant facts and applicable law – not whether the Commission adequately investigated complainant’s request for investigation or should have pursued additional charges. The allegations and materials complainant submitted during the investigative process, along with respondent’s answers, were reviewed by the Commission, which then exercised its discretion in determining which charges to file. In short, complainant must accept the allegations actually brought in the formal complaint, not the allegations he believes should have been included. His additional claims do not constitute proof of misconduct and should not be considered.
Complainant also argues that the reprimand imposed by the panel is insufficient. However, the ABA Standards cited by the parties and accepted by the hearing panel, along with the applicable aggravating and mitigating factors and conditions imposed, all support discipline in the range of a reprimand. We find that a reprimand, when combined with the imposed conditions and significant restitution, is sufficient to prevent future misconduct by respondent and to protect the public, the courts, and the profession.
On review, complainant primarily takes issue with the mitigating factors the parties agreed to apply in the amended stipulation,[2] starting with the application of ABA Standard 9.32(f), inexperience in the practice of law. This factor primarily takes into account the number of years a lawyer has practiced at the time of the misconduct, with fewer years in practice weighing more heavily toward mitigation. Respondent was licensed to practice law in Michigan in November of 2019. Therefore, at the time of the misconduct (August 2020 until April 2022), respondent had very little experience. As such, it was proper for the hearing panel to consider this as a mitigating factor.
Complainant also takes issue with the application of remorse as set forth in ABA Standard 9.32(l), as a mitigating factor. However, in statements made and by entering into the stipulation for consent discipline, respondent has acknowledged the wrongfulness of his conduct, agreed to pay substantial restitution, and has shown a willingness to take preventative measures to avoid issues in the future. There is nothing in the record to contradict the applicability of remorse as a mitigating factor.
Third, complainant takes issue with the application of Standard 9.22(e), full and free disclosure to disciplinary board or cooperative attitude toward proceedings, as a mitigating factor. Contrary to complainant's assertion, the record supports the application of this factor. Respondent pled no contest to all but one subsection of the allegations,[3] and took action to rectify the effects of his actions. Further, counsel for the Grievance Administrator is in the best position to evaluate respondent's cooperation, and he confirmed that respondent was cooperative, there were no attempts to obstruct the Grievance Administrator or the hearing panel, and there is no evidence that respondent submitted or attempted to submit forged or false evidence.
Finally, complainant asserts that Board precedent mandates disbarment for the severity of respondent's violations. However, complainant's claim is not supported by the case law. The Board opinions cited and relied upon by complainant involve the intentional misappropriation of client funds, which was not charged in the present case. While the violations found here are serious, there was no finding of dishonest or intentional conduct. And although there are numerous individual rule violations, cumulatively they support the hearing panel's conclusion that respondent's misconduct was negligent and not intentional, and was the result of inexperience. A reprimand combined with substantial restitution and conditions that are relevant to the established misconduct is within the range of appropriate discipline for the misconduct to which respondent pleaded no contest.
We find that the hearing panel’s acceptance of the Amended Stipulation for Consent Order of Discipline was based on an informed decision as to whether the sanction agreed to by the parties was appropriate for which respondent’s plea of no contest was tendered. The Board is satisfied that the discipline imposed is within the acceptable range of the ABA Standards and prior Board precedent.
NOW THEREFORE,
IT IS ORDERED that the hearing panel's Order of Reprimand with Conditions and Restitution (By Consent) issued on June 16, 2025, is AFFIRMED.
IT IS FURTHER ORDERED that respondent is hereby REPRIMANDED, effective JULY 8, 2025.
ATTORNEY DISCIPLINE BOARD
By: /s/ Alan M. Gershel, Chairperson
Dated: December 2, 2025
Board Members Alan Gershel, Peter A. Smit, Rev. Dr. Louis Prues, Linda M. Orlans, Jason M. Turkish, Tish Vincent, and Andreas Sidiropoulos, MD, concur in this decision.
Board Members Katie M. Stanley and Kamilia Landrum were absent and did not participate in this decision.
[1] The amended stipulation, and ultimately the panel’s order, contained the following conditions:
1. Respondent must participate in a one‑year mentorship with attorney Sam F. Fakih acting as mentor, beginning no sooner than the effective date of the order of discipline, with the mentor submitting quarterly reports to the Grievance Administrator;
2. Respondent and his mentor shall meet at least once a month and the mentor shall monitor respondent's office management and client management practices. In addition to any other relevant information, the mentor's quarterly reports to the Grievance Administrator shall include a summary of any recommendations the mentor may make to respondent regarding his office management and client management practices, as well as a summary of respondent's compliance, or lack thereof, with said recommendations. If for whatever reason Mr. Fakih becomes unwilling or unable to serve as respondent's mentor, Mr. Fakih and/or respondent shall inform the Grievance Administrator of this fact and the reason he can no longer continue as mentor, and respondent shall secure a replacement mentor that shall be approved in advance by the Grievance Administrator;
3. Respondent must attend and successfully complete the State Bar of Michigan's next available "Tips and Tools for a Successful Practice" seminar, and shall provide proof of said completion to the Grievance Administrator; and
4. Respondent must attend and successfully complete an Institute of Continuing Legal Education (ICLE) seminar (or comparable course) related to law practice management, within twelve months of the effective date of the order of discipline, and shall provide proof of said completion to the Grievance Administrator.
[2] Standard 9.0 of the ABA Standards for Imposing Lawyer Sanctions lists aggravating and mitigating circumstances, described as factors that may justify an increase or decrease in the degree of discipline to be imposed. In the amended stipulation, the parties noted that they considered and applied the aggravating factors set forth in ABA Standard 9.22(a) prior disciplinary offenses; 9.22(c) a pattern of misconduct; and 9.22(d) multiple offenses. The amended stipulation further noted that the parties considered and applied the mitigating factors set forth in ABA Standard 9.32(e) full and free disclosure to disciplinary board or cooperative attitude toward proceedings; 9.32(f) inexperience in the practice of law; and 9.32(l) remorse.
[3] The parties agreed that the violation of MRPC 8.4(b), as set forth in paragraph 79(v) of the formal complaint, would be dismissed.