In the Matter of Gege Okezuandue Odion

Gege Okezuandue Odion, an optometrist who graduated from law school, applied to the Board to Determine Fitness of Bar Applicants for the certificate needed to practice law in Georgia. His application initially listed only a handful of lawsuits he had filed himself, but the Board found he had left out many more. Even after the Board flagged the problem and gave him chances to amend his application, he added dozens more lawsuits but still left out about 20 additional matters. A Special Master appointed by the Supreme Court of Georgia held a hearing, found Odion's explanations for the omissions inconsistent and unconvincing, and concluded he had not shown the character and fitness required of Bar applicants. The Board adopted those findings and denied his application. Odion appealed to the Supreme Court of Georgia, which reviewed the record and agreed that the denial was justified.

The court held that an applicant's repeated failure to disclose numerous lawsuits, even after being given multiple opportunities to amend and supplement his application, supports a finding that he lacks the diligence, judgment, and candor required for bar admission, so the Board properly denied his fitness certification.

The decision reinforces that Georgia bar applicants bear a strict, ongoing duty to fully disclose litigation history, and that repeated omissions, even after being given chances to correct them, can permanently bar someone from becoming a lawyer regardless of other qualifications like a law degree.

Denial of certification affirmed

1. The court explained that throughout the fitness application process, the burden rests on the applicant to prove his own fitness to practice law, not on the Board to prove he lacks it.
2. It noted that false, misleading, or evasive answers on bar application questionnaires can by themselves support a finding that an applicant lacks the required character and fitness.
3. Applying the 'any evidence' standard, meaning the Board's decision will be upheld if the record contains any support for it, the court reviewed the Special Master's findings that Odion left out roughly 20 lawsuits even after being specifically asked about them.
4. The court found Odion's justifications, such as believing only recent lawsuits needed disclosure or forgetting a case that stalled in discovery, were not supported by the record or were inadequate.
5. Because Odion never fully accepted responsibility for the omissions even when directly confronted, the court concluded this pattern showed a lack of diligence and judgment, and possibly a lack of candor, justifying denial of his application.

• bar admission
• fitness to practice law
• attorney character review
• undisclosed lawsuits