Georgia Commons

Supreme Court of Georgia · bar discipline

In the Matter of Majd M. Ghanayem

Filed April 19, 2021 · Docket S21Y0705 · 311 Ga. 366

The Supreme Court of Georgia disbarred a lawyer after Texas disciplinary authorities found he forged a judge's signature on a fake court order to hide his neglect of a client's parental rights case.

In plain language

A Texas woman hired attorney Majd M. Ghanayem in 2015 to file a legal action to terminate the parental rights of her son's biological father. Instead of promptly handling the matter, Ghanayem let it sit for nearly two years, failed to keep his client informed, and then lied to her about the status of the case. He went further and gave her a fraudulent court order with a forged judge's signature to cover up his neglect. A Texas disciplinary panel disbarred him in December 2019 after a hearing at which he was present. Because Georgia's State Bar Rules allow reciprocal discipline based on out-of-state sanctions, the Georgia State Disciplinary Review Board reviewed the Texas findings and Georgia's own rules and concluded disbarment was the right punishment here too. Ghanayem did not object, and the Supreme Court of Georgia agreed, removing him from the rolls of lawyers allowed to practice in Georgia.

What the court decided

The court held that disbarment, the same sanction imposed by Texas disciplinary authorities, is the appropriate reciprocal discipline in Georgia because the underlying misconduct, including forging a judge's signature, would similarly warrant disbarment under Georgia's own disciplinary rules.

Why it matters

Georgians who hired or might have hired Ghanayem, who was licensed in both Texas and Georgia, are protected because he can no longer practice law in this state. The case also shows how Georgia enforces discipline imposed by other states' bar authorities against lawyers licensed here.

Outcome

Disbarred

How the court got there

  1. Under Georgia's reciprocal discipline rule (Rule 9.4 of the Georgia Rules of Professional Conduct), a lawyer disciplined by another state's bar can face equivalent discipline in Georgia unless there is a valid basis for imposing something different.
  2. The Texas Evidentiary Panel found that Ghanayem neglected his client's case for nearly two years, failed to communicate with her, and engaged in dishonest conduct by providing her a fraudulent court order with a forged judge's signature.
  3. Georgia's State Disciplinary Review Board compared the Texas disciplinary rules and procedures to Georgia's own rules and concluded that the same misconduct would also warrant disbarment under Georgia law, finding no basis for a lesser sanction.
  4. Because Ghanayem did not object to the Review Board's recommendation and the record supported it, the Supreme Court of Georgia agreed that disbarment was the appropriate reciprocal sanction.

From the opinion

Ghanayem engaged in conduct involving dishonesty, fraud, deceit or misrepresentation by misrepresenting the status of the matter to his client and by providing her with a fraudulent order and forged signature of a judge.

Per Curiam · Describing the dishonest conduct underlying the Texas disbarment that Georgia mirrored.

Topics

  • attorney disbarment
  • reciprocal discipline
  • forged court order
  • State Bar of Georgia
  • Texas Bar

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In the Matter of Majd M. Ghanayem | Georgia Commons