In the Matter of Clifford E. Hardwick, IV

Clifford Hardwick, an attorney since 1976, had previously represented Joseph Carswell in a criminal case involving elder financial exploitation. After that case, Hardwick let Carswell route money from third parties through Hardwick's personal and business bank accounts, taking a small commission along the way. Fourteen victims, including an elderly woman, wired a total of about $655,000 to Hardwick's accounts after being promised safe investment opportunities; they never got their money or any returns back. When victims filed grievances with the State Bar, Hardwick wrote letters denying any knowledge of the transactions, even though he had already received and disbursed the funds and had emailed Carswell about a 'botched transaction.' A Special Master and the State Disciplinary Review Board both concluded Hardwick violated several ethics rules, including lying to the Bar, and recommended disbarment. Hardwick challenged those findings, but the Supreme Court of Georgia agreed that his false statements to the Bar, combined with a long history of prior discipline, made disbarment the only appropriate outcome.

The court held that Hardwick knowingly made false statements to State Bar disciplinary investigators, violating Rule 8.1(a), and that this violation, combined with his extensive disciplinary history including prior suspensions and admonitions, warranted disbarment under Bar Rule 4-103's provision for repeat offenders.

The ruling ends Hardwick's ability to practice law in Georgia and signals that the court treats lying to Bar investigators as a serious offense on its own, especially for repeat offenders, reinforcing protections for the public and reassuring clients that dishonest lawyers face permanent removal from practice.

Disbarred

1. The court gave deference to the Special Master's credibility findings, explaining that special masters are best positioned to judge witness credibility and their determinations stand unless clearly erroneous, so it accepted the finding that Hardwick lied to the Bar.
2. The record showed Hardwick told the State Bar he had 'no knowledge' of victims' transactions even though he had already received and disbursed their funds and had emailed his former client about a 'botched transaction,' supporting the finding that his denials were knowingly false.
3. The court explained that a single violation of Rule 8.1(a), which bars knowingly false statements to Bar disciplinary authorities, already carries disbarment as its maximum penalty and that the court has little tolerance for lawyers who lie during disciplinary proceedings.
4. The court applied Bar Rule 4-103, which allows a finding of a third or subsequent disciplinary infraction to itself serve as grounds for suspension or disbarment, noting Hardwick's decades-long pattern of admonitions and suspensions for similar dishonesty.
5. Because the Rule 8.1(a) violation and Hardwick's disciplinary history alone justified disbarment, the court declined to separately resolve his remaining challenges to findings that he violated trust-account and dishonest-conduct rules.

• attorney disbarment
• State Bar of Georgia
• false statements to investigators
• elder fraud scheme
• repeat disciplinary offenses