In the Matter of Muhammad Abdul-Warit Abdur-Rahim

Muhammad Abdul-Warit Abdur-Rahim, a Georgia lawyer, was charged with family violence battery and related offenses after an altercation with his father. Representing himself at his arraignment, he was argumentative with prosecutors, used profanity, ignored the court's instructions, and generally disrupted the proceeding. Abdur-Rahim later filed a petition asking the Supreme Court of Georgia to accept a specific punishment, a reprimand from the State Disciplinary Review Board, for violating the rule that bars lawyers from intentionally disrupting a court. He pointed to mitigating facts: he had no prior disciplinary record, sought treatment for personal problems, apologized to the judge and court staff, and cooperated fully with the State Bar. The State Bar agreed the proposed punishment was appropriate. The court accepted the petition and imposed the reprimand.

The court held that a State Disciplinary Review Board reprimand, the maximum penalty available for violating the rule against disrupting a tribunal, was appropriate given the lawyer's cooperation, remorse, treatment for personal problems, and lack of prior discipline.

The decision shows how Georgia disciplines lawyers for disrespecting courts, even when the misconduct happens during the lawyer's own personal legal trouble rather than while representing a client. It signals that isolated, mitigated misconduct can result in a lighter sanction than the maximum allowed.

Petition for voluntary discipline accepted; Review Board reprimand imposed

1. The lawyer conceded that his conduct at his arraignment violated Georgia Rule of Professional Conduct 3.5 (d), which forbids lawyers from engaging in conduct intended to disrupt a court proceeding, and the maximum punishment for that rule is a public reprimand.
2. The court weighed mitigating factors described in the petition, including that the lawyer sought treatment for personal and emotional problems, apologized to the judge and court staff, cooperated fully with the State Bar, and expressed remorse.
3. The court noted the lawyer had no prior disciplinary history and that the State Bar presented no evidence he had disrupted court proceedings on any other occasion, treating the incident as isolated.
4. Because the misconduct was isolated and mitigated, and because a Review Board reprimand is already the most severe sanction available for this rule violation, the court agreed that this specific reprimand was the appropriate discipline.

• attorney discipline
• State Bar of Georgia
• courtroom misconduct
• voluntary discipline petition