In the Matter of Vi Bui

Vi Bui, a Georgia attorney admitted to the State Bar in 2013, pleaded guilty to a federal felony count of corruptly obstructing the administration of the Internal Revenue Code. After entering that plea, Bui had already been suspended from practicing law by the Supreme Court of Georgia pending resolution of his criminal case. Once he was sentenced to 16 months in prison followed by a year of supervised release, Bui asked the court to accept the voluntary surrender of his law license rather than go through further disciplinary proceedings. The State Bar supported his request. The Supreme Court of Georgia reviewed the record, found that Bui's felony conviction violated the rule making felony convictions professional misconduct, and agreed to accept his voluntary surrender of license. That surrender counts the same as disbarment, and his name is removed from the rolls of Georgia lawyers.

The court held that Bui's admitted felony conviction violated Rule 8.4(a)(2) of the Georgia Rules of Professional Conduct, which makes any felony conviction professional misconduct, and that voluntary surrender of his license was an appropriate sanction, treated the same as disbarment.

The decision removes a convicted felon from the rolls of licensed Georgia attorneys, protecting clients and the legal system from someone unable to practice due to imprisonment. It also shows how Georgia handles lawyers convicted of serious federal crimes, treating voluntary surrender as equivalent to disbarment.

Voluntary surrender of license accepted, tantamount to disbarment

1. The court noted that Bui had previously been suspended from practicing law pending resolution of his federal criminal case, after pleading guilty to corruptly obstructing the administration of the Internal Revenue Code, a felony under federal law.
2. After Bui was sentenced to 16 months in prison plus a year of supervised release, he filed a petition to voluntarily surrender his law license, admitting his conduct violated Rule 8.4(a)(2), the Georgia rule that makes any felony conviction a violation of professional conduct rules.
3. The State Bar of Georgia filed a response supporting acceptance of the petition.
4. The court looked to its own prior decisions, In the Matter of Huber and In the Matter of Hardwick, where it had accepted similar voluntary surrenders of license from attorneys whose felony convictions violated the same rule, and found accepting Bui's petition consistent with that precedent.
5. Because the maximum sanction for violating Rule 8.4(a)(2) is disbarment, and Bui's admitted felony conviction satisfied that rule, the court concluded that accepting his voluntary surrender, which is treated as equivalent to disbarment, was an appropriate sanction.

• attorney discipline
• voluntary surrender of license
• felony conviction
• State Bar of Georgia
• disbarment