In the Matter of Andrew David Taylor
Filed April 6, 2020 · Docket S20Y0815 · 841 S.E.2d 661
The Supreme Court of Georgia disbarred an attorney reciprocally after he was disbarred in Nevada for misappropriating more than a million dollars in client funds and misleading Nevada bar officials.
In plain language
Andrew David Taylor was a Georgia lawyer, admitted to practice in Georgia since 2009 and in Nevada since 2004. The Supreme Court of Nevada disbarred him after finding he misappropriated more than a million dollars of clients' money, mixed his own funds with client funds, and opened multiple law firms with separate accounts to hide what he was doing from the Nevada bar and his clients. He also arranged loans on clients' behalf without telling them, spent the money himself, and lied to Nevada bar investigators. Because Georgia treats disbarment in another state as grounds for the same discipline here, the State Bar of Georgia served Taylor with notice of a reciprocal discipline proceeding. He never responded. The State Disciplinary Review Board reviewed Nevada's rules and Georgia's rules and found them similar enough to recommend disbarment. The Supreme Court of Georgia agreed and ordered Taylor's name removed from the rolls of lawyers allowed to practice in the state.
What the court decided
Where a lawyer has been disbarred in another state for serious misconduct and Georgia's disciplinary rules impose similar sanctions for similar conduct, reciprocal disbarment in Georgia is appropriate, especially when the lawyer does not respond to the disciplinary notice.
Why it matters
The decision protects Georgia clients by removing a lawyer already found to have stolen client money and deceived bar regulators in another state. It also shows how Georgia's reciprocal discipline process quickly mirrors serious sanctions imposed by sister states' bars.
Outcome
Disbarred
How the court got there
- The case arose under Georgia's reciprocal discipline rule (Georgia Rules of Professional Conduct, Rule 9.4 (b)), which allows Georgia to impose discipline mirroring another state's action against the same lawyer.
- The State Bar properly served Taylor with notice of the reciprocal proceeding under Bar Rule 4-203.1, but he failed to acknowledge service or file any response or objection.
- The Nevada Supreme Court had already found that Taylor misappropriated over a million dollars of client funds, commingled personal and client money, misled clients and regulators through multiple law firms, and lied to Nevada bar investigators.
- The State Disciplinary Review Board compared Nevada's disciplinary rules and procedures to Georgia's and concluded disbarment was a substantially similar and appropriate sanction under Rule 9.4 (b)(3)(i)-(vi).
- Having reviewed the record, the Supreme Court of Georgia agreed with the Review Board's recommendation and ordered Taylor removed from the rolls of Georgia lawyers.
Topics
- attorney disbarment
- reciprocal discipline
- misappropriation of client funds
- State Bar of Georgia
- Nevada disbarment