In the Matter of Sanjay Patel

Sanjay Patel, a lawyer admitted to the Georgia Bar in 2004, represented a lender in a real estate refinancing deal. The lender wired nearly $470,000 into Patel's attorney escrow account so he could pay off the borrower's existing mortgages. Patel failed to pay off the mortgages, failed to account for the money, and stole at least $235,565.62 of it. When the State Bar filed a formal complaint, Patel answered but then refused to respond to discovery requests or comply with two court orders, so the Special Master struck his answer and deemed the Bar's allegations admitted. After a hearing, the Special Master recommended disbarment. The Supreme Court of Georgia reviewed the record, agreed that disbarment was warranted, and ordered Patel removed from the rolls of Georgia lawyers, with no readmission unless he fully repays the stolen money.

A lawyer who steals escrowed client funds and violates the rule requiring prompt delivery and accounting of client property, Rule 1.15(I)(c), commits an intentional breach of a core professional duty causing serious injury, warranting disbarment as the presumptive sanction.

The ruling removes a lawyer who stole client escrow funds from practicing law in Georgia and signals that theft from a trust account brings automatic disbarment, reassuring clients and lenders who rely on attorneys to safeguard real estate closing funds.

Disbarred

1. Because Patel ignored discovery orders, the Special Master struck his answer and deemed the Bar's factual allegations admitted, establishing that Patel stole at least $235,565.62 from escrow funds meant to pay off a borrower's mortgages.
2. The court looked to the ABA Standards for Imposing Lawyer Discipline, a national guide courts use to match misconduct to an appropriate sanction, and found Patel violated the duty lawyers owe to protect client and third-party property held in trust.
3. Applying those standards, the court found Patel acted intentionally in stealing the funds and that his theft caused actual serious injury to the borrower and damaged the legal profession's reputation, making disbarment the presumptive sanction under ABA Standard 7.1.
4. The court weighed aggravating factors, including a prior 2014 disciplinary reprimand for similar real estate misconduct, a dishonest motive, substantial legal experience, and indifference to repaying the stolen money, and found no mitigating circumstances since Patel never linked his claimed substance abuse to his misconduct.
5. Comparing this case to prior disbarments for similar real estate escrow theft and failure to cooperate with disciplinary authorities, the court concluded disbarment matched its precedent and ordered that Patel not be readmitted without making full restitution.

• attorney disbarment
• escrow funds theft
• State Bar of Georgia
• real estate closing
• trust account violation