In the Matter of Michael Anthony Eddings

Michael Anthony Eddings, a Georgia lawyer, represented a man charged with murder in Muscogee County. Eddings recorded an interview with a witness even though the witness was represented by another attorney, Stacey Jackson. At the witness's later murder trial, Eddings testified under oath that he never got Jackson's permission to do the interview. The next day, Eddings sent an email claiming he had actually forgotten that Jackson had given consent during a June 2017 phone call, and he backed up this new story with sworn affidavits from his wife and two relatives of his client. The State Bar charged Eddings with lying to courts and to Bar investigators. A special master held a hearing, believed Eddings's original trial testimony and Jackson's denial of consent, and found Eddings's later story and supporting witnesses not credible. The Bar's Review Board agreed. The Supreme Court of Georgia reviewed the record, deferred to those credibility findings, and ordered Eddings disbarred, noting this was his third disciplinary infraction.

The court held that clear and convincing evidence, based on the special master's credibility findings, showed Eddings violated rules against contacting a represented witness without consent and against making false statements to courts and Bar investigators, and that disbarment was the appropriate sanction given his prior disciplinary history.

The ruling reinforces that Georgia lawyers cannot contact represented witnesses without permission and that lying to courts or Bar investigators, especially repeatedly, can end a legal career. It also shows how heavily the court relies on trial-level credibility findings in discipline cases.

Disbarred

1. The court explained it defers to a special master's factual and credibility findings unless they are clearly erroneous, since the special master personally observes witnesses testify and is best positioned to judge who is telling the truth.
2. Applying that deference, the court accepted the special master's finding that Eddings's original sworn trial testimony (that he lacked Jackson's consent to interview the witness) was truthful, and that his later email and supporting affidavits recanting that testimony were fabricated.
3. Based on those facts, the court agreed Eddings violated the rule against contacting a person represented by another lawyer without that lawyer's consent (Rule 4.2), because Eddings knowingly interviewed the witness without Jackson's permission.
4. The court also agreed Eddings violated rules against dishonesty (Rules 3.3, 4.1, 8.1(a), and 8.4(a)(4)) by later lying to judges, a prosecutor, and Bar investigators, and by recruiting his wife and two relatives to give false sworn statements backing his story.
5. Using the American Bar Association's sanctions framework, which weighs the duty violated, the lawyer's mental state, and aggravating or mitigating factors, the court found almost every aggravating factor present, including two prior disciplinary infractions, dishonest motive, and refusal to admit wrongdoing, with no mitigating factors.
6. Because this was Eddings's third disciplinary infraction, the court applied a Bar rule making a third violation grounds for suspension or disbarment, and concluded that disbarment, not a lesser sanction, was required.

• attorney disbarment
• State Bar of Georgia
• false statements to court
• represented witness contact
• Rule 4.2 violation