In the Matter of Christopher Michael

Christopher Michael Howlette was admitted to the Georgia Bar in 1998 and worked as a prosecutor and then a lawyer in private practice. In 2008 he voluntarily gave up his law license, which counted the same as being disbarred, after he was set to plead guilty to selling cocaine, MDMA, and ketamine. He completed probation under Georgia's First Offender Act and was later discharged without a formal conviction. Years later, Howlette applied to be certified as fit to practice law again, saying he had not used drugs since 2007 and had rebuilt his life through counseling, church involvement, community service, and steady work as a paralegal. The Board to Determine Fitness of Bar Applicants investigated, found no pending complaints against him, confirmed he passed a drug test, and recommended readmission. The Supreme Court of Georgia reviewed the full record and had to decide whether Howlette proved his rehabilitation by clear and convincing evidence. The court agreed he did and granted his application for certification of fitness.

The court held that Howlette met his burden of proving, by clear and convincing evidence, that he has been rehabilitated since surrendering his law license, based on his sustained sobriety, community service, counseling, and clean record, and granted him certification of fitness to practice law pending completion of remaining bar admission requirements.

The decision lets a disbarred Georgia attorney work toward returning to legal practice after addiction and criminal conduct, once he passes the bar exam and meets other admission requirements. It illustrates the path and evidentiary standard, clear and convincing proof of rehabilitation, that other lawyers seeking readmission in Georgia must also satisfy.

Certification of fitness for readmission granted

1. The court applied the rehabilitation standard from In re Cason, which requires a bar applicant to prove by clear and convincing evidence that he has restored his reputation and reestablished himself as a useful, constructive member of society, including through positive action.
2. The Fitness Board's investigation found no pending grievances against Howlette, no restitution owed to the Client Security Fund, and no negative responses from bar associations, judges, or the public despite notice being given.
3. Howlette submitted a negative drug test, testified at an informal conference taking full responsibility for his past conduct, and provided a Statement of Rehabilitation describing years of sobriety, counseling, church involvement, and volunteer work.
4. Letters from his employer, a supervising attorney, and a life coach corroborated his personal growth, work ethic, and community involvement since surrendering his license in 2008.
5. Based on this record, the court concluded that Howlette carried his burden of demonstrating rehabilitation and satisfied the requirements for certification of fitness under Part A, Section 10 of the Bar Admission Rules.

• bar readmission
• certification of fitness
• attorney disbarment
• drug addiction recovery
• voluntary license surrender