Inquiry Concerning Judge Robert Reeves

905 S.E.2d 1, 319 Ga. 532
CourtSupreme Court of Georgia
DecidedJuly 30, 2024
DocketS23Z0337
StatusPublished

This text of 905 S.E.2d 1 (Inquiry Concerning Judge Robert Reeves) 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 Reeves, 905 S.E.2d 1, 319 Ga. 532 (Ga. 2024).

Opinion

319 Ga. 532 FINAL COPY

S23Z0337. INQUIRY CONCERNING JUDGE ROBERT REEVES.

PER CURIAM.

This judicial discipline matter is before this Court on the

agreement between the Director of the Judicial Qualifications

Commission (“JQC”) and the Chief Judge of the Middle Judicial

Circuit Superior Court, Robert Reeves. Pursuant to JQC Rule 23,

the Amended Discipline by Consent Agreement (“Consent

Agreement”) would resolve formal charges against Judge Reeves

with a 30-day unpaid suspension and a published public reprimand.

Further, under the terms of the Consent Agreement, Judge Reeves,

whose current term expires on December 31, 2026, has agreed that

he will not seek reelection to judicial office. As explained below, with

the understanding that Judge Reeves is serving his final term in

judicial office, we accept the Consent Agreement and order a 30-day

unpaid suspension followed by a public reprimand published in

Judge Reeves’s local legal organs and the Fulton County Daily Report.

On November 16, 2022, the Director filed formal charges

against Judge Reeves. The formal charges included 58 counts, which

alleged numerous instances of misconduct inside and outside the

courtroom over a seven-year period.

In June 2024, the Director and Judge Reeves entered into an

initial consent agreement, under which Judge Reeves agreed to be

publicly reprimanded. But the Hearing Panel rejected the proposed

sanction as insufficient and gave guidance on the type of sanctions

the Hearing Panel would find more appropriate.

The Director and Judge Reeves then entered into the Consent

Agreement under consideration here, which adopted the Hearing

Panel’s recommended sanctions, proposing discipline in the form of

“a 30-day unpaid suspension followed by a public reprimand

published in [Judge Reeves’s] local legal organ and the Fulton

[County] Daily Report.”1 Under the Consent Agreement, Judge

1 The Middle Judicial Circuit has several legal organs. Accordingly, the

agreement that Judge Reeves receive “a public reprimand published in [his]

2 Reeves agreed to voluntarily recuse from any cases involving certain

of the lawyers named in the allegations of this case. The Consent

Agreement further provided that Judge Reeves’s current term in

office expires on December 31, 2026, and that “[h]e does not intend

to pursue election to another term in judicial office.” At a June 18,

2024 hearing, the Hearing Panel inquired into the meaning of this

statement, asking, “If we are distilling for the Supreme Court what

we understand the consent agreement to be, . . . would [it] be correct

to say . . . that one of the conditions is that Judge Reeves will not

seek reelection[?]”And Judge Reeves responded, “Correct.”

Under the Consent Agreement, Judge Reeves either admitted

the charge or admitted that “evidence exists with which the Director

could prove” the charge in 33 of the formal charges’ 58 counts. See

JQC Rule 23 (A) (providing for discipline by consent based on a

“judge’s admission of some or all of the formal charges or the judge’s

admission that evidence exists with which the Director could

local legal organ” requires publication of the public reprimand in each of the Middle Judicial Circuit’s legal organs. 3 properly prove some or all of the formal charges”). And the Director

explained that she did not proceed on the remaining counts because,

as to some counts, Judge Reeves had admitted violating other

provisions of the Code of Judicial Conduct based on the same

conduct, and, as to other counts, there were conflicts in the evidence

or issues with a witness’s credibility.

As summarized by the Hearing Panel, the counts that Judge

Reeves admitted pursuant to the Consent Agreement

describe[d] fourteen incidents spanning seven years of [Judge] Reeves’s seventeen years of service as a Superior Court judge. Most of these episodes involved [Judge] Reeves’s use of coarse, insensitive, demeaning, and/or insulting language, particularly with women. One involved a series of minor but nonetheless unwanted physical contacts between [Judge] Reeves and a female lawyer. The remaining incidents consisted of [Judge] Reeves improperly seeking to influence the handling of criminal prosecutions and misusing his title and office to assist the fundraising efforts of a local charity.

The Hearing Panel found that Judge Reeves’s admissions pursuant

to the Consent Agreement proved by clear and convincing evidence

that Judge Reeves committed the charged acts. And although Judge

Reeves had admitted that his conduct violated the Code of Judicial

4 Conduct, the Hearing Panel performed its own assessment of the

matter, concluding:

All of Judge Reeves’s offensive in-court and out-of- court statements violated Rules 1.2 (A) (duty to promote public confidence in the integrity of the judiciary) and 2.8 (B) (duty to be dignified and courteous to all with whom judges interact in their official capacity). Some of his statements also were inconsistent with Rule 2.3 (B) (duty not to engage in sexual harassment). His various improper interactions with a municipal court judge and state and superior court prosecutors concerning their cases and investigations violated Rules 1.2 (A), 1.3 (duty not to lend prestige of office to advance private interests of others) and 2.9 (A) (duty to avoid ex parte communications). Finally, his well-meaning but prohibited fundraising efforts ran afoul of Rules 1.2 (A), 1.3, and 3.1 (C) (duty to abstain from extra-judicial activities that cast doubt on judicial impartiality)[,] and 3.7 (A) (3) (duty to refrain from personally soliciting funds for organizations).

(Footnote and emphasis omitted.) The Hearing Panel further

concluded that Judge Reeves had engaged in forms of judicial

misconduct for which the Georgia Constitution authorizes sanctions,

stating:

[Judge] Reeves’s various acts of misconduct constitute[d] willful misconduct in office (i.e., judicial acts taken in bad faith), habitual intemperance (i.e., rude, abusive, or off-color language or improper and unsolicited

5 physical contact), and/or conduct prejudicial to the administration of justice which brings the judicial office into disrepute.

(Footnotes and emphasis omitted.)

Turning to the appropriate sanction, the Hearing Panel

weighed the gravity of some of the admitted misconduct against

certain mitigating factors. In particular, it highlighted the instances

of “unwanted physical contact” and “judicial interference in criminal

proceedings,” but noted that Judge Reeves’s offenses were “not

mean-spirited or self-serving” and that he had taken a “refreshing

and honest approach to the investigative process” and accepted

responsibility for his misconduct. The Hearing Panel concluded that,

under the circumstances, a public reprimand was an insufficient

sanction on its own and that removal from office would be too severe.

And although the Hearing Panel noted that “[t]here [were] no

published Georgia judicial discipline matters directly comparable to

Judge Reeves’s miscellaneous collection of violations,” it concluded

that the sanctions proposed in the Consent Agreement were

generally consistent with existing precedent. Accordingly, based on

6 existing precedent, the contents of the Consent Agreement, and the

statements made by Judge Reeves and his counsel during the June

18, 2024 hearing, the Hearing Panel recommended that this Court

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905 S.E.2d 1, 319 Ga. 532, Counsel Stack Legal Research, https://law.counselstack.com/opinion/inquiry-concerning-judge-robert-reeves-ga-2024.