--- title: In the Matter of Samuel Elias Skelton collection: opinions id: S23Z1032 cite_as: In the Matter of Samuel Elias Skelton, 317 Ga. 280 (2023) canonical_url: https://georgiacommons.org/opinions/S23Z1032 md_url: https://georgiacommons.org/opinions/S23Z1032.md text_url: https://georgiacommons.org/opinions/S23Z1032/text source_url: https://www.courtlistener.com/opinion/10680040/in-the-matter-of-samuel-elias-skelton/ date: 2023-09-06 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/2023.md previous: https://georgiacommons.org/opinions/S23A0699.md next: https://georgiacommons.org/opinions/S23Y0500.md index: https://georgiacommons.org/opinions/index.md omitted: opinion extras omitted_chars: 1952 omitted_url: https://georgiacommons.org/opinions/S23Z1032.md?full=1 docket: S23Z1032 citation: 317 Ga. 280 court: Supreme Court of Georgia case_type: bar discipline authoring_justice: Per Curiam disposition: Certification of fitness for readmission granted vote: All the Justices concur word_count: 835 date_filed_source: courtlistener citations: - 892 S.E.2d 751 record_source: courtlistener legal_areas: - professional discipline - bar admission upstream_id: "10680040" summaries_model: claude-sonnet-5 --- # In the Matter of Samuel Elias Skelton Supreme Court of Georgia, docket S23Z1032, filed 2023-09-06, 317 Ga. 280. ## Opinion 317 Ga. 280 FINAL COPY S23Z1032. IN THE MATTER OF SAMUEL ELIAS SKELTON. PER CURIAM. This matter is before the Court on the Application for Certification of Fitness to Practice Law pursuant to Part A, Section 10 of the Rules Governing Admission to the Practice of Law in Georgia (the “Rules”), submitted by Samuel Elias Skelton. Skelton was originally admitted to the practice of law in 2009 but voluntarily surrendered his license to practice law in 2017 after pleading guilty under the First Offender Act, see OCGA § 42-8-60, to 21 counts of theft by taking, in violation of the Georgia Rules of Professional Conduct 8.4 (a) (2), found at Bar Rule 4-102 (d). See In the Matter of Skelton, 300 Ga. 866 (800 SE2d 514) (2017). Skelton successfully completed his sentence, and the trial court entered an order of discharge in December 2021. Skelton asserts that his guilty plea was related to his struggles with mental health and addiction, and he maintains that he has been rehabilitated and now seeks readmission. Following review of his application and his appearance at an informal conference, the Board to Determine Fitness of Bar Applicants (the “Fitness Board”) voted to recommend granting Skelton’s application. The application is now before this Court for final adjudication. See Bar Admission Rules, Part A, Section 10 (e) (“[t]he Supreme Court shall make the final determination regarding certification of fitness” of attorneys applying for readmission to the practice of law). On July 13, 2022, Skelton filed his application, in which he accepted responsibility for his actions; explained that the conduct that led to the voluntary surrender of his license was the result of a serious struggle with mental health and substance abuse; and described his efforts to improve his mental health and to become sober and maintain his sobriety. He detailed his close relationship with his wife and three young children; his current, stable employment; and his community service work, including his work with the Georgia Bar Association Committee on Attorney Wellness, Celebrate Recovery, and the Hart Youth Development Resource Association (the “Association”). As part of Skelton’s work with the Committee on Attorney Wellness, he published wellness articles in the Georgia Bar Journal, including one which detailed how Skelton’s struggles with his mental health and addiction led to losing his Bar license and incarceration and what members of the Bar can do to help friends and colleagues with similar struggles. Skelton also submitted 40 letters of recommendation from lawyers—including from former and current colleagues and employers, former opposing counsels, a county solicitor general, a retired judge, and lawyers who have struggled with mental health and addiction—and non-lawyers who know Skelton through his work with the Committee on Attorney Wellness, Celebrate Recovery, and the Association, all of whom attest to Skelton’s potential to once again become a productive member of the Bar and many of whom attest to Skelton’s work to help lawyers and others who have struggled with addiction to achieve and maintain their own sobriety. Through its investigation, the Fitness Board determined that no active grievances or other disciplinary matters against Skelton are pending before the Bar and that no restitution was required to be made to the Client Security Fund. At an informal conference convened before the Fitness Board, Skelton took full responsibility for his actions and made no excuses; expressed remorse for his actions; described his descent into addiction and the cycle of destructive behavior that led to his incarceration; and described in detail his path to recovery and maintaining his sobriety following his incarceration. After considering Skelton’s testimony and written submissions, the Fitness Board concluded that he had, by clear and convincing evidence, carried his burden of demonstrating rehabilitation and recommended that he be readmitted to the Bar. See In re Cason, 249 Ga. 806, 808-809 (294 SE2d 520) (1982) (bar admission applicant bears burden to establish rehabilitation by clear and convincing evidence, and “rehabilitation is the reestablishment of the reputation of a person by his or her restoration to a useful and constructive place in society,” including “[t]he requirement of positive action”). Upon consideration of the entire record, we likewise conclude that Skelton has shown that he is entitled to be certified as fit to practice law in Georgia. Accordingly, as it appears that Skelton has satisfied all of the requirements for approval of his application for certification of fitness, see Bar Admission Rules, Part A, Section 10, this Court hereby grants Skelton’s application for certification of fitness and orders that, upon satisfaction of all the requirements of Part B of the Rules, including taking and passing the Georgia Bar Examination, Skelton may be readmitted as an attorney licensed to practice law in the State of Georgia. Certification of fitness for readmission granted. All the Justices concur. Decided September 6, 2023. Certification of fitness to practice law. John A. Earles, Rebecca S. Mick, for Office of Bar Admissions. Christopher M. Carr, Attorney General, Russell D. Willard, Senior Assistant Attorney General, for Board to Determine Fitness of Bar Applicants. ## 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 approved Samuel Elias Skelton's application to be certified as fit to practice law again, after he surrendered his law license in 2017 following a guilty plea for theft tied to addiction and mental health struggles. ### Plain-language summary Samuel Elias Skelton was admitted to practice law in Georgia in 2009 but gave up his law license in 2017 after pleading guilty, under a program that avoids a formal conviction record, to 21 counts of theft by taking. He said his crimes stemmed from serious struggles with mental health and substance abuse. After completing his sentence and being discharged by the trial court in 2021, he applied to be certified as fit to practice law again. A board that reviews these applications held an informal conference, heard Skelton describe his recovery and community service, and reviewed 40 letters of support from lawyers and non-lawyers. The board concluded Skelton had proven his rehabilitation by clear and convincing evidence and recommended readmission. The Supreme Court of Georgia reviewed the full record and agreed, granting his certification of fitness, meaning he can become a licensed Georgia attorney again once he meets remaining requirements, including passing the bar exam. ### Holding, as summarized The court held that Skelton proved by clear and convincing evidence that he has been rehabilitated and reestablished himself as a useful and constructive member of society, satisfying the requirements for certification of fitness to practice law, so his application for readmission is granted pending completion of remaining bar admission steps. ### Disposition Certification of fitness for readmission granted. All the Justices concur. ### Why it matters The decision shows Georgia's path for disbarred or license-surrendering attorneys to demonstrate rehabilitation and return to law practice, reassuring the public that readmission requires thorough vetting while giving people who address addiction or mental health issues a real chance to rebuild their careers. > The summarized reasoning, checked quotes, suggested questions, and the CourtListener opinion records (1,952 characters) are at https://georgiacommons.org/opinions/S23Z1032.md?full=1