In the Matter of Tamorra A. Boyd

Tamorra A. Boyd, a Georgia lawyer, signed on as 'Of Counsel' for a California company called Olympia Law Group that promised to help homeowners avoid foreclosure by negotiating mortgage modifications. A Georgia couple paid the company thousands of dollars, but the work was never properly done, and Boyd had almost no direct contact with them. The couple complained to the State Bar, and a special master initially found Boyd in default on the Bar's complaint and recommended a six-month suspension. The Supreme Court of Georgia had already sent the case back once for a hearing on whether Boyd was properly in default. On remand, the special master again found her in default, but Boyd then negotiated a petition for voluntary discipline, offering new information about mental health struggles that clouded her judgment at the time. The Bar agreed a public reprimand was now appropriate. The court accepted that agreement, finding Boyd's misconduct was the product of negligence and naivete rather than dishonesty, and ordered a public reprimand instead of a suspension.

The court held that a public reprimand, rather than a suspension, is the appropriate discipline for Boyd's violations of the rules on client communication, fee disclosure, and misleading advertising, because her conduct stemmed from negligence and mental health struggles rather than dishonest or selfish motives, and mitigating factors outweighed the aggravating ones.

The decision shows Georgia lawyers who rent out their licenses to out-of-state companies marketing legal services can face discipline, while also showing that new evidence of mental health struggles and full restitution can significantly reduce a lawyer's punishment, affecting how future bar discipline cases are resolved.

Petition for voluntary discipline accepted; public reprimand imposed

1. The court applies the American Bar Association's Standards for Imposing Lawyer Sanctions, a framework that weighs the duty violated, the lawyer's mental state, the harm caused, and any aggravating or mitigating circumstances to set the right punishment.
2. Because Boyd's default meant the facts in the Bar's complaint were deemed admitted, the court accepted as established that she let the mortgage company use her law license to market services in Georgia without properly supervising or communicating with the clients.
3. The court found Boyd's conduct was primarily negligent rather than knowing or intentional, since new evidence showed her judgment was clouded by a misdiagnosed and later properly treated mental health condition, so the aggravating factor of dishonest or selfish motive did not apply.
4. Weighing mitigating factors, including Boyd's inexperience as a young lawyer, her full repayment of the couple's money, her expressed remorse, and evidence of her good character, against the aggravating factors of a prior disciplinary matter and initial resistance to the case, the court concluded the mitigating factors outweighed the aggravating ones.
5. Comparing this case to prior discipline cases involving similar rule violations, the court concluded a public reprimand, rather than the suspension previously recommended, matched the level of punishment given in comparable cases.

• attorney discipline
• State Bar of Georgia
• mortgage modification scam
• public reprimand
• voluntary discipline petition