In the Matter of Dell Jackson

Dell Jackson, a Georgia lawyer admitted to the State Bar in 1993, represented a client on his direct appeal of a criminal conviction to the Supreme Court of Georgia. According to the facts admitted through her default, Jackson refused to give her client his trial transcript when he asked for it, would not discuss with him what issues to raise on appeal, never told him how the appeal was going, and never sent him a copy of the court's opinion once it came out. She then stopped communicating with him entirely. The State Bar filed a formal complaint against Jackson, but she never responded, so the Bar served her by publication and eventually won a default, meaning the allegations were treated as true. A Special Master reviewed the case, found Jackson had violated rules requiring diligence, communication, and following client decisions, and recommended disbarment. The Supreme Court of Georgia agreed and ordered her removed from the rolls of Georgia lawyers.

The court held that disbarment is the appropriate sanction for an attorney who abandoned a criminal appeal client by refusing to communicate, withholding the trial transcript, and failing to update him on his case, causing potential serious injury including loss of habeas remedies.

The ruling protects clients, especially those without legal training, by holding lawyers accountable when they abandon appeals and cut off communication. It also signals to the legal community that ignoring State Bar disciplinary proceedings will not soften the resulting punishment.

Disbarred

1. The Special Master applied the American Bar Association Standards for Imposing Lawyer Sanctions, a framework courts use to weigh the duty violated, the lawyer's mental state, the harm caused, and any aggravating or mitigating factors.
2. Because Jackson's default meant the formal complaint's factual allegations and rule violations were treated as true, the court found she violated Georgia's rules requiring lawyers to follow client decisions, act with reasonable diligence, and keep clients informed.
3. The court weighed aggravating factors, including that Jackson committed multiple offenses against this one client, had substantial experience as a lawyer since 1993, and took advantage of a vulnerable client who had no legal training and depended on her.
4. The court balanced this against the sole mitigating factor, that Jackson had no prior disciplinary history, but found it did not outweigh the seriousness of abandoning the client, which risked foreclosing his ability to file a timely habeas corpus petition, a legal challenge to the validity of his imprisonment.
5. Relying on prior Georgia disciplinary cases involving similar abandonment and non-participation in the disciplinary process, the court concluded disbarment was the sanction consistent with its precedent.

• attorney disbarment
• State Bar of Georgia
• client abandonment
• default judgment
• criminal appeal representation