This disciplinary matter returned to the Supreme Court of Georgia after the Court previously rejected a proposed public reprimand as insufficient. Stephanie Dianne Woodard, a Georgia lawyer since 1996 and former Solicitor General of Hall County State Court, sought voluntary discipline for conduct that led to a misdemeanor guilty plea under OCGA § 45-11-4(b)(1) and (5) and admitted violations of GRPC 8.4(a)(3) and 8.4(a)(4).

The renewed petition presented two central questions: (1) the appropriate length of suspension given admitted dishonesty-related rule violations and a misdemeanor involving moral turpitude; and (2) whether any suspension should be entered nunc pro tunc (retroactively), and if so, to what date.

The State Bar supported accepting the petition but requested a 12-month suspension without retroactivity. Woodard proposed a suspension of three to 12 months and sought retroactivity to the end of her First Offender sentence (August 30, 2024), while stating she would accept a non-retroactive suspension if the Court deemed it appropriate.

The Court accepted Woodard’s petition for voluntary discipline and imposed a 12-month suspension, but it granted retroactivity only to June 26, 2025—the undisputed date Woodard transferred to inactive Bar status—rather than to August 30, 2024, the date Woodard requested.

On sanction length, the Court held that the seriousness of GRPC 8.4(a)(4) dishonesty misconduct (and the additional GRPC 8.4(a)(3) conviction-based violation), coupled with case comparators, warranted a mid-range suspension. On retroactivity, the Court applied the evidentiary and compliance expectations articulated in In the Matter of Onipede, 288 Ga. 156 (2010), finding Woodard did not adequately prove she voluntarily ceased all practice by August 2024, but did establish a reliable anchor date of June 26, 2025 through her inactive-status election.

• In the Matter of Woodard, 321 Ga. 681 (2025) (“Woodard I”)
  
  The Court’s prior opinion set the baseline: a public reprimand was too lenient for admitted violations of GRPC 8.4(a)(3) and (4) arising from criminal misconduct as a public officer. Woodard I also framed the appropriate comparator cases as involving suspensions (not reprimands), effectively instructing that any renewed voluntary discipline proposal must align with that level of sanction. In this second appearance, the Court treated Woodard I as the controlling roadmap on proportionality and seriousness.
• In the Matter of Williams, 284 Ga. 96 (2008)
  
  Williams supplied the low-end comparator for suspension length (six months) for a prosecutor involved in a scheme to steal county funds and pleading guilty to a public-officer offense. Woodard attempted to distinguish Williams based on alleged lack of intent and smaller sums, but the Court emphasized that Woodard’s guilty plea to a “willfully and knowingly” demand of excess cost under OCGA § 45-11-4(b)(5) undercut claims of non-intentional conduct. The Court also rejected sentence-comparison to a co-conspirator as a meaningful disciplinary metric, noting the respondent in Williams received a similar First Offender probation structure.
• In the Matter of Adams, 291 Ga. 768 (2012)
  
  Adams provided the high-end comparator (18 months) for dishonesty-based overbilling and misrepresentation, involving multiple offenses over time and an indictment under statutes similar to those underlying Woodard’s indictment. Although Woodard highlighted differences (including supportive Bar recommendation in Adams, prior reprimand, and opposition letters), the Court found the structural similarity—repeated dishonest conduct over a meaningful period and a core GRPC 8.4(a)(4) violation—supported a “lengthier than minimal” suspension. The Court also treated Woodard’s additional GRPC 8.4(a)(3) violation as a further reason not to reduce discipline below the six-month floor suggested by comparator cases.
• In the Matter of Dowdy, 247 Ga. 488 (1981)
  
  Dowdy supplied the classic articulation of disciplinary purpose: punishment, deterrence, and public assurance that courts will maintain professional ethics. The Court used Dowdy as a normative justification for selecting a sanction that both accounts for mitigation and visibly addresses misconduct by a public official in a way that preserves public confidence.
• In the Matter of Cook, 311 Ga. 206 (2021)
  
  Cook was cited for the four-factor sanctioning framework: duty violated, lawyer’s mental state, actual/potential injury, and aggravating/mitigating factors. Here, the Court invoked that framework to rebut Woodard’s emphasis on dollar amount alone, clarifying that financial magnitude is relevant but not determinative.
• In the Matter of Onipede, 288 Ga. 156 (2010)
  
  Onipede was the controlling precedent on retroactive suspensions: the lawyer bears the burden to prove voluntary cessation of practice, the cessation date, and compliance with ethical obligations implicated by stopping practice (including client transitions and file transfers). Applying Onipede, the Court found Woodard’s requested retroactivity to August 30, 2024 unsupported because it rested primarily on her “bare, unsworn assertion,” and because her conduct (failure to raise the claim earlier; delayed move to inactive status) undermined the reliability of that assertion. However, the Court accepted June 26, 2025 as a sufficiently supported retroactivity date because it was undisputed and objectively tied to her election of inactive membership.
• In the Matter of Coomer, 320 Ga. 430 (2024)
  
  Coomer was used to clarify that the practical content of Bar Rule 4-219(b) obligations depends on the lawyer’s role. The Court noted Woodard, as an elected official without traditional private clients, had no additional client-notification steps comparable to typical private-practice suspensions, paralleling the observation in Coomer that certain roles may limit what Bar Rule 4-219(b) requires.
• In the Matter of Veach, 310 Ga. 470 (2020)
  
  Veach was cited for the principle that the Court should not impose a sanction greater than what the lawyer requested in voluntary discipline. The Court used it to explain why selecting a different retroactivity date (June 26, 2025 rather than August 30, 2024) did not exceed Woodard’s requested sanction framework, especially given her expressed willingness to accept up to 12 months without retroactivity.

A. Determining suspension length

The Court began from the premise (reinforced in Woodard I) that GRPC 8.4(a)(4) dishonesty is “among the most serious violations,” and that Woodard also admitted GRPC 8.4(a)(3) based on a misdemeanor involving moral turpitude relating to fitness. It then used comparator discipline (Williams and Adams) to establish a presumptive suspension band (six to 18 months), rejecting Woodard’s attempt to justify a three-month suspension as lacking supporting authority.

Importantly, the Court discounted Woodard’s “non-intentional” framing by relying on the legal significance of her guilty plea: pleading guilty to OCGA § 45-11-4(b)(5) entails admitting she “willfully and knowingly” demanded more cost than allowed by law. That admission supported a finding that her mental state was at least willful as to the misdemeanor offense, strengthening the case for a meaningful suspension.

The Court also applied the Cook factors, emphasizing that the injury assessment is not solely about the amount of money involved. The duty violated (honesty; public trust), mental state (willful/knowing admission), injury (misappropriated public funds; erosion of confidence), and aggravation/mitigation collectively drove the sanction.

On mitigation, the Court acknowledged Woodard’s cited ABA Standards factors (no disciplinary history, restitution, cooperation, remorse, character/reputation, health/personal issues, collateral consequences). Yet it also scrutinized the evidentiary support for health-related mitigation, noting the medical documentation post-dated the misconduct, and it credited aggravators identified by the State Bar: substantial experience and illegal conduct. Balancing these, the Court selected a 12-month suspension—midpoint between the six-month and 18-month comparators.

B. Granting partial retroactivity (nunc pro tunc)

Retroactivity was resolved through the burden-shifting structure in Onipede: it was Woodard’s responsibility to prove (1) voluntary cessation, (2) the cessation date, and (3) compliance with ethical obligations triggered by stopping practice.

The Court refused to retroact to August 30, 2024 because Woodard’s showing was not sufficiently reliable: the plea did not require complete cessation of law practice; her claim was unsworn; she did not mention cessation in her first petition (despite its potential mitigating value); and she waited until June 26, 2025 to transfer to inactive status.

Nevertheless, the Court granted nunc pro tunc relief to June 26, 2025 because that date was undisputed and objectively documented by her election of inactive membership. The Court reinforced that election of inactive status under Bar Rule 1-202(a) is not merely administrative: it entails representations and restrictions (not practicing, not holding oneself out, not giving legal advice in positions calling for it, not evaluating legal effects for others). Those built-in constraints functioned as corroboration of cessation as of that date.

Finally, the Court rejected the State Bar’s argument that nunc pro tunc relief was inconsistent with Woodard I’s insistence on meaningful discipline. The Court’s approach preserved “real” discipline (12 months) while recognizing a supported, documented cessation date—aligning sanction proportionality with credible proof.

A. A practical evidentiary anchor for nunc pro tunc requests

This opinion underscores that Georgia’s nunc pro tunc discipline is not granted on narrative assertions alone. Where a lawyer cannot credibly prove an earlier cessation date under Onipede, the Court may still grant partial retroactivity to a verifiable milestone—here, the date of transfer to inactive status. Practically, lawyers seeking retroactive credit are incentivized to create a clear record early (sworn statements, contemporaneous communications, proof of cessation, and—when appropriate—timely inactive transfer).

B. Heightened sensitivity to public-official misconduct and public confidence

The Court explicitly connected discipline to preserving confidence in the profession, particularly where the attorney held public power and responsibility. Even when the underlying criminal resolution is a misdemeanor under the First Offender Act and the amount is relatively small, admitted dishonesty and abuse of office can require a substantial suspension.

C. Voluntary discipline negotiations and the Court’s supervisory role

The decision reinforces that the Supreme Court of Georgia will actively police proportionality in voluntary discipline petitions, using comparator cases and sanctioning principles to prevent under-sanctioning. Woodard I operated as a “warning shot,” and this opinion shows how the Court expects renewed petitions to track that guidance.

• Nunc pro tunc: Latin for “now for then.” In discipline, it means the suspension is treated as having started earlier than the order date, but only if the lawyer proves they actually stopped practicing and complied with the duties associated with stopping.
• Voluntary discipline petition: A process where the lawyer proposes a sanction to resolve disciplinary exposure. The Court is not bound to accept the proposed outcome and may reject it if inconsistent with precedent or public protection.
• GRPC 8.4(a)(4): Prohibits professional conduct involving “dishonesty, fraud, deceit or misrepresentation.” The Court describes this as among the most serious categories of misconduct.
• GRPC 8.4(a)(3): Addresses conviction of a misdemeanor involving moral turpitude related to fitness to practice. Even without a felony, certain misdemeanors can reflect directly on a lawyer’s suitability.
• First Offender Act: A Georgia sentencing mechanism allowing certain defendants to avoid a formal conviction record upon successful completion of conditions. It does not immunize lawyers from professional discipline; the underlying conduct and plea admissions remain central to bar sanctions.
• Mitigating vs. aggravating factors: Mitigation (e.g., restitution, cooperation, remorse, no prior record) can reduce discipline; aggravation (e.g., substantial experience, criminal conduct) can increase it. Courts weigh both to reach a proportionate sanction.
• Inactive status (Bar Rule 1-202(a)): A formal membership category requiring the lawyer not to practice or hold out as practicing, among other restrictions. Here, it served as objective support for the earliest date the Court would credit as cessation of practice.
• Bar Rule 4-219(b) duties: After suspension/disbarment, lawyers must cease practice and notify clients and take steps to protect client interests. The Court noted that in certain public roles there may be no traditional client-notification steps to perform, but the duty framework still matters.

The Supreme Court of Georgia accepted Woodard’s renewed voluntary discipline petition and imposed a 12-month suspension, granting partial retroactivity only to the verified date she became an inactive Bar member (June 26, 2025). The opinion’s significance lies in its disciplined application of comparator precedent for sanction length and its rigorous approach to nunc pro tunc requests under In the Matter of Onipede: retroactivity is earned through credible proof and ethically compliant cessation of practice, not through unsupported assertions.

In broader context, the decision reinforces that dishonesty-related misconduct—especially by attorneys holding public office—demands sanctions that visibly protect the public, deter similar conduct, and preserve trust in the legal profession, consistent with the disciplinary purposes articulated in In the Matter of Dowdy.