Background
Steven D. DiLibero is a Rhode Island attorney who was suspended by the Massachusetts Supreme Judicial Court. Based on that suspension, the Rhode Island Supreme Court entered an order on June 16, 2025 imposing reciprocal discipline: a one-year suspension, with six months and one day to serve.
Disciplinary Counsel Kerry Travers subsequently filed a Second Report and Recommendation, which the Court considered at its June 3, 2026 conference. As of that date, DiLibero remained suspended in Massachusetts and had not sought reinstatement in either jurisdiction. Through his counsel, Michael Lepizzera, DiLibero communicated no objection to the Rhode Island suspension order remaining in effect.
The Court’s Holding
The Rhode Island Supreme Court ordered that DiLibero shall remain suspended pursuant to its June 16, 2025 order until further order of the Court. The Court declined to lift or modify the reciprocal suspension while the underlying Massachusetts suspension remains in place.
The Court also directed Disciplinary Counsel to provide a status update no later than September 15, 2026, at which point the Court will reassess whether any further action is warranted.
Key Takeaways
- Rhode Island will maintain a reciprocal suspension as long as the originating Massachusetts suspension remains in force.
- An attorney’s consent to continued suspension — communicated through counsel — is a relevant factor in the Court’s decision to leave the order in place without further proceedings.
- The Court set a mandatory status-update deadline of September 15, 2026, keeping the matter on its active docket rather than closing it.
Why It Matters
This order illustrates Rhode Island’s standard practice of tying reciprocal discipline to the status of discipline in the originating jurisdiction. Attorneys suspended elsewhere cannot treat the Rhode Island reciprocal order as a separate, self-expiring matter; the suspension continues automatically until the home-state bar clears them and Rhode Island issues a further order.
The case also signals to disciplinary practitioners that cooperation — here, DiLibero’s express non-objection — streamlines the process but does not accelerate reinstatement. Reinstatement requires affirmative action in the originating jurisdiction first.