In the Matter of Christopher Ryan Breault
Filed March 4, 2025 · Docket S25Y0220 · 321 Ga. 338
The Supreme Court of Georgia suspended attorney Christopher Ryan Breault for six months after finding he repeatedly disclosed his clients' confidential information and refused to stop representing them after being fired.
In plain language
Christopher Breault was hired as lead trial counsel for a South Carolina couple pursuing a personal injury case after a truck accident. During the litigation, Breault publicly disclosed confidential information about the clients' case in two separate court filings, mishandled scheduling a key medical deposition, and, after the clients fired him, continued communicating with them and giving them advice instead of promptly withdrawing. This was the second time the case reached the Supreme Court of Georgia. The first time, the court sent it back because the Special Master had not properly analyzed the misconduct under the American Bar Association's sanctions framework. A new Special Master then recommended a one-year suspension, and Breault objected, arguing the rules were misapplied and he was being punished for asserting his rights. The court rejected Breault's objections, agreed he violated multiple ethics rules, and imposed a six-month suspension from practicing law.
What the court decided
The court held that Breault violated Georgia's competence, confidentiality, withdrawal, and tribunal-disruption rules, that no exception excused his disclosures of client information, and that a six-month suspension appropriately balances the seriousness of his misconduct against comparable disciplinary cases.
Why it matters
The decision shows Georgia lawyers can face serious suspension, not just a reprimand, for disclosing client secrets and ignoring termination instructions. It signals to attorneys statewide that mishandling confidentiality and withdrawal duties carries real professional consequences.
Outcome
Six-month suspension imposed
How the court got there
- The court applied the American Bar Association's sanctions framework, which requires weighing the duty violated, the lawyer's mental state, the injury caused, and any aggravating or mitigating factors before choosing a punishment.
- It found Breault knowingly and intentionally disclosed his clients' confidential information twice in public court filings, failed to withdraw promptly after being fired, and mishandled a key deposition, breaching duties owed to clients and to the legal system.
- The court rejected Breault's claim that two exceptions to the confidentiality rule (Rule 1.6(a)) applied, finding the clients never authorized the disclosures and the disclosures were not reasonably necessary to defend himself against accusations.
- Weighing seven aggravating factors, including a pattern of misconduct and refusal to acknowledge wrongdoing, against only two mitigating factors, the court concluded a sanction more severe than a public reprimand was warranted.
- Comparing Breault's conduct to a prior case where a lawyer received only a public reprimand for a similar confidentiality violation and another where disbarment followed far more extensive misconduct, the court placed Breault's case between the two and settled on a six-month suspension.
From the opinion
“sufficient to penalize the offender for his wrongdoing, deter other attorneys from engaging in similar behavior, and inform the general public that the courts will maintain the ethics of the profession.”
Topics
- attorney suspension
- client confidentiality
- State Bar of Georgia
- withdrawal from representation
- ethics violations