--- title: In the Matter of Muhammad Abdul-Warit Abdur-Rahim collection: opinions id: S20Y0209/10367530 cite_as: In the Matter of Muhammad Abdul-Warit Abdur-Rahim, 308 Ga. 485 (2020) canonical_url: https://georgiacommons.org/opinions/S20Y0209/10367530 md_url: https://georgiacommons.org/opinions/S20Y0209/10367530.md text_url: https://georgiacommons.org/opinions/S20Y0209/10367530/text source_url: https://www.courtlistener.com/opinion/10367530/in-the-matter-of-muhammad-abdul-warit-abdur-rahim/ date: 2020-04-06 status: published corpus_version: opinions-2026-09-14 license: Public record of the Supreme Court of Georgia, via CourtListener and the court's own website; see about.md publisher: Georgia Commons, an independent project of Georgia Civic Data. Not the State of Georgia. Not legal advice. up: https://georgiacommons.org/opinions/2020.md previous: https://georgiacommons.org/opinions/S20A0273.md next: https://georgiacommons.org/opinions/S19Y1450.md index: https://georgiacommons.org/opinions/index.md omitted: opinion extras omitted_chars: 1531 omitted_url: https://georgiacommons.org/opinions/S20Y0209/10367530.md?full=1 docket: S20Y0209 citation: 308 Ga. 485 court: Supreme Court of Georgia case_type: bar discipline authoring_justice: Per Curiam disposition: Petition for voluntary discipline accepted; Review Board reprimand imposed vote: Melton, C. J., Nahmias, P. J. and Blackwell, Boggs, Peterson, Warren, Bethel, and Ellington, JJ., concur word_count: 545 date_filed_source: courtlistener citations: - 841 S.E.2d 666 record_source: courtlistener legal_areas: - professional discipline upstream_id: "10367530" summaries_model: claude-sonnet-5 --- # In the Matter of Muhammad Abdul-Warit Abdur-Rahim Supreme Court of Georgia, docket S20Y0209, filed 2020-04-06, 308 Ga. 485. ## Opinion 308 Ga. 485 FINAL COPY S20Y0209. IN THE MATTER OF MUHAMMAD ABDUL-WARIT ABDUR-RAHIM. PER CURIAM. Lawyer Muhammad Abdul-Warit Abdur-Rahim (State Bar No. 560822) has filed a petition for voluntary discipline, consenting to a State Disciplinary Review Board reprimand for his disrespectful and disruptive behavior in a criminal proceeding in which he represented himself. Abdur-Rahim concedes that his conduct was a violation of Georgia Rule of Professional Conduct 3.5 (d), which forbids lawyers to “engage in conduct intended to disrupt a tribunal.” The maximum penalty for a violation of Rule 3.5 (d) is a public reprimand. The State Bar of Georgia agrees that a Review Board reprimand is appropriate, and for the reasons that follow, we accept the petition for voluntary discipline. According to his petition, Abdur-Rahim was involved in an altercation with his father in September 2017, and as a result, Abdur-Rahim was charged with family violence battery, third- degree cruelty to children, and disorderly conduct. At his arraignment in April 2018, Abdur-Rahim was unnecessarily argumentative with prosecutors, used profanity, failed to follow the instructions of the court, and generally engaged in disruptive conduct. In mitigation, Abdur-Rahim says that he was suffering from personal and emotional problems at the time of his arraignment, that he later sought and obtained treatment for these problems, that he apologized to the judge and court staff involved in his arraignment, that he freely and fully disclosed his wrongful conduct to and cooperated with the State Bar and State Disciplinary Board, and that he is remorseful for his misconduct. We note as well that Abdur-Rahim has no prior disciplinary history, and his disrespectful and disruptive conduct on the occasion of his arraignment appears to have been an isolated incident, inasmuch as the State Bar has come forward with no evidence of Abdur-Rahim disrupting court proceedings on other occasions. In light of these mitigating circumstances, and considering that the most severe discipline for a violation of Rule 3.5 (d) is a public reprimand, we agree that a Review Board reprimand is appropriate discipline for Abdur-Rahim’s conduct at his arraignment.1 We accept the petition for voluntary discipline and direct that Abdur-Rahim receive a Review Board reprimand in accordance with Bar Rules 4-102 (b) (4) and 4-220 (b).2 Petition for voluntary discipline accepted. Review Board reprimand. Melton, C. J., Nahmias, P. J. and Blackwell, Boggs, Peterson, Warren, Bethel, and Ellington, JJ., concur. DECIDED APRIL 6, 2020. Petition for voluntary discipline. Lawson & Thornton, George O. Lawson, Jr., for Abdur- Rahim. Paula J. Frederick, General Counsel State Bar, William D. NeSmith III, Deputy General Counsel State Bar, Jenny K. Mittelman, James S. Lewis, Assistant General Counsel State Bar, for State Bar of Georgia. 1 See American Bar Association Standards for Imposing Lawyer Sanctions (2015), Standards 6.23, 6.24, 9.32. See also In the Matter of Morse, 266 Ga. 652, 653 (470 SE2d 232) (1996). 2 We note that the petition for voluntary discipline concerns only the misconduct that occurred at the arraignment, not any misconduct that may have occurred in connection with the altercation that led to the criminal charges on which Abdur-Rahim was arraigned. Our disposition of this petition would not preclude discipline for any such other misconduct. See Rule 8.4 (a) (convictions for certain criminal conduct shall constitute a violation of the Rules). ## Summaries written by Georgia Commons The following was written by claude-sonnet-5 from the opinion above and is not part of the court's opinion. Quote the opinion, not the summary. The Supreme Court of Georgia accepted a lawyer's request for a State Disciplinary Review Board reprimand after he admitted to disruptive, profanity-laced behavior while representing himself at his own criminal arraignment. ### Plain-language summary Muhammad Abdul-Warit Abdur-Rahim, a Georgia lawyer, was charged with family violence battery and related offenses after an altercation with his father. Representing himself at his arraignment, he was argumentative with prosecutors, used profanity, ignored the court's instructions, and generally disrupted the proceeding. Abdur-Rahim later filed a petition asking the Supreme Court of Georgia to accept a specific punishment, a reprimand from the State Disciplinary Review Board, for violating the rule that bars lawyers from intentionally disrupting a court. He pointed to mitigating facts: he had no prior disciplinary record, sought treatment for personal problems, apologized to the judge and court staff, and cooperated fully with the State Bar. The State Bar agreed the proposed punishment was appropriate. The court accepted the petition and imposed the reprimand. ### Holding, as summarized The court held that a State Disciplinary Review Board reprimand, the maximum penalty available for violating the rule against disrupting a tribunal, was appropriate given the lawyer's cooperation, remorse, treatment for personal problems, and lack of prior discipline. ### Disposition Petition for voluntary discipline accepted; Review Board reprimand imposed. Melton, C. J., Nahmias, P. J. and Blackwell, Boggs, Peterson, Warren, Bethel, and Ellington, JJ., concur. ### Why it matters The decision shows how Georgia disciplines lawyers for disrespecting courts, even when the misconduct happens during the lawyer's own personal legal trouble rather than while representing a client. It signals that isolated, mitigated misconduct can result in a lighter sanction than the maximum allowed. > The summarized reasoning, checked quotes, suggested questions, and the CourtListener opinion records (1,531 characters) are at https://georgiacommons.org/opinions/S20Y0209/10367530.md?full=1