Inquiry Concerning Judge Robert M. Crawford

310 Ga. 403
CourtSupreme Court of Georgia
DecidedNovember 12, 2020
DocketS18Z1636
StatusPublished
Cited by5 cases

This text of 310 Ga. 403 (Inquiry Concerning Judge Robert M. Crawford) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Inquiry Concerning Judge Robert M. Crawford, 310 Ga. 403 (Ga. 2020).

Opinion

310 Ga. 403 FINAL COPY

S18Z1636. INQUIRY CONCERNING JUDGE ROBERT M. CRAWFORD.

PER CURIAM.

This judicial discipline matter is before the Court on the Report

and Recommendation of the Hearing Panel of the Judicial

Qualifications Commission (“JQC”) and a timely notice of exceptions

filed by Robert M. “Mack” Crawford. The Hearing Panel

recommended that Crawford, who later resigned as a Superior Court

Judge of the Griffin Judicial Circuit, be “removed from office” for

violating Rule 1.1 of the Georgia Code of Judicial Conduct (“CJC”),

which says that “Judges shall respect and comply with the law.”1

The Hearing Panel did not recommend that Crawford be

permanently barred from seeking or holding judicial office.2 The

1 The CJC italicizes terms that are defined in its Terminology section.

The Terminology section defines “law” to include, among other things, statutes and court rules, but not non-emergency court orders. 2 JQC Rule 6 (B) (1) identifies removal from office “with . . . a prohibition

on seeking or holding judicial office in the future” as a permissible sanction. JQC Director did not file a notice of exceptions, thereby accepting

the Hearing Panel’s recommendation. See JQC Rule 24 (F). Under

rules promulgated by this Court, we must now file a written decision

either dismissing this matter or imposing a sanction. See JQC Rule

25 (D) (1). For the reasons stated below, we dismiss.

1. At the direction of the JQC’s Investigative Panel, the

Director filed a formal complaint against Crawford. The complaint

alleged that Crawford violated CJC Rule 1.1 in two ways: (1) by

“impermissibly converting money from the registry of the Superior

Court of Pike County . . . when he ordered the Pike County Clerk via

handwritten note to disburse $15,675.62 in funds from the court

registry to him via check” and “then cashed and used a portion of

the check for his personal benefit and deposited the remainder of

this money in his personal checking account,” although he later

returned the funds; and (2) by “failing to follow the proper procedure

for the disbursement of funds, even if the money had been his, as

required by law,” noting the certification requirement for

withdrawal of funds from a court registry contained in Uniform

2 Superior Court Rule 23. In 2002, when Crawford was in private

practice, he had deposited the funds into the registry from his client

trust account in connection with a lawsuit. The JQC complaint

acknowledged that Crawford claimed that at least some of the

money was owed to him as attorney fees and expenses. The

complaint sought Crawford’s removal from office but not a ban on

seeking or holding judicial office in the future.3

At a formal hearing before the JQC Hearing Panel, the Pike

County Clerk, who had held that position for 30 years, testified —

and the Hearing Panel later found — that Crawford did not order

the Clerk to disburse the funds to him, nor did the Clerk feel

compelled to do so; she simply trusted Crawford because he was a

close, longtime friend. The Hearing Panel issued its Report and

Recommendation, concluding that there was clear and convincing

evidence that Crawford violated CJC Rule 1.1 by taking money that

3 The complaint also charged Crawford with violating CJC Rule 1.3, but

the Hearing Panel issued a “directed verdict” on that charge. 3 was “not demonstrably his own” and by failing to comply with the

certification requirement.

To assist in our review of this judicial discipline matter, on

August 10, 2020, we directed Crawford and the Director to file briefs

on three issues: (1) whether there is clear and convincing evidence

that Crawford violated CJC Rule 1.1; (2) whether the JQC was

validly constituted at all relevant times; and (3) whether this Court

should ban Crawford from seeking or holding judicial office in the

future in light of the evidence. In connection with the third issue, we

noted that the Director did not seek such a sanction in the formal

complaint, the issue was not raised before the Hearing Panel, and

the Hearing Panel did not recommend a lifetime ban.

2. Crawford contends that the JQC failed to prove by clear and

convincing evidence that he violated CJC Rule 1.1 in a manner

sufficient to support his removal from office and that the Hearing

Panel erred in concluding otherwise based on the evidence before it.

See JQC Rule 7 (“Charges of misconduct . . . shall be established by

the standard of clear and convincing evidence. . . .”). It is undisputed

4 that Crawford violated CJC Rule 1.1 by obtaining funds from the

court registry without complying with the certification requirement

of Uniform Superior Court Rule 23. However, while such a violation

is serious, we express doubt that the complaint would have sought

or the Hearing Panel would have recommended Crawford’s removal

from office for violating CJC Rule 1.1 based solely on a single

violation of the certification requirement of Uniform Superior Court

Rule 23. As a result, and particularly in light of the sanction sought

here, we move to the clearly more serious of the Hearing Panel’s CJC

Rule 1.1 findings.

It also seems clear that, while the evidence before the Hearing

Panel likely was sufficient to support a finding that Crawford

violated CJC Rule 1.1 by impermissibly converting the funds he

obtained from the court registry under a preponderance of the

evidence standard of proof, and perhaps even under the higher clear

and convincing evidence standard, that is a close question; we note

that the evidence on that issue certainly was not overwhelming. See

Inquiry Concerning Judge Peters, 289 Ga. 633, 635 (715 SE2d 56)

5 (2011) (explaining that in judicial discipline matters, “this Court

employs the clear and convincing proof standard to decide whether

allegations against a judge are established by the evidence of record”

(citation and punctuation omitted)). Critical to our analysis of the

evidence, though, is the fact that Crawford has since resigned,

thereby voluntarily removing himself from office, which was the

very sanction sought in the formal complaint and recommended by

the Hearing Panel. Under these circumstances, we conclude that it

is unnecessary for us to decide definitively whether the evidence was

sufficient to support a finding by clear and convincing evidence that

Crawford violated CJC Rule 1.1 by impermissibly converting the

funds from the court registry so as to warrant his removal from

office.4

3. Crawford also contends that the Hearing Panel was not

properly constituted when it considered this matter because the

4 We note that Crawford later pled guilty to misdemeanor theft arising

from the same incident and was sentenced to serve 12 months on probation. As part of a plea deal, Crawford resigned from office and agreed not to seek or hold judicial office while on probation. See Crawford v. Balli, 355 Ga. App. 297, 297 n.1 (844 SE2d 236) (2020). 6 names of its members were not submitted to the Senate by January

15, 2018. See OCGA § 15-1-21 (g) (1) (“The names of the appointees

. . . shall be submitted by the appointing authorities to the Senate

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