In the Matter of Sawand Palmer

Sawand Palmer, a Georgia lawyer since 2010, was indefinitely suspended by the Supreme Court of Georgia in April 2018 for failing to complete required continuing legal education. Despite that suspension, she filed a notice of appearance and represented a client at two court hearings in one county, and after being told by a judge that she was suspended, she appeared at a hearing in a different county days later. Palmer admitted this violated the rule barring lawyers from practicing law in violation of the profession's regulations, and she filed a petition asking the court to accept discipline. A special master recommended a suspension of three to twelve months with conditions on reinstatement, citing mitigating factors like Palmer's cooperation, remorse, mental health struggles, and financial hardship. The Supreme Court of Georgia accepted her petition and imposed a three-month suspension with specific conditions she must meet before seeking reinstatement.

A lawyer who practiced law after being suspended for noncompliance with continuing legal education requirements violated Rule 5.5(a) against practicing law in violation of professional regulations, and given the mitigating circumstances, the appropriate discipline is a three-month suspension with conditions on reinstatement rather than a harsher sanction like disbarment.

The decision shows Georgia's system for disciplining lawyers who practice while suspended, and signals that mental health treatment, cooperation, and remorse can meaningfully reduce sanctions. Clients and courts rely on knowing which attorneys are authorized to practice.

Petition for voluntary discipline accepted; three-month suspension with conditions imposed

1. The court reviewed the special master's findings that Palmer, while under an indefinite suspension for failing continuing legal education requirements, entered a notice of appearance and represented a client at multiple hearings, including one after she was told directly by a judge that she was suspended.
2. This conduct amounted to an admitted violation of Rule 5.5(a) of the Georgia Rules of Professional Conduct, which bars a lawyer from practicing law in a jurisdiction in violation of that jurisdiction's regulation of the legal profession, a violation that can carry disbarment as the maximum penalty.
3. The court weighed aggravating factors, limited here to Palmer's substantial experience practicing law, against several mitigating factors including her cooperation with the Bar, full disclosure, remorse, ongoing mental health counseling, financial hardship, and having since corrected her continuing education compliance.
4. Comparing this case to a prior disciplinary decision involving similar rule violations and mitigating circumstances such as emotional distress, the court concluded that a three-month suspension, rather than a longer suspension or disbarment, was the appropriate sanction.
5. The court adopted the specific reinstatement conditions suggested by Palmer, supported by the Bar, and recommended by the special master, including medication compliance, therapy, an impaired professional's program, and continuing legal education, as prerequisites to seeking reinstatement.

• attorney discipline
• practicing while suspended
• State Bar of Georgia
• suspension conditions
• continuing legal education