In the Matter of Megan Kate Andrews

Megan Kate Andrews, a New York-licensed lawyer who had worked in Georgia government roles, applied to join the State Bar of Georgia without taking the bar exam, relying on a reciprocity rule for out-of-state lawyers. The Board of Bar Examiners denied her application, finding she had not been primarily engaged in active law practice for five of the past seven years as required. Instead of appealing that denial to the Supreme Court of Georgia within 30 days as the rules require, Andrews asked the Board to waive that deadline rule, citing limited review time, lack of a hearing, and pandemic-related court backlogs. The Supreme Court of Georgia held that it had no power to review the Board's original denial because Andrews missed the 30-day appeal window, and the Board itself has no authority to extend that deadline. The court also found the Board did not abuse its discretion in refusing to waive the rule, since Andrews had not shown good cause and had not submitted her supporting letters until after the Board's decisions were already made.

The court held it lacked jurisdiction to review the Board's denial of Andrews's admission application because she did not appeal within the required 30 days, and it affirmed the Board's separate denial of her waiver request because she failed to show good cause by clear and convincing evidence and the Board cannot alter the court's own jurisdictional deadlines.

The decision reminds lawyers seeking Georgia bar admission that they must strictly meet the 30-day appeal deadline after a Board denial, since neither the Board nor late-submitted evidence can revive a missed appeal, protecting the reliability of the bar admission process.

Appeal dismissed in part and decision affirmed in part

1. Under Part F, Section 8 of the Rules Governing Admission to the Practice of Law, an applicant denied admission must file a notice of appeal with the bar admissions office and the Clerk of the Supreme Court within 30 days of the Board's final determination.
2. Andrews did not file an appeal within that 30-day window after the Board denied her application on March 23, 2021; instead she sent the Board a request to waive the deadline, which does not count as a timely appeal.
3. Because the Board has no authority to extend or stay the court's own jurisdictional deadlines, Andrews's failure to appeal within 30 days left the Supreme Court of Georgia without jurisdiction to review the merits of the original denial, so that part of her appeal was dismissed.
4. On the separate waiver request, the Board may excuse compliance with its rules only for good cause shown by clear and convincing evidence, and the applicant bears the burden of proving that good cause; the court reviews the Board's refusal to waive a rule only for abuse of discretion.
5. The court found the record supported the Board's conclusion that Andrews had not met that high burden, noting she offered no authority requiring a hearing and that supporting letters from employers were written only after the Board's decisions and were never part of the record before the Board.
6. Because the Board's denial of the waiver request was supported by the record and no abuse of discretion was shown, the court affirmed that decision.

• bar admission
• reciprocity admission
• appeal deadline
• Board of Bar Examiners
• waiver request