A California Notary was ordered to pay more than $600,000 in penalties and legal fees in September 2025 for providing unauthorized legal services to immigrants, according to the San Francisco City Attorney’s office.
City Attorney David Chiu said in a statement that California Notary Leonard Lacayo falsely portrayed himself as an attorney to provide improper legal services to hundreds of immigrants despite neither being licensed to practice law in the state or registered and bonded as an immigration consultant. The city had filed previous injunctions against Lacayo in 2017 and 2022, prohibiting him from providing immigration-related services. However, an investigation found that Lacayo had violated the injunction.
The San Francisco Superior Court imposed a civil penalty of $503,500 against Lacayo for violations of the injunction since 2022, along with $110,581 in attorney fees.
“Leonard Lacayo has demonstrated zero regard for the law or the immigrant communities he claims to serve,” Chiu said. “For years, he has targeted vulnerable immigrants, taking their money while putting them in legal jeopardy. His actions are particularly egregious during a time of mass deportations and heightened fear in our immigrant communities. Immigration services are desperately needed right now, but I want the public to know that Lacayo is not legally allowed to provide immigration services of any kind. We appreciate the Court agreed that Lacayo’s deliberate misconduct must end.”
As of September 25, 2025, Lacayo’s California Notary commission remains active.
Unethical Notaries have taken advantage of immigrants seeking legal advice in many states. In Spanish-speaking countries, the title “Notario Publico” refers to legal professionals authorized to advise clients on matters of law. However, nonattorney U.S. Notaries are not allowed to provide legal advice to clients, but many immigrants are not aware of this. As a result, immigrants may fall prey to scammers calling themselves “Notarios” who falsely claim they can provide legal assistance with immigration matters, but instead take money from victims without providing any real advice or services. The clients of these scammers often find themselves in serious legal difficulties as a result.
Many U.S. states prohibit Notaries from translating the title “Notary Public” into a foreign language in their advertisements, and require Notaries to post notices that they are not authorized to provide legal advice to customers. California also prohibits Notaries from advertising Notary services if they claim to be an immigration specialist, immigration consultant, or use any other title that suggests they have expertise in immigration matters.
Offering unauthorized legal advice can result in severe legal, financial and civil penalties for Notaries. For more information, please see our article on avoiding the unauthorized practice of law as a Notary.
David Thun is the Editorial Manager at the National Notary Association.