Addressing head on for the first time the issue of attorney ghostwriting, a federal appeals court said yesterday that a Manhattan immigration attorney had not engaged in sanctionable misconduct when she drafted petitions for parties appearing pro se.

Judges Jose Cabranes (See Profile), Robert Sack (See Profile) and Richard Wesley (See Profile) of the U.S. Court of Appeals for the Second Circuit made that decision in In re Fengling Liu, 09-90006-am, while also adopting a disciplinary report recommending that attorney Fengling Liu be publicly reprimanded for other misconduct.