In the Matter of Christopher Ryan Breault

Christopher Ryan Breault, a Georgia lawyer, represented a couple in a personal injury case in federal court. A federal judge disciplined him after finding he disclosed confidential client information twice while defending himself against motions to revoke his court admission, and after he failed to promptly withdraw when his clients fired him. The federal court referred the matter to the State Bar of Georgia, which charged him with violating several Georgia ethics rules. A special master and a Review Board recommended Breault be suspended for one month. But the Supreme Court of Georgia found that the special master never walked through the full analysis lawyers' groups use to decide punishment: what duty was broken, what the lawyer's mental state was, and what harm resulted, before weighing aggravating and mitigating factors. Because that analysis was missing, the court rejected the one-month suspension recommendation and sent the case back for a complete redo, without deciding yet whether Breault actually violated the rules or what punishment, if any, is appropriate.

The court held that special masters must analyze an attorney's violated duties, mental state, and actual or potential injury to clients using the ABA Standards framework before recommending a sanction, and because that analysis was missing here, the recommended one-month suspension could not yet be evaluated.

The ruling shapes how the State Bar disciplines lawyers going forward, requiring special masters to methodically analyze duty, mental state, and injury before recommending punishment. It also means Breault's discipline remains unresolved, and his clients, opposing counsel, and the broader bar await a final sanction.

Recommendation rejected and matter remanded with direction

1. The court explained that the ABA Standards for Imposing Lawyer Sanctions, a widely used guide for deciding attorney punishment, are not binding but are 'generally instructive' and require considering the duty violated, the lawyer's mental state, actual or potential injury, and aggravating or mitigating factors.
2. The court found the special master skipped straight to aggravating and mitigating factors without first analyzing which professional duties (to clients, the legal system, or the profession) Breault's alleged rule violations implicated.
3. The court found no explicit findings on Breault's mental state, meaning whether he acted with intent, knowledge, or mere negligence, even though the special master noted his actions were 'clouded by anger.'
4. The court found the special master made scattered comments about lack of financial harm to the clients but never explicitly tied those comments to a structured analysis of actual or potential injury from the confidentiality violations.
5. Because a full ABA Standards analysis was missing, the court concluded it could not yet evaluate whether a one-month suspension, or any particular sanction, was appropriate, and that the case needed to go back for that analysis before any sanction is decided.

• attorney discipline
• State Bar of Georgia
• confidential client information
• pro hac vice revocation
• ABA Standards