SAN FRANCISCO (LN) — A federal judge in the Northern District of California sanctioned Strategic Legal Practices and four of its attorneys a combined $5,250 Monday, separately sanctioned defendant's counsel $500, barred the lemon law firm from dismissing or transferring any of its cases without court approval, and ordered founder Payam Shahian to appear in person May 6 and attest under penalty of perjury to every sanction ever imposed on the firm, its lawyers, or himself since SLP opened its doors.
U.S. District Judge Noel Wise issued the order in a Song-Beverly Consumer Warranty Act case brought by plaintiff Santiago Talavera Castro against FCA US, LLC — a case that spiraled into a firm-wide reckoning after SLP attorneys missed the March 18, 2026 pretrial filing deadline entirely and no one who appeared at the subsequent April 1 hearing had even been counsel of record when the deadline passed.
The sanctions against SLP attorneys tell a story of widespread compliance failures: Tionna Carvalho, one of only two current SLP partners, disclosed 19 prior sanctions and drew a $3,000 penalty; former Senior Counsel Rabiya Tirmizi, who was counsel of record on the missed deadline and filed a notice of disassociation from the firm a week after the show-cause order, drew $1,500; Elizabeth LaRocque, who had disclosed five prior sanctions, drew $750; and Larry Chae, who initially reported no sanctions before the court ordered a supplemental declaration, drew $500 after acknowledging he had been sanctioned twice. Defendant's firm RoseWaldorf LLP was separately sanctioned $500 for failing to meet and confer or file any pretrial materials.
The picture Carvalho painted at the April 22 hearing was stark: SLP carries approximately 10,000 active cases, runs on a split pre-trial and trial team structure with no single responsible attorney assigned through a case's lifecycle, and has watched roughly 30 percent of its attorneys depart in the past year. Carvalho herself told the court she is leaving the firm effective May 1, 2026 — meaning Shahian will shortly be the sole remaining partner overseeing that entire docket.
At the April 22 hearing, Carvalho provided the court with a hard copy of a March 26, 2026 order from the Central District of California imposing a $10,000 sanction against SLP in a separate consumer warranty case, Chapman v. FCA US. The first paragraph of that order states:
Plaintiff Brittany Michelle Chapman retained Strategic Legal Practices APC (the Firm) to represent her in this consumer warranty action. What followed was not merely inadequate representation but an abdication of counsel's core professional responsibility of providing competent, diligent, and accountable representation. The record reveals a volume-driven business approach to litigation—marked by perfunctory line-level attention, lack of meaningful supervision, and execution falling well below professional standards. Most strikingly, counsel approved and filed critical trial documents that effectively doomed their client's case by requiring Plaintiff to prove she purchased a "new" vehicle, despite the undisputed fact that it was preowned. These deficiencies were further compounded by counsel's failure to conduct a reasonable factual and legal investigation, to comply with basic pretrial obligations and court orders, and to provide timely and adequate responses when called to account. Taken together, the record reflects not isolated error, but a systemic breakdown in professional responsibility warranting sanctions.
After imposing the $10,000 sanction, that court added that it was uncertain whether even that amount would be sufficient to deter similar problems in the future.
Wise also flagged a Southern District of California ruling from February 2025 in Mason v. FCA USA in which the court stated that the record could support a conclusion that SLP attorneys affirmatively misled their clients when they advised their clients that the court would be dismissing their case — conduct the Mason court described as something that might be construed as a breach of an attorney's duty of undivided loyalty. Wise wrote that this was likewise unsettling to the court.
The order prohibits SLP from dismissing or transferring to another firm any case in which an SLP attorney was counsel of record as of April 22, 2026, without advance written approval from the client, approval from the applicable court, and personal confirmation by Shahian that both the client and the court have received the order — a restriction Wise tied directly to concern that clients whose statutes of limitations may have already run could be left without recourse.
Both Carvalho and Tirmizi were ordered to report their sanctions to the State Bar of California within 14 days. The court noted that despite Carvalho having been sanctioned twice in February alone — each time $1,500, above the $1,000 threshold that triggers mandatory State Bar reporting — it does not appear the State Bar has disciplined any of the SLP lawyers involved in the case.
Shahian's declaration is due May 1, 2026, and must include a comprehensive alphabetical chart of every sanction imposed on every current and former SLP attorney since the firm's founding, every sanction imposed on the firm itself, and a thorough explanation of what steps he has personally taken to ensure compliance with professional responsibility rules across his practice. He is required to appear in person at the May 6 hearing — no substitutions or video appearances permitted.