In the Matter of Chadrick A. Mance

Chadrick A. Mance, a Georgia lawyer since 2013, filed a motion asking a trial court to delay ruling on a summary judgment motion while discovery issues got sorted out. He attached a 'proposed order' as an exhibit, but the document included a cut-and-pasted copy of the judge's actual signature and language suggesting the judge had made revisions, even though the judge had never seen or signed it. Opposing counsel noticed the signature and asked whether the judge had actually signed anything; Mance quickly clarified that he had not. The trial court held a hearing, and Mance apologized and accepted responsibility. Mance later asked the Supreme Court of Georgia to impose only a public reprimand for violating the rule requiring competent representation, rather than a harsher penalty. The State Bar agreed that a reprimand was appropriate and did not pursue a separate dishonesty charge. The court reviewed the case and agreed, ordering a public reprimand.

The court held that submitting a proposed order bearing a cut-and-pasted copy of the judge's actual signature, without the judge's knowledge or approval, violated the duty of competent representation under Rule 1.1, and that a public reprimand was the appropriate sanction given the lack of client harm, prompt correction, and mitigating factors.

The decision shows Georgia lawyers can face discipline for shortcuts like fabricating a judge's apparent signature on a proposed order, even without dishonest intent, while also showing that quick correction, apology, and lack of harm to a client can limit the punishment to a reprimand instead of suspension.

Petition for voluntary discipline accepted; public reprimand imposed

1. The court looked to the ABA Standards for Imposing Lawyer Sanctions, a framework courts use to pick an appropriate discipline level based on the duty violated, the lawyer's mental state, actual or potential harm, and aggravating or mitigating factors.
2. Because the attorney failed to understand proper procedure by embedding a judge's signature image on an unauthorized proposed order, and this caused only potential rather than actual injury to his client, the court found ABA Standard 4.53(a), which calls for a reprimand in such circumstances, to be the fitting benchmark.
3. The court weighed mitigating factors such as the attorney's prompt correction of the confusion, his cooperation and honesty with both the trial court and the State Bar, his good reputation, and his remorse, against an aggravating factor of a prior confidential admonition for a similar competence violation.
4. Comparing this case to prior discipline cases, the court distinguished it from harsher suspension or forgery cases where lawyers actually submitted forged signatures as final court orders or tried to deceive a judge or client, finding those situations more serious than Mance's mistaken attempt at drafting efficiency.
5. Balancing these factors, the court concluded that a public reprimand, rather than suspension or disbarment, adequately served the purposes of discipline: punishing the offender, deterring others, and reassuring the public that the courts enforce professional ethics.

• attorney discipline
• public reprimand
• judge's signature
• proposed order
• State Bar of Georgia