In THE MATTER OF CHRISTOPHER CASEY TAYLOR (Six Cases)

• Court: Supreme Court of Georgia
• Decided: December 23, 2025
• Docket: S24Y1247, S24Y1248, S24Y1249, S24Y1250, S24Y1251, S24Y1252
• Status: Published

Opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: December 23, 2025

S24Y1247, S24Y1248, S24Y1249, S24Y1250, S24Y1251, S24Y1252. IN THE MATTER OF CHRISTOPHER CASEY TAYLOR (six cases).

PER CURIAM.

These six matters are before the Court on the report and

recommendation of the State Disciplinary Review Board (“Review

Board”), which reviewed special master LaVonda Rochelle DeWitt’s

report and recommendation. In each of these six matters,

Christopher Casey Taylor (State Bar No. 699696), a member of the

Bar since 2002, is charged with violating several provisions of the

Georgia Rules of Professional Conduct (“GRPC”) regarding clients of

the law firm where he is a partner. Taylor’s law practice, and that

of his firm, has a heavy focus on immigration matters. Indeed, all

six of these disciplinary matters arise out of representation in the

context of immigration law. The special master recommended a six- to-twelve-month suspension with a condition on reinstatement,

while the Review Board instead recommended disbarment based

largely on its conclusion that Taylor’s lack of remorse should weigh

heavily against him. Taylor initially denied that he was culpable for

any misconduct regarding the grievants’ cases. But he now concedes

the record supports a determination that he violated the Rules

concerning supervision of other attorneys, and he asks this Court to

impose a suspension consistent with the special master’s

recommendation of discipline. However, with the benefit of oral

argument1 and having carefully reviewed the record, we conclude

that disbarment is warranted.

1. Special Master’s Report and Recommendation

(a) Factual Findings

Following an extensive fact-finding process, which involved

multiple evidentiary hearings and the parties’ submission of

documentary and testimonial evidence, the special master made the

1 These matters were orally argued before this Court on September 16,

2025.

2 following findings of fact: Taylor is one of two equity partners at the

firm, which has an immigration-focused practice, and he

characterizes himself as the “face of the firm.” New clients reviewed

their firm engagement agreement with a paralegal and did not

speak to an attorney about their case until the firm was paid. Taylor

generally did not attend court proceedings with clients, but he

commonly filed an entry of appearance as counsel for the firm’s

clients. During the relevant periods, Taylor had approximately

10,000 open cases and consistently filed pleadings in the

immigration courts under his name as counsel of record.

Taylor made conflicting representations regarding his degree

of oversight of associate attorneys and staff, but evidence

established that these individuals were at times permitted to sign

Taylor’s name to letters and filings related to client matters without

Taylor having reviewed those documents before submission. Taylor

alternatively claimed both that he did not have supervisory or

administrative duties within the firm and that he was a “supervising

attorney” who had “supervisory responsibility” over the firm’s other

3 attorneys and staff. He entered an appearance in five of the six

immigration cases at issue, received court documents addressed to

him as counsel of record in those five cases, and in the sixth case

referred to himself as “lead counsel” and acknowledged that he

reviewed interrogatory responses. The special master found that,

despite Taylor’s assertions to the contrary, Taylor was each of these

clients’ attorney and owed them duties under the GRPC.

The special master next considered certain policies and

procedures of the immigration courts based on a policy manual

published by the federal Executive Office for Immigration Review

(“EOIR”), of which Taylor acknowledged being aware. The EOIR

manual provides that when a client retains more than one attorney

at a time, all such attorneys are counsel of record and are all

responsible as counsel for the client, although only one is recognized

as the primary or “notice” attorney. Only individual attorneys, not

firms, may represent parties before the immigration courts. And if a

firm wishes to re-assign responsibility for a client from one attorney

to another, a substitution of counsel must be filed, with the original

4 attorney remaining responsible for the representation until

substitution is granted.2 Immigration courts also require parties to

submit documents supporting certain applications, like those

supporting a removal cancellation application, no later than 15 days

before the hearing on the matter. Taylor acknowledged awareness

of the 15-day timing requirement, the attorney substitution

requirement, and the fact that his firm did not follow the latter.

The special master then addressed what she described as

Taylor’s “indifference and disregard” towards the disciplinary

process. Taylor initially did not cooperate with the discovery process,

forcing the Bar to file two motions to compel before he provided

discovery responses. Taylor and his counsel also failed to cooperate

in advancing these matters, necessitating several calls with the

special master on issues as basic as case timelines and Taylor’s non-

2 Although immigration courts may define the processes and procedures

by which an attorney must conduct themselves in that court, Georgia law (not federal law), as regulated by the State Bar and this Court, defines the practice of law within the state, including the duties that an attorney owes to a client. See Eckles v. Atlanta Technology Group, 267 Ga. 801, 804 (1997) (“Only this Court has the inherent power to govern the practice of law in Georgia.”).

5 compliance with the discovery process. The special master entered a

scheduling order in April 2023, setting the evidentiary hearing for

September 19–21, 2023, with the understanding that all parties and

witnesses would appear in person. But on September 19, Taylor’s

counsel appeared without Taylor, who failed to provide prior notice

to the Bar or the special master that he would not appear. Taylor

instead asked, through counsel, to appear virtually based on a

confidential medical situation. The special master ended the

proceedings, privately reviewed medical records that Taylor

submitted later that day, and entered an order the following

morning authorizing Taylor to appear virtually. 3 Taylor appeared

virtually on the second day of the hearing, but his failure to appear

the day before necessitated adding another day to complete the

proceedings. After the Bar rested, Taylor left the hearing, stating

that he was ill. He did not ask for a continuance or present any

evidence or testimony, leaving such matters to his counsel. Taylor

3 The special master issued the order on the morning of the second day

scheduled for the hearing, before Taylor filed a written request to appear virtually. He filed his motion several days later to complete the record.

6 then submitted briefs and a proposed order to the special master,

seeking to have all the complaints against him dismissed, but the

special master explained that post-hearing procedures did not

permit her to rule on the proposed order. Taylor then submitted a

one-and-a-half page proposed report and recommendation providing

that no discipline be imposed because: Taylor did not do the work at

issue; because he did not manage or supervise other attorneys;

because his firm did not mishandle the grievants’ cases; because the

grievants’ negative outcomes were foreseeable; and because his

firm’s administrative issues did not amount to ethical violations.

The special master then analyzed the underlying grievances

and found as follows. The client in State Disciplinary Board Docket

(“SDBD”) No. 7481 (S24Y1247), who was born in Mexico and entered

the United States in 1999, retained Taylor’s firm in April 2012

regarding his removal proceeding. The client paid $4,000 in fees,

executed his engagement agreement with the assistance of a

paralegal, and never met Taylor during the firm’s representation.

Taylor entered an appearance in the case as the primary attorney

7 and filed on the client’s behalf an EOIR 42B Application for

Cancellation of Removal and Adjustment of Status—which bore

Taylor’s signature as the client’s attorney and the preparer of the

application—and an I-485 Application to Adjust to Permanent

Resident Status. G.D., a “self-supervising” attorney employed by the

firm, filed an entry of appearance in the case and filed documents

supporting the removal cancellation application. Taylor did not

attend the client’s “master hearing” or speak to G.D. about the case.

Around four years later, in 2016, Taylor submitted a request for

prosecutorial discretion (which asks immigration officials to exercise

their discretion not to pursue removal), signing the document as the

client’s attorney. But Taylor did not follow up or obtain a decision on

the request. In November 2018, Taylor again filed an entry of

appearance as the client’s primary attorney and submitted

documents in the removal cancellation case for the first time since

December 2012. Taylor did not appear for a December 2018 hearing,

with the client instead represented by C.S., another attorney at

Taylor’s firm. After the hearing, the immigration judge denied the

8 client’s application for cancellation of removal and ordered him

removed. Taylor entered an appearance and filed an appeal on the

client’s behalf, but did not consult with the client, obtain his

authorization, or execute a new engagement agreement. The client

subsequently terminated Taylor’s representation and retained a

new attorney.

In SDBD No. 7483 (S24Y1248), a client retained Taylor’s firm

to represent him in a removal proceeding in 2012. Taylor did not

meet with the client, discuss his case with him, or appear at his

hearings. In February 2014, G.D. attended the client’s master

hearing and filed an application for cancellation of removal on the

client’s behalf. Taylor signed the application as the attorney who

had prepared the filing, but he did not prepare or review the

application or meet with the client before or after the hearing. At

the master hearing, an immigration judge scheduled the client’s

“individual hearing” for July 2016 and informed the client that any

documents on which he wished to rely had to be filed no later than

15 days before the individual hearing. Taylor was aware that the 15-

9 day deadline was the standard practice in immigration courts. The

client provided the supporting documents, at G.D.’s request, in May

2016. The individual hearing was rescheduled to March 8, 2018, and

K.M., an attorney at Taylor’s firm, attended the hearing. The same

day, a motion bearing Taylor’s signature and seeking the untimely

filing of the client’s documents was filed with the court. The motion

alleged that those documents were not provided to Taylor until

February 28, 2018, although the client had in fact provided them in

2016. The immigration judge denied the motion and asked K.M. why

the documents had not been timely provided. K.M. responded that

the firm had delayed asking the client to bring in the documents.

The immigration judge then denied the application for cancellation

of removal, and Taylor failed to consult with the client or K.M.

regarding how the case should proceed. Taylor instead filed an

appeal and entry of appearance without the client’s consent, arguing

that the immigration judge had failed to consider the evidence put

forward at the hearing. The Board of Immigration Appeals (“BIA”)

10 then affirmed the immigration judge’s decision. Taylor failed to

communicate the outcome of the appeal to the client.

In SDBD No. 7484 (S24Y1249), an individual entered the

United States from Mexico in 1992 at the age of two, and

immigration officials detained her in 2011. Her sister paid $4,000 to

retain Taylor’s firm to assist the client in obtaining legal status. One

of the firm’s employees told the client that Taylor would be her

attorney. During the disciplinary proceedings, Taylor acknowledged

that the client was his client but also stated that she was a client of

the firm, asserting that whether he represented her was a “complex”

question without a simple answer. Taylor was listed as counsel of

record for the client and conceded that he had “some level of

responsibility” for the client’s representation although he never met

or spoke with her. In January 2012, Taylor filed a removal

cancellation application on the client’s behalf, but no one from the

firm explained the requirements of such a filing to the client. A week

before her individual hearing, the client met with an unnamed

female attorney from the firm to prepare for the hearing. The client

11 testified that the attorney was not prepared for the hearing and

knew nothing about the client’s case. The client’s application was

denied after the hearing, but no one from the firm explained the

decision to the client. Without obtaining the client’s consent or

discussing the merits of her case with her, Taylor filed an appeal

and entry of appearance on her behalf. He did not personally fill out

or supervise the preparation of the notice of appeal, which had a

section requiring the client to state in detail the reasons for the

appeal. Taylor also failed to file a brief. The BIA dismissed the

appeal because the submitted documents failed to “meaningfully

apprise [the] Board of the reasons underlying the appeal.” Taylor

failed to discuss the outcome of the appeal with the client.

In SDBD No. 7632 (S24Y1250), a native of Nicaragua entered

the United States in 2017 and paid Taylor’s firm $5,500 to represent

her in connection with an application for asylum based on abuse she

suffered from her father. Taylor entered an appearance in the

client’s case and appeared at her master hearing, but neither Taylor

nor any other firm attorney spoke with her before the hearing.

12 Taylor filed an application for asylum without preparing or

reviewing it and without consulting the client about the application

or her chances of success. In the disciplinary proceedings, Taylor

said the application was filed simply to delay the client’s removal,

but this strategy was apparently never communicated to the client.

Although Taylor submitted certain documents in support of the

client’s application, he did not submit other documents that she had

provided to him and did not present witness testimony in support of

her claim. R.H., an attorney at Taylor’s firm, represented the client

at her March 2020 individual hearing, but Taylor did not meet with

R.H. or the client before the hearing or inquire about why certain

documents were not submitted. The client’s application was denied,

and while R.H. told the client he would represent her on appeal and

the client paid the requested filing fee to the firm, no appeal was

filed. When the client contacted the firm to inquire about the appeal,

R.H. and another employee falsely told her that the appeal had been

filed. Taylor maintained that the appeal was not filed because the

client did not execute a new engagement agreement or pay

13 additional attorney fees. There was no evidence that she was asked

to do either; the evidence presented in other related matters showed

that the firm filed appeals without a new engagement agreement or

additional fees. Taylor did not communicate with the client outside

of the master hearing or consult about her case with the attorneys

who worked on it, whom Taylor failed to supervise. Taylor also did

not refund any of the fees the client paid. She subsequently retained

new counsel and spent more than $10,000 in additional fees for her

immigration case.

In SDBD No. 7633 (S24Y1251), a native of Mexico who entered

the United States in 2000 hired Taylor’s firm while incarcerated.

The client first paid the firm $3,000 for Taylor to secure a bond for

him and later paid $4,500 for Taylor to file a removal cancellation

application. Taylor did not meet or speak with the client or consult

about the case with the attorneys who actually worked on it. Taylor

entered an appearance as the client’s primary attorney and filed the

removal cancellation application without preparing or reviewing it.

The client provided the firm with documents related to his claim

14 before his individual hearing; Taylor failed to supplement the

application before the hearing. C.N., an attorney at Taylor’s firm,

represented the client at the hearing, but Taylor did not speak with

C.N. about the case beforehand. C.N. informed the court at the

hearing that he intended to update the client’s application. The

court asked why an incomplete application had been submitted, and

C.N. answered that he had not prepared the application. The court

paused the proceedings so that Taylor could appear and “take

ownership” for the incomplete filing but ultimately resumed the

hearing, denied the client’s application, and ordered his removal.

C.N. then informed the client that the client could initiate an appeal.

The client said he would pursue an appeal but indicated that he

intended to hire new counsel. The client did not authorize Taylor or

his firm to file an appeal and instead terminated the representation

and asked for a copy of his file. Taylor nonetheless filed a notice of

appeal as the client’s attorney, but he failed to file a brief or

statement in support of the appeal, resulting in the appeal’s

dismissal. Taylor was aware that failure to file a brief or statement

15 could result in dismissal, and he indicated on the notice of appeal

that a brief or statement would be filed. The client learned of the

failed appeal only after someone from the firm told him about it. He

subsequently spent an additional $5,000 to obtain new counsel.

Taylor did not refund any of the fees paid by the client.

In SDBD No. 7634 (S24Y1252), a client hired Taylor’s firm in

2019 to assist him in obtaining permanent U.S. residency. The client

met with Taylor, who told him that Taylor could assist him in

gaining permanent residency. The client paid $2,000 and provided

information such as his home address. Taylor provided no legal

services to the client: he failed to respond to inquiries from the client

on the status of the matter, failed to make an entry of appearance,

failed to file a notice of substitution of counsel, failed to notify the

immigration court of his representation, and failed to provide the

client’s address to the court. In March 2020, the client received a

letter bearing Taylor’s signature, informing him that his case had

been scheduled for a master hearing. Taylor did not actually sign or

review the letter or otherwise attempt to communicate with the

16 client. Approximately two weeks before the scheduled hearing, the

client called Taylor’s firm for information regarding the hearing. He

was unable to reach Taylor or any other attorney. The client

appeared for the hearing, but neither Taylor nor anyone from his

firm was present. The clerk then informed the client that a

deportation order had already been entered against him for failure

to appear at the hearing, which had been rescheduled to a date

several months earlier. No one from the firm informed the client of

the date change until approximately two weeks later when the client

received a letter, signed by Taylor, which noted the missed court

date and the entry of the removal order. Taylor did not refund any

of the fee paid by the client, who had to hire a new attorney.

(b) Rules Violations

17 The special master then turned to Taylor’s alleged violations of

the following GRPC provisions: Rules 1.1, 4 1.2(a),5 1.3, 6 1.4(a),7

1.16(d),8 3.2,9 and 5.1(a) and (b).10 The maximum sanction for a

4 Rule 1.1 imposes on lawyers a duty to provide competent representation. 5 Rule 1.2(a) provides, in pertinent part, that “a lawyer shall abide by a

client’s decisions concerning the scope and objectives of representation and, as required by Rule 1.4, shall consult with the client as to the means by which they are to be pursued.” 6 Rule 1.3 provides that “[a] lawyer shall act with reasonable diligence

and promptness in representing a client. Reasonable diligence as used in this rule means that a lawyer shall not without just cause to the detriment of the client in effect willfully abandon or willfully disregard a legal matter entrusted to the lawyer.” 7 Rule 1.4(a) provides, in pertinent part, that a lawyer shall “reasonably

consult with the client about the means by which the client’s objectives are to be accomplished; … keep the client reasonably informed about the status of the matter; … [and] promptly comply with reasonable requests for information[.]” 8 Rule 1.16(d) provides that

[u]pon termination of representation, a lawyer shall take steps to the extent reasonably practicable to protect a client’s interests, such as giving reasonable notice to the client, allowing time for employment of other counsel, surrendering papers and property to which the client is entitled and refunding any advance payment of fee that has not been earned. 9Rule 3.2 provides that “[a] lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client.” 10 Rule 5.1(a) provides, in pertinent part, that “[a] law firm partner …

shall make reasonable efforts to ensure that the firm has in effect measures giving reasonable assurance that all lawyers in the firm conform to the Georgia Rules of Professional Conduct[,]” while Rule 5.1(b) provides that “[a] lawyer having direct supervisory authority over another lawyer shall make reasonable

18 single violation of Rules 1.1, 1.2(a), 1.3, and 5.1(a) and (b) is

disbarment; the maximum sanction for a single violation of Rules

1.4(a), 1.16(d), and 3.2 is a public reprimand.

Addressing Taylor’s violations of the GRPC rule-by-rule, the

special master concluded that Taylor violated Rule 1.1 in the 7484

matter by failing to properly specify the grounds for appeal in his

submission of the notice of appeal to the BIA.

Taylor violated Rule 1.2(a):

• in the 7481 matter by failing to consult with the client

regarding the filing of an appeal and by filing an appeal

without that client’s authorization;

• in the 7483 matter by failing to consult with the client

about how to proceed with his case once his application

was denied and by failing to consult with that client

before filing an appeal on his behalf;

efforts to ensure that the other lawyer conforms to the Georgia Rules of Professional Conduct.”

19 • in the 7484 matter by failing to discuss any aspect of the

case with the client, including failing to discuss with her

the requirements for success on her application, failing to

explain the denial of her application, and failing to

consult with her regarding the filing of an appeal;

• in the 7632 matter by failing to consult with the client

regarding the merits of her case and by failing to pursue

her desired appeal;

• in the 7633 matter by failing to consult with the client

regarding the documents to support his claim, failing to

consult with him regarding the filing of an appeal, and

filing that appeal without authorization; and

• in the 7634 matter by failing to consult with or provide

legal services to the client.

Taylor violated Rule 1.3:

• in the 7481 matter by failing to submit any documents

supporting the client’s application between 2012 and

2018;

20 • in the 7483 matter by failing to timely submit documents

supporting the client’s case—resulting in those

documents not being considered by the immigration

judge—and by misrepresenting when that client had

provided those documents;

• in the 7484 matter by failing to diligently pursue a

properly supported appeal;

• in the 7632 matter by failing to present documents and

witness testimony in support of the client’s asylum claim

and by failing to ensure that her appeal was filed;

• in the 7633 matter by submitting an incomplete

application, failing to timely update that application, and

failing to submit a brief or statement in support of the

client’s appeal, resulting in its dismissal; and

• in the 7634 matter by failing to notify the court of his

representation of the client, failing to inform that client of

the change in the hearing date, and failing to appear for

court.

21 Taylor violated Rule 1.4(a):

• in the 7481 matter by failing to communicate with the

client about his case and appeal;

• in the 7483 matter by failing to communicate with the

client about his case, including the motion for out-of-time

filing, the outcome of the individual hearing, and the

appeal;

• in the 7484 matter by failing to discuss the application or

appeal with the client;

• in the 7632 matter by failing to communicate with the

client about her case, including failure to discuss

documents submitted in support of her claim and her

• in the 7633 matter by failing to communicate with the

client about his case, including failure to discuss the

documents needed to support his claim and appeal; and

• in the 7634 matter by failing to have any communications

with the client beyond the initial consultation.

22 Taylor violated Rule 1.16(d) in the 7634 matter by abandoning

the client without having done any work on his case and by failing

to refund any of the $2,000 fee the client paid.

Taylor violated Rule 3.2 in the 7632 matter by failing to make

reasonable efforts to pursue the client’s appeal, despite having

prepared the documents necessary to do so.

As to Rule 5.1(a) and (b), the special master first determined

that Taylor failed to make reasonable efforts to ensure that his firm

had policies and procedures to reasonably ensure that the firm’s

attorneys would comply with the GRPC. The special master also

determined that Taylor’s failure to supervise attorneys and his

policy of allowing attorneys to sign his name to pleadings without

reviewing those documents contributed to the pattern of non-

compliance with the GRPC. And the special master concluded that

Taylor violated Rule 5.1 in the 7632 matter by failing to select or

review the documents submitted by the client, failing to discuss with

R.H. (the attorney who appeared at the client’s hearing) why certain

documents were omitted, and failing to ensure that R.H. pursued

23 that client’s appeal. And the special master concluded that Taylor

violated Rule 5.1 in the 7633 matter by failing to ensure that a

complete application was submitted on the client’s behalf, failing to

discuss that client’s case with C.N. (the attorney who appeared at

the client’s hearing) or ensure that C.N. updated the application,

and failing to ensure that the firm complied with the client’s desire

to terminate the firm’s representation.

(c) ABA Standards

Citing the American Bar Association Standards for Imposing

Lawyer Sanctions (“ABA Standards”), see In the Matter of Morse,

265 Ga. 353, 354 (1995) (to determine the appropriate level of

discipline, disciplinary authority considers the duty violated; the

lawyer’s mental state; the potential or actual resulting injury; and

aggravating or mitigating factors), the special master first

determined that Taylor failed to meet his obligations to consult with

and diligently represent these clients. The special master deemed

his actions—including neglecting these clients and failing to

supervise other firm attorneys—to be knowing rather than

24 inadvertent or negligent. Regarding the harm caused, Taylor’s

clients were vulnerable victims and suffered significant injuries in

the form of adverse outcomes in their immigration cases. And, citing

ABA Standard 4.42, the special master noted that suspension is

generally appropriate when an attorney’s knowing failure to

perform services for a client causes injury or potential injury and

when an attorney’s pattern of neglect causes injury or potential

injury to a client. In aggravation, the special master found that

Taylor engaged in a pattern of misconduct, committed multiple

offenses, engaged in bad-faith obstruction of the disciplinary process

by intentionally failing to comply with the rules and orders of the

disciplinary authority, refused to acknowledge the wrongful nature

of his conduct, harmed vulnerable victims, and had substantial

experience in the practice of law. See ABA Standard 9.22(c), (d), (e),

(g), (h), and (i). Taylor’s lack of prior discipline was the only

mitigating factor. See ABA Standard 9.32(a). The special master

concluded that a six-to-twelve-month suspension was the

25 appropriate sanction. 11 The special master further concluded that

Taylor’s reinstatement should be conditioned on “completing an

evaluation with the Law Practice Management Department of the

State Bar and providing the Office of the General Counsel with proof

that [Taylor] has implemented the recommendations of the Law

Practice Management Department in his law firm practice.”

2. Review Board Proceedings

(a) Taylor’s Exceptions to the Special Master’s Report & Recommendation

Taylor began his exceptions to the special master’s report and

recommendation by asserting that his role as the firm’s “notice

attorney” did not imply a corresponding duty for him to represent

11 The special master based that conclusion on In the Matter of Lewis,

313 Ga. 695 (2022) (six-month suspension for lawyer who violated Rules 1.1, 1.2, 1.3, 1.4, 1.16(d), and 3.2 in three separate matters); In the Matter of Golub, 313 Ga. 686 (2022) (one-year suspension with conditions for lawyer who violated Rules 1.2(a), 1.3, 1.4(a), 1.16(d), 3.2, and 8.4(a)(4) in the representation of one client); In the Matter of Sneed, 314 Ga. 506 (2022) (nine-month suspension with conditions for lawyer who violated Rules 1.3, 1.4, and 9.3 in four separate matters); In the Matter of Kirby, 312 Ga. 341 (2021) (six-month suspension for lawyer who violated Rules 1.2, 1.3, 1.4, and 1.16 in four separate matters); and In the Matter of Miller, 291 Ga. 30 (2012) (twelve-month suspension with conditions for lawyer who violated Rules 1.2, 1.3, and 1.4 in the representation of one client).

26 each client individually. Taylor argued that the “notice attorney”

procedure, which he describes as routine in immigration cases,

arises from the fact that immigration cases can take many years to

resolve: designating one senior attorney for this role helps ensure

the firm continues to receive notice on such matters, even if the

attorneys directly responsible for the case should leave the firm.

Taylor argued that the record demonstrates that his designation as

the “notice attorney” should not be taken as proof of his individual

involvement in each client’s case as most of the clients at issue here

had not met Taylor, had no expectation that he would be

individually involved in their cases, and instead worked only with

associates and staff. Taylor then argued that the record shows he

did not personally represent any of these clients and that, to the

extent the Bar was proceeding under a respondeat superior theory

of liability, its failure to charge violations of Rule 5.1 in four of these

six matters was fatal to the allegations in those matters. Next,

Taylor argued that new counsel initiated at least four of the six

grievances for Taylor’s former clients because of what he

27 characterized as their attorneys’ willful misinterpretation of Matter

of Lozada, 19 I.&N. Dec. 637 (Bd. of Immigr. Appeals 1988), a BIA

decision that some practitioners interpret to require a bar complaint

to be filed against a client’s former attorney in order to sustain a

motion to re-open removal proceedings.

Taylor then turned to the specific client grievances. As to each

of the six, Taylor made largely the same argument that he did not

individually represent any of the clients. Taylor asserted that each

client’s engagement agreement did not list Taylor as the primary

attorney assigned to the case; that it was clear that other attorneys

and staff would be responsible for actually providing the agreed-

upon services; that he had little or no interaction with the clients,

such that they had no reasonable expectation that Taylor would

provide the legal services they sought; and that various clients gave

false testimony or made false statements during the grievance

process. Concerning the 7481, 7484, and 7632 matters, Taylor

alleged that the disciplinary process was being manipulated by the

clients’ new attorneys, whom he characterized as competitors who

28 had brought spurious grievances against him as to matters for which

he had no direct involvement or responsibility. Taylor also

addressed the purported merits of each client’s underlying legal

matters, arguing that the clients’ underlying claims and cases

lacked merit or that the clients’ own actions were the “proximate

cause” of their unfavorable outcomes.

(b) The State Bar’s Response

In response, the Bar first argued that Taylor was not simply a

“notice attorney” for the clients’ underlying cases: he entered

appearances as counsel of record in each case; his name was listed

on all pleadings as counsel of record; the records of the immigration

courts listed him as counsel of record; and no substitution of counsel

was filed in any of the cases. And the Bar noted that,

notwithstanding his inconsistent assertions to the contrary, Taylor

testified that he had “supervisory responsibility” over lawyers and

staff at the firm after a senior associate left and that Taylor

performed “tasks” in the case underlying at least one of these

matters. The Bar also argued that Taylor was the clients’ attorney

29 of record—and thus was directly responsible for the misconduct that

occurred—in all of these matters even though he was not charged

with violating the supervision Rules in each matter. Finally, the Bar

argued that Taylor’s claim about the reasons these grievances were

filed in the first place was misdirected because, regardless of what

may have prompted the grievances, the Bar was prosecuting these

matters at the State Disciplinary Board’s direction and only after

the Office of the General Counsel’s extensive investigation.

The Bar then addressed each matter individually and

maintained that Taylor directly represented each of the clients,

relying principally on his entries of appearance and the presence of

his name on the clients’ filings. And the Bar insisted that, even if

other attorneys also worked on the underlying cases, Taylor was at

least an attorney for each client and had direct ethical obligations to

them all. Regarding Taylor’s arguments about the merits of the

clients’ underlying immigration cases, the Bar noted that the

disciplinary process is designed to assess whether an attorney has

failed in his ethical obligations under the GRPC—not to adjudicate

30 the potential merits of a client’s underlying claims. Even in a case

unlikely to prevail on the merits, the Bar said, an attorney must

fulfill duties like communicating and consulting with the client,

providing diligent representation, and ensuring that other attorneys

under his supervision comply with their ethical responsibilities. The

Bar also noted that, although Taylor made much of the supposed

lack of merit of the clients’ cases, there is no evidence that he or

anyone else at his firm advised the clients of these apparent defects.

Moreover, the Bar argued, Taylor’s attempt to shift blame onto the

clients for the unfavorable results in their cases did not address

Taylor’s own failings.

(c) Review Board’s Report and Recommendation

The Review Board then issued its report and recommendation.

As to the special master’s findings of fact, reviewed for clear error,

the Review Board characterized the primary factual dispute as

whether Taylor represented the clients in an individual capacity.

Although the Review Board acknowledged Taylor’s extensive

arguments to the contrary, it concluded that Taylor had not

31 demonstrated that the special master’s findings—that Taylor bore

responsibility for the representation of each of these clients—were

clearly erroneous. The Review Board then adopted and incorporated

the special master’s factual findings. The Review Board also adopted

and incorporated the special master’s conclusions of law, including

her application of the ABA Standards to the duties violated, Taylor’s

mental state, the potential or actual injury caused by his

misconduct, and the aggravating and mitigating factors. The Review

Board reiterated that Taylor’s actions were knowing and that the

clients all suffered significant injuries.

But the Review Board rejected the special master’s conclusion

regarding the appropriate sanction to be imposed. The Review Board

first stated (without any citation to authority) its belief that the

special master had to recommend a precise sanction rather than a

range for suspension (as the special master proposed here). The

Review Board cited the special master’s reference to Lewis, Sneed,

and Kirby and concluded that each of those cases dealt with similar

Rule violations but were distinguishable because they arose from

32 voluntary discipline petitions. See Lewis, 313 Ga. at 698; Sneed, 314

Ga. at 510; Kirby, 312 Ga. at 345. The Review Board further

distinguished Golub and Miller, which the special master also cited,

on the basis that Golub expressed remorse for the harm done to his

client and Miller engaged with the disciplinary process and was

remorseful. Golub, 313 Ga. at 694; Miller, 291 Ga. at 30. The Review

Board stated that the correct standard for determining the

appropriate sanction was ABA Standard 4.41,12 applied in In the

Matter of Bell, 313 Ga. 615, 615–16, 618 (2022) (disbarment for

failure to act diligently and adequately communicate with client;

lawyer made numerous misrepresentations to client, exhibited a

dishonest or selfish motive, had two instances of prior discipline, and

failed to respond to the Bar’s motion for summary judgment), and In

the Matter of Roberts, 314 Ga. 510, 511, 514, 517–18 (2022) (attorney

12 ABA Standard 4.41 provides that

[d]isbarment is generally appropriate when: (a) a lawyer abandons the practice and causes serious or potentially serious injury to a client; or (b) a lawyer knowingly fails to perform services for a client and causes serious or potentially serious injury to a client; or (c) a lawyer engages in a pattern of neglect with respect to client matters and causes serious or potentially serious injury to a client.

33 without prior discipline disbarred for conduct in two client matters

where attorney failed to respond to filings and appear at court

hearings, failed to communicate and consult with clients to their

substantial detriment, and refused to acknowledge wrongful

conduct and showed indifference to making restitution). Since

Taylor knowingly failed to perform services for multiple clients,

constituting a pattern of neglect that seriously injured multiple

clients, and since he lacked remorse for his misconduct, the Review

Board recommended that Taylor be disbarred.

3. Filings Before this Court

(a) Taylor’s Exceptions to the Review Board’s Report & Recommendation

Taylor begins his exceptions to the Review Board’s report and

recommendation by discussing the “rarefied field of immigration

law” and lamenting the “state of utter dysfunction” of the

immigration courts, “particularly the court here in Atlanta.” But

Taylor admits to violating Rule 5.1(a) as to the 7632 and 7633

34 matters,13 and he admits that the record could support finding that

he also violated Rule 5.1(b) in those matters, given his managerial

authority over his firm’s work and his failures to ensure that the

attorneys directly handling these matters were adequately

supervised. Taylor nonetheless continues to insist that he was only

the “marketing face” of the firm and a “notice attorney” for all cases.

He expresses his mystification at the failings of the associate

attorneys. And he bemoans the fact that the immigration courts’

unusual practices made him appear responsible for matters in which

he was not actually involved. Yet Taylor concedes that he is “legally,

ethically, and personally obligated” to his firm’s clients and to

ensuring that legal services are competently rendered. Still, he

attempts to cabin any failures on his part to a failure to adequately

13 Taylor further notes that, although violations of Rule 5.1(a) were not

charged in the remaining four cases, the record could support finding that he violated that Rule in those cases as well.

35 attend to the firm’s structure, which he concedes has become

“untenable” as the firm has grown rapidly in size. 14

Taylor nonetheless excepts to the Review Board’s decision on

multiple grounds. Taylor admits that the record supports the special

master’s findings that he failed to supervise associate attorneys and

ensure that those attorneys provided the required and requested

legal services. But Taylor emphasizes that the special master did

not find that he directly and knowingly made false representations

to clients, failed to provide legal services, or abandoned client

matters. He maintains that the Review Board improperly rejected

the special master’s recommended suspension in favor of

disbarment, which he contends is not appropriate. Taylor argues

that Bell and Roberts, cited by the Review Board, are

14 Taylor says the firm’s structure has since been altered by establishing

a committee of three senior associates to exercise direct supervisory authority over more junior personnel. And Taylor says the firm would also benefit from additional guidance from the Law Practice Management Department. Taylor further asserts that he is working with his law partner and senior associates to develop additional systems to assist the firm’s associates, apparently including the provision of additional support for associates to access professional development resources.

36 distinguishable because they addressed intentional misconduct and

personal harm to clients rather than supervisory inaction. As to the

Review Board’s focus on his lack of remorse, Taylor insists that he

was merely putting up a good-faith defense to the charges against

him. 15

Taylor next reiterates his claim that the grievances underlying

these matters largely or entirely resulted from competitor attorneys’

weaponization of Lozada. Taylor insists that Lozada’s effects are a

“specter … haunt[ing]” all attorneys who practice removal defense.

And he insists that the aggrieved clients’ cases were destined to fail,

so any ethical violations on his part were not the proximate cause of

any harm to the clients, let alone sufficient to support the finding of

serious injury necessary to warrant disbarment. Taylor asserts that

the special master properly analyzed the level of injury that the

15 Taylor also maintains that he did not intentionally fail to comply with

the rules or orders governing the disciplinary proceedings, given the serious medical issues he was experiencing at the time of the hearing on these matters. He has not disclosed what those medical issues were, but the special master granted Taylor’s motion to appear virtually after confidentially reviewing medical records Taylor submitted.

37 clients suffered and properly applied ABA Standard 4.42 in

concluding that suspension was appropriate.

Finally, Taylor argues that the alleged violations of Rules 1.1,

1.2(a), 1.3, 1.4, 1.5(a), 1.16(d), and 3.2 cannot be sustained because

the Bar failed to allege a violation of Rule 5.1(c).16 Taylor asserts

that, even assuming his firm’s associate attorneys committed the

misconduct alleged, Taylor could not be held vicariously liable

unless the Bar alleged and proved that he violated Rule 5.1(c).

Consistent with the special master’s recommendation, Taylor asks

this Court to impose a suspension between six and twelve months,

with reinstatement conditioned on completing an evaluation with

the Bar’s Law Practice Management Program and providing to the

16 Rule 5.1(c) provides that

[a] lawyer shall be responsible for another lawyer’s violation of the Georgia Rules of Professional Conduct if: (1) the lawyer orders or, with knowledge of the specific conduct, ratifies the conduct involved; or (2) the lawyer is a partner or has comparable managerial authority in the law firm in which the other lawyer practices or has direct supervisory authority over the other lawyer, and knows of the conduct at a time when its consequences can be avoided or mitigated but fails to take reasonable remedial action.

38 Bar’s Office of the General Counsel proof that he has implemented

any recommendations from that evaluation.

(b) The Bar’s Response

In response, the Bar first notes that it supports the imposition

of a six-to-twelve-month suspension but maintains that the Review

Board correctly concluded that disbarment would also be

appropriate. In support of disbarment, the Bar argues that the

special master’s findings that Taylor individually represented each

of the grievants—making him responsible for the misconduct that

occurred in each matter—belies Taylor’s assertion that he violated

only the Rules governing supervisory misconduct. And the Bar

rejects Taylor’s contention that disbarment would be excessive,

relying on ABA Standard 4.41’s provision that disbarment is the

presumptive sanction for knowing failure to perform legal services

or a pattern of neglect that causes serious or potentially serious

injury to a client. The Bar asserts that Taylor’s firm’s business

model was predicated on knowing neglect, citing his

acknowledgement that growth in the firm’s client list made it

39 impossible to adequately manage all client matters within the firm’s

existing structures. And, the Bar says, the special master’s findings

also support concluding that Taylor knowingly failed to perform

needed services for his clients and that the clients thereby suffered

serious injuries. The Bar also contends that the special master’s

findings regarding harm to the clients are sufficient to support

disbarment, particularly given that cases in other jurisdictions17

have concluded that the risk of deportation constitutes a “serious

injury” warranting disbarment. And the Bar argues that the special

master properly found six aggravating factors and only one

mitigating factor—Taylor’s lack of prior discipline.

The Bar disputes Taylor’s argument that these disciplinary

proceedings were instituted only because Lozada arguably requires

aggrieved litigants to file a Bar complaint against former counsel in

order to reopen removal proceedings. The Bar asserts that its

decision to pursue these matters arises only from Taylor’s

17 Specifically, the Bar points to Matter of Anschell, 69 P3d 844, 855

(Wash. 2003) (en banc), and People v. Wake, 528 P3d 943 (Colo. 2023) (“substantial injury”).

40 misconduct, not anything related to immigration law. Regarding

Taylor’s argument that any errors in the 7632 matter do not warrant

discipline because the client’s case was meritless, the Bar argues

that nothing in the record suggests Taylor communicated with the

client regarding the merits of her case. The Bar further responds

that disciplinary proceedings are not concerned with the merits of

underlying legal claims; that Taylor had ethical obligations even to

clients with a low chance of success; and that failure to meet those

obligations harmed Taylor’s clients regardless of the merits of their

cases. Finally, contrary to Taylor’s argument that he could not be

found to have violated certain Rules because the Bar failed to allege

a violation of Rule 5.1(c), the Bar maintains that Taylor overlooks

the special master’s conclusion that he was the attorney of record in

these clients’ cases, thereby owed them direct ethical obligations

under the GRPC, and is responsible for the misconduct at issue.

4. Analysis

As noted, Taylor now concedes that he violated Rule 5.1(a) in

the 7632 and 7633 matters, that the record could support finding

41 that he violated Rule 5.1(b) in those matters as well, and that the

record could support finding that he violated Rule 5.1(a) in the four

matters in which it was not charged.18 Additionally, the special

master made a specific factual finding that the record supported the

conclusion that Taylor was the attorney of record in these clients’

cases. Taylor has not demonstrated that this finding was clearly

erroneous or that, given this finding, the special master erred in

concluding that Taylor’s conduct violated Rules 1.1, 1.2(a), 1.3,

1.4(a), 1.16(d), and 3.2, as charged.19

Regarding the proper sanction, we first note that Taylor’s

failures of diligence, competence, communication, and supervision

18 The Bar helpfully explained at oral argument that Rule 5.1 violations

were not charged in the other matters because Taylor’s systemic failures to supervise did not become clear until Taylor testified later in the disciplinary process. See In re Ruffalo, 390 US 544, 551–52 (1968) (“The charge must be known before the proceedings commence. They become a trap when, after they are underway, the charges are amended on the basis of testimony of the accused.”). 19 Neither the special master’s findings regarding Taylor’s failures of

communication, nor our review of those findings, should be understood to suggest that when multiple attorneys represent a client, each attorney must directly communicate with the client. But some attorney must communicate with the client.

42 violate some of an attorney’s most consequential duties. See ABA

Standard 3.0(a) (duty violated impacts sanction determination).

Taylor abandoned the grievants and did not ensure that other

attorneys would provide the diligent, competent representation

those clients were entitled to. And, per the special master’s

unrebutted finding, that abandonment and abdication of

supervisory responsibility was knowing—with “conscious awareness

of the nature or attendant circumstances of the conduct[.]”

Knowledge, ABA Standards. See also ABA Standard 3.0(b) (mental

state informs sanction determination).

Further, Taylor’s misconduct caused at least some of his clients

actual injury. See ABA Standard 3.0(c) (degree of actual or potential

injury, ranging from “little or no” injury to “serious” injury, informs

sanction determination). At least three clients received no refund for

the several thousand dollars in fees they each paid Taylor’s firm.

And at least four clients had to obtain new representation—one

spending $10,000 to retain new counsel and another spending

$5,000—on top of having to effectively restart litigating their cases.

43 See, e.g., In the Matter of McCalep, 318 Ga. 260, 269 (2024) (attorney

injured grievants “due to the loss of funds they paid for services he

did not provide, and the loss of their opportunities to hire competent

and diligent lawyers to pursue their claims and defend their rights”).

We regularly conclude that this sort of misconduct—abandoning

even a single client after taking their money—is injurious. See, e.g.,

In the Matter of Haklin, 321 Ga. 530, 531–32 (2025) (disbarring

attorney who injured single client by accepting $2,300 fee and

abandoning that client); id. at 532 (collecting cases disbarring

attorneys who similarly injured and abandoned a single client and

violated Rules 1.2, 1.3, and 1.4, along with aggravating factors like

client vulnerability and attorney’s substantial professional

experience).20 So Taylor abandoned his clients, did so knowingly,

and injured at least some of them in the process. The presumptive

sanction is—at minimum—suspension. See ABA Standard 4.42

20 Abandonment can itself be an injury when, for example, an adjudicative body makes some decision adverse to the client because of his attorney’s abandonment. See, e.g., In the Matter of Blain, 315 Ga. 475, 476 (2023) (disbarring attorney based on part on abandonment of client, which resulted in court dismissing client’s case with prejudice).

44 (suspension generally appropriate when attorney knowingly fails to

perform services for client or engages in pattern of negligence and

that misconduct causes “injury” or “potential injury”).

But that does not end the matter. Multiple aggravating factors,

see ABA Standard 3.0(d), demonstrate that disbarment is

warranted. The vulnerable nature of the victims of Taylor’s

misconduct and the systemic nature of that misconduct are

particularly aggravating. Regarding the victims’ vulnerability,

Taylor continues to assert that he is effectively the victim of

competitor attorneys’ unscrupulous use of Lozada through the

grievances brought on behalf of his former clients. But that assertion

appears entirely speculative and, as noted below, is largely beside

the point. And it cannot be ignored that Taylor’s former clients

appear to be legally unsophisticated parties whose uncertain

immigration statuses rendered them particularly vulnerable and

potentially less likely than other parties to pursue redress of

attorney misfeasance through the State Bar grievance process. See,

e.g., In the Matter of Strang, 322 Ga. 354, 358–59 (2025) (client’s

45 incarceration and indigency, among other things, aggravated

misconduct and supported disbarment).

As to the pattern of Taylor’s misconduct and his commission of

multiple offenses, the record makes clear that ill-advised practices

endemic to Taylor’s firm fostered his failures of diligence,

communication, and supervision in these matters.21 During the

periods in question, Taylor led a practice of signing up large

numbers of clients to be serviced by a firm with a modest number of

attorneys, and he then exercised minimal, if any, oversight of how

those clients’ cases were handled. Taylor now concedes that, given

the firm’s rapid growth, the practices initially in place are now

insufficient. Taylor’s failure to attend to these matters—and his

seeming indifference to the actual handling of client matters once

the client paid the firm—exacerbate the severity of his misconduct.

See, e.g., In the Matter of Chin, 322 Ga. 218, 231–33 (2025)

(systematic misconduct in firm management and client fund

21 It is deeply ironic that one of these practices—filing an appeal without

consulting the client—occurred in each of the appealed matters except for the one matter where the client actually requested an appeal.

46 administration, among other things, aggravated misconduct and

supported disbarment). It is not merely Taylor’s failure to supervise

but his own failures of diligence, consultation, and communication,

that justify his disbarment.

We acknowledge that in many cases resulting in disbarment,

there is “serious” injury to the attorney’s client or clients (often in

the form of substantial monetary loss or materially worse case

outcomes), one or more Rule 8.4(a)(4)22 violations, and total failure

to engage with the disciplinary process.23 In those matters,

22 Rule 8.4(a)(4) provides that it shall be a violation of the GRPC for a

lawyer to “engage in professional conduct involving dishonesty, fraud, deceit or misrepresentation.” 23 See, e.g., In the Matter of McGowan, 322 Ga. 349, 352 (2025) (disbarring attorney who defaulted, abandoned client, violated Rule 8.4(a)(4), improperly retained $30,000 of client’s funds, and converted over $17,000 of those funds to personal use, which forced client to “drain[] her savings account to pay her medical expenses”); In the Matter of David-Vega, 318 Ga. 600, 605– 06 (2024) (disbarring attorney who defaulted, violated Rule 8.4(a)(4), failed to file client’s lawsuit before statute of limitations expired); In the Matter of Tuggle, 319 Ga. 687, 690, 697–98 (2024) (attorney violated Rule 8.4(a)(4), among others, and abandoned two clients, one of whom spent nearly $32,000 to set aside a default judgment imposed as result of attorney’s abandonment); In the Matter of Van Johnson, 319 Ga. 627, 627–28, 631–32 (2024) (accepting voluntary surrender of license, tantamount to disbarment, from attorney who, among other things, forged client’s signature to convert a $47,000 settlement payment).

47 disbarment is typically presumed appropriate. See ABA Standards

4.41, 4.51 (disbarment presumptively warranted when failure of

diligence or competence causes “serious injury” or “potentially

serious injury”). Here, it is unclear whether Taylor’s misconduct

caused his clients to face worse case outcomes, the State Bar did not

charge Taylor with any Rule 8.4(a)(4) violations, and Taylor did not

default in the disciplinary proceedings, so this is not the typical

disbarment case.

Disbarment is nonetheless appropriate. In the first instance,

the special master’s findings reflect that at least some of these

clients suffered economic injury through the loss of thousands of

dollars of unreturned unearned fees and the cost of hiring other

representation. Moreover, injury to the client and the severity

thereof is only one of several factors for determining the appropriate

sanction for attorney misconduct. And we have never conditioned

disbarment, much less a finding of injury to the client, on a showing

that the client lost their case because of their attorney’s misconduct.

Disbarment can be proper even when a client’s case has a low chance

48 of success from the start. Cf. In the Matter of Jackson, 321 Ga. 256,

258 (2025) (disbarring attorney whose abandonment precluded

client from filing timely habeas petition); Strang, 322 Ga. at 357,

358–59 (noting attorney’s arguments about merits of clients’ cases

but disbarring because attorney knowingly abandoned multiple

clients and numerous aggravating factors outweighed absence of

prior discipline). See also In the Matter of Melnick, 319 Ga. 730, 736

n.10, 739–40 (2024) (attorney’s argument—that Rule 1.3 and 1.4

violations did not harm client because she received a favorable

outcome with another attorney—“reflect[ed] a lack of remorse”). In

fact, disbarment is often warranted based on other harms, like

financial harm, especially where (as here) an attorney causes such

harm to multiple clients. See, e.g., In the Matter of Greene, 320 Ga.

527, 531 n.9 (2024) (noting that attorney’s abandonment may or may

not have extended one client’s period of incarceration but still

concluding disbarment was warranted when attorney abandoned

three clients, two of whom paid at least $10,000 in legal fees before

being abandoned). Likewise, we have never held that finding that

49 an attorney violated Rule 8.4(a)(4) or defaulted in the disciplinary

matter is necessary to support disbarment. See, e.g., Haklin, 321 Ga.

at 531 (disbarring attorney who abandoned one client and failed to

participate in disciplinary process but was not charged with

violating Rule 8.4); In the Matter of Briley-Holmes, 304 Ga. 199, 208–

09 (2018) (accepting voluntary surrender of license when attorney

abandoned seven clients and caused serious injury). And while the

record supports Taylor’s claim that medical issues affected his

participation in the special master’s hearing, Taylor’s overall

participation in the disciplinary process was—even if short of

default—half-hearted at best and obstructive at worst. See, e.g., In

the Matter of Lain, 311 Ga. 427, 427–28, 437–38 (2021) (misconduct

aggravated by “failure to engage honestly in the disciplinary

process” when attorney responded inadequately to State Bar’s

discovery requests, resulting in multiple motions to compel, with

which attorney did not comply). We therefore evaluate this

disciplinary matter on the many facts and circumstances particular

to this matter and outlined above. In the Matter of Jones, 298 Ga.

50 185, 187 (2015). The unique circumstances here do not change our

conclusion that disbarment is appropriate considering the duties

violated, the harm caused, and the aggravating factors.

We also acknowledge the lack of adequate comparator cases

concerning Taylor’s Rule 5.1 violations. See, e.g., Melnick, 319 Ga.

at 740 (sanctions imposed in prior, similar cases can be useful in

establishing a baseline comparison). But for the other violations—

Rules 1.1, 1.2(a), 1.3, 1.4(a), 1.16(d), and 3.2—there is no shortage of

precedent supporting disbarment for such misconduct. See, e.g., In

the Matter of Lemoine, 322 Ga. 463, 463–64 (2025) (disbarring

attorney for violating Rules 1.1, 1.2(a), 1.3, and 1.4(a), among

others); McCalep, 318 Ga. at 269–70 (same). We are convinced that

Taylor’s direct failures of communication, consultation, and diligent

and appropriate representation, exacerbated by his failures of

supervision, support disbarment. 24 Taylor’s Rule 5.1 violations,

24 Given the special master’s determination that Taylor was these clients’

attorney—and thus owed them direct ethical obligations under the GRPC and was personally responsible for violating them—Taylor’s argument regarding the Bar’s failure to charge Rule 5.1(c) violations is unavailing. Disbarment is

51 despite the lack of direct comparator cases, simply bolster that

conclusion.

Although we have concluded that disbarment is the

appropriate sanction here, we note that our analysis departs from

the Review Board’s analysis in one notable respect. The Review

Board’s disbarment recommendation appears to be premised largely

on Taylor’s lack of remorse for his misconduct. Refusing to

acknowledge the wrongful nature of one’s conduct is a recognized

aggravating factor, and one which certainly applies here: for

example, even as late as oral argument on these matters, Taylor was

reluctant to acknowledge his responsibility for the violations of Rule

5.1 (violations which he had already conceded in this Court). But we

caution Special Masters and the State Disciplinary Review Board

against overreading an attorney’s refusal to admit guilt from the

outset. Attorneys in disciplinary proceedings have the right, like all

litigants, to advance good-faith, colorable arguments supporting

warranted based on Taylor’s misconduct towards his clients, not because of anyone else’s purported ethical violations.

52 their position. See In the Matter of Meyers, 302 Ga. 742, 745 (2017)

(“[A] lawyer’s decision to put up a defense in a disciplinary

proceeding … is not always an aggravating factor that counsels

imposition of harsher discipline.”). So refusing to admit guilt from

the outset generally means the mitigating effect of showing

remorse—one factor among many—is absent, not that the

aggravating effect of refusing to “acknowledge [the] wrongful nature

of [one’s] conduct” is present. See ABA Standards 9.22(g), 9.32(l).

Taylor has advanced numerous arguments that attempt to

undermine the seriousness of these matters. He has argued, among

other things, that his “ethical violations were not the proximate

cause of the grievants’ removal orders,” that the grievants’ cases

were “always doomed to fail,” and that the grievants’ new attorneys,

alleged competitors of Taylor’s firm, filed the State Bar complaints

to “hijack the disciplinary process to harass” Taylor. As to the

underlying cases’ merits, we decline to deem Taylor’s culpability

lessened based on his conjecture about his clients’ chances of

success. It would require us to speculate on merits issues based only

53 on a limited record and Taylor’s characterization25 of those matters.

Also, as noted above, Taylor’s misconduct clearly caused injury apart

from the underlying cases’ outcomes. And regardless, the existence

and degree of injury is only one factor in determining the proper

sanction for attorney misconduct. We agree with the Bar that these

proceedings properly focus on Taylor’s failure to fulfill his

professional obligations, not the underlying cases’ merit.

Taylor has also consistently attempted to cast his mishandling

of the underlying client matters as resulting primarily from the

peculiarities of immigration court practice, especially the practice of

limited representation.26 Because it is unnecessary to resolve this

matter, we decline to set out any general guidelines regarding how

25 We need not and do not express any opinion here about the propriety

of charging several thousands of dollars to file documents that contain, in the attorney’s opinion, no chance of success other than in delay of the proceedings. But we are not willing to accept the premise that an attorney representing a client who lacks meritorious claims is freed of the duties to communicate and otherwise provide professional services. 26 In his exceptions filed in this Court, Taylor cites a 2022 amendment to

the EOIR rules which he says altered immigration-court practice to allow attorneys to enter appearances to provide limited services. But the relevant facts in these matters apparently all occurred before the rule’s promulgation.

54 considerations like a firm’s size and practice area may bear on the

issues that have arisen here. Instead, we reiterate that a

disciplinary inquiry in circumstances like these properly focuses on

whether a firm has adequately discharged its obligations to its

clients. And a firm’s structure and management practices do not

relieve individual attorneys who have appeared as counsel of record

of their responsibility for their clients.

Concerning Taylor’s claim that competitor attorneys brought

these grievances for improper reasons, we reiterate our admonition

that “weaponization of the disciplinary process must not be

encouraged.” In the Matter of Cook, 311 Ga. 206, 215 (2021). But

whatever reasons may have prompted the underlying grievances,

these matters should stand or fall on their own merits—especially

given Taylor’s acknowledgement that he violated the lawyer

supervision Rules and his failure to rebut the special master’s

determination that he was responsible for these clients and

personally violated Rules 1.1, 1.2(a), 1.3, 1.4(a), 1.16(d), and 3.2. In

55 short, Taylor’s arguments largely miss the point and do not change

our conclusion that disbarment is proper.

5. Imposition of Discipline

Accordingly, it is hereby ordered that Christopher Casey

Taylor be removed from the rolls of persons authorized to practice

law in the State of Georgia. Taylor is reminded of his duties under

Bar Rule 4-219(b).

Disbarred. All the Justices concur.