In the Matter of Stephanie Dianne Woodard
Filed May 28, 2025 · Docket S25Y0649 · 321 Ga. 681
The Supreme Court of Georgia rejected a former Hall County solicitor-general's request for only a public reprimand over a misdemeanor conviction for misusing public funds, finding the misconduct warranted a suspension instead.
In plain language
Stephanie Dianne Woodard served as Solicitor-General of the Hall County State Court for 15 years. She admitted receiving 11 improper reimbursements from a state prosecutors' council and Hall County between 2018 and 2022, totaling over $2,200, and was indicted on 24 felony counts. She resolved the case by pleading guilty to one misdemeanor count under Georgia's public officer misconduct statute, receiving First Offender treatment and eventually a clean record after paying restitution. Before the State Bar filed formal charges, Woodard asked the Supreme Court of Georgia to accept a public reprimand, citing several mitigating factors, and the State Bar agreed that a reprimand was appropriate even though it said a short suspension was the normal starting point. The court disagreed with both of them, comparing her case to prior cases involving public officials misusing government funds that resulted in six-month and eighteen-month suspensions, and rejected her petition without prejudice so she can file a new one.
What the court decided
The court held that a public reprimand is insufficient discipline for a lawyer-public official convicted of a misdemeanor involving moral turpitude for repeatedly misusing government funds, because such misconduct is comparable to cases warranting six-month to eighteen-month suspensions, not a mere reprimand.
Why it matters
The ruling signals that Georgia lawyers who are also public officials face suspension, not just a reprimand, for repeated misuse of government money, reinforcing that the court weighs public trust heavily when disciplining officials who abuse their positions.
Outcome
Petition for voluntary discipline rejected without prejudice
How the court got there
- The court noted that a violation of Rule 8.4(a)(4), which bars dishonesty, fraud, deceit, or misrepresentation, is one of the most serious violations a lawyer can face, and that Rule 8.4(a)(3) violations, covering conviction of a misdemeanor involving moral turpitude, typically call for suspension or disbarment depending on the circumstances.
- Because Woodard held public office as Solicitor-General, the court explained it must also weigh the public's confidence in the legal profession when a lawyer-official abuses a position of trust, not just the individual violation.
- The court distinguished the two cases Woodard cited for a public reprimand, explaining neither involved a misdemeanor conviction for moral turpitude nor repeated misuse of government funds like hers.
- Instead, the court compared her conduct to prior cases involving public officials who misused government money, one resulting in a six-month suspension for an assistant district attorney who took money he was not entitled to, and another resulting in an eighteen-month suspension for overbilling a public defense program.
- Concluding her case more closely resembled those suspension cases than the reprimand cases she cited, the court determined that a public reprimand was too lenient a sanction for her admitted misconduct.
From the opinion
“a violation of Rule 8.4 (a) (4) is among the most serious violations with which a lawyer can be charged.”
Topics
- state bar discipline
- public official misconduct
- misuse of government funds
- voluntary discipline petition
- Hall County solicitor-general