The Massachusetts Supreme Judicial Court has affirmed the disbarment of attorney Benjamin Behnam Tariri, definitively rejecting his claims that his original consent to disbarment was obtained through duress and coercion. The court's October 14, 2025 decision in *In the Matter of Benjamin Behnam Tariri* marks the conclusion of a protracted legal battle that began with Tariri's disbarment in June 2023.
The case originated on June 26, 2023, when a single justice of the Supreme Judicial Court issued a judgment of disbarment against Tariri. Despite having consented to the disbarment, Tariri immediately sought to appeal the judgment. However, his notice of appeal was dismissed as untimely, effectively ending his first attempt to challenge the disciplinary action.
Undeterred by the failed appeal, Tariri pursued an alternative legal strategy. In July 2024, more than a year after his disbarment, he filed a motion in county court titled "Motion Under M.R.Civ.P. 60(b)." In this motion, Tariri argued that his consent to disbarment "was obtained under duress and coercion" and requested that the court set aside the judgment of disbarment.
The Massachusetts Rules of Civil Procedure Rule 60(b) typically allows parties to seek relief from final judgments under certain circumstances, including fraud, mistake, or newly discovered evidence. Tariri's motion appeared to invoke this provision as grounds for overturning his disbarment.
However, the single justice denied Tariri's motion, prompting him to appeal once again to the full Supreme Judicial Court. In its October 2025 decision, the court affirmed the denial of Tariri's motion on multiple grounds, effectively closing all avenues for challenging his disbarment.
The Supreme Judicial Court's opinion addressed two fundamental legal issues that undermined Tariri's motion. First, the court noted that the Massachusetts Rules of Civil Procedure do not apply to bar discipline proceedings. The court cited Mass. R. Civ. P. 81(a)(1) and referenced precedent from *Matter of the Discipline of an Attorney* (2014) to support this position. This ruling meant that Tariri's entire legal strategy was based on an inapplicable procedural framework.
The court emphasized that it would have been well within the single justice's discretion to deny the motion solely on the basis that civil procedure rules do not govern attorney disciplinary matters. This represents a significant limitation on the types of post-judgment relief available to attorneys facing disciplinary sanctions.
Second, the court addressed the substance of Tariri's motion, noting that despite his designation of the filing as a Rule 60(b) motion, it essentially requested reconsideration of the disbarment judgment. The court found that the single justice did not err or abuse his discretion in denying the motion based on the record presented.
Critically, the court noted that Tariri's motion consisted of "a single three-page document containing unsworn assertions regarding 'newly discovered' evidence." This characterization suggests that Tariri's motion lacked the evidentiary foundation necessary to support his claims of duress and coercion. The court's reference to "unsworn assertions" indicates that Tariri failed to provide affidavit testimony or other verified evidence to substantiate his allegations.
The decision highlights important procedural requirements for attorneys seeking to challenge disciplinary actions. The court's emphasis on the inadequacy of unsworn assertions suggests that future challenges to disciplinary proceedings must be supported by properly verified evidence, including sworn testimony and documentary proof.
Tariri's case also illustrates the limited options available to attorneys who consent to disciplinary sanctions but later seek to withdraw that consent. The court's rejection of his duress claims, combined with the dismissal of his original appeal as untimely, demonstrates the finality that courts attach to consensual disciplinary resolutions.
The Supreme Judicial Court's decision reinforces the separate procedural framework that governs attorney discipline in Massachusetts. Unlike civil litigation, disciplinary proceedings operate under specialized rules that limit the availability of traditional post-judgment relief mechanisms.
For the legal profession, this case serves as a reminder of the importance of carefully considering any consent to disciplinary action. Once an attorney consents to sanctions such as disbarment, the opportunities for subsequent challenge are extremely limited, particularly when procedural deadlines are missed or inadequate evidence is presented.
The court's affirmance of the disbarment also underscores the seriousness with which Massachusetts courts treat attorney misconduct and the finality of disciplinary sanctions. Tariri's multiple unsuccessful attempts to challenge his disbarment demonstrate the difficulty of overturning consensual disciplinary resolutions, even when allegations of duress are raised.
With the Supreme Judicial Court's October 2025 decision, Tariri has exhausted his legal options for challenging the disbarment. The ruling represents a definitive conclusion to a case that spanned more than two years and involved multiple legal strategies. The decision reinforces existing precedent regarding the procedural framework governing attorney discipline in Massachusetts and the evidentiary standards required for post-judgment relief in such proceedings.