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IN RE: Jeffrey JACKSON.
This disciplinary matter is before the Court on the petition for voluntary discipline filed before the issuance of a formal complaint by Jeffrey Jackson (State Bar No. 779477), who has been a member of the State Bar since 2018. See Bar Rule 4-227(b). This is Jackson's second petition for voluntary discipline filed in this Court in connection with eight client grievances filed against him. In his first petition, Jackson asserted that an ongoing mental health crisis forced him to close his private law practice and that, in the process of doing so, he failed to adequately communicate with and properly withdraw from his representation of some of his clients; admitted violating three Rules of the Georgia Rules of Professional Conduct (“GRPC”) found in Bar Rule 4-102(d); and requested that we impose a State Disciplinary Review Board reprimand but agreed to accept up to a public reprimand. We rejected the petition, explaining that it was unclear “how [Jackson] allegedly advised his clients of his decision to terminate his practice,” whether he “violated more serious rules,” and “whether a reprimand is appropriate discipline given the allegations of misconduct.” In the Matter of Jackson, 320 Ga. 318, 319, 908 S.E.2d 627 (2024). In the instant petition for voluntary discipline, Jackson provides evidence of the mental health crisis that he was experiencing at the time of his misconduct and of the restitution he has provided to his clients; expands on how and when he communicated with his clients regarding the termination of his practice; admits that he violated Rules 1.1, 1.2(a), 1.3, 1.4(a), 1.16(a), 1.16(c), 1.16(d), and 3.2; admits that his conduct implicated Rule 4-104; and requests that this Court accept the proposed voluntary discipline of a six-month suspension, nunc pro tunc to October 20, 2023, the date that he took a 22-month voluntary break from the practice of law. The State Bar supports the petitioner for voluntary discipline and request for a six-month suspension to be imposed nunc pro tunc. Because Jackson has sufficiently addressed the deficiencies in his first petition and because we agree that a six-month nunc pro tunc suspension is appropriate and consistent with similar cases, we accept Jackson's amended petition for voluntary discipline.
1. Factual Admissions
Jackson was admitted to the Georgia Bar in 2018. He joined another attorney in a partnership named Jackson-Brubaker Law P.C. in 2020. This partnership ended in January 2022. Shortly thereafter, Jackson established Jeffrey A. Jackson, Attorney at Law LLC and represented about 45 to 50 clients, some of whom he began representing during his partnership. However, during this time, Jackson was suffering from mental health issues. Jackson contacted the State Bar, and, per its guidance, took an emergency 90-day leave of absence from the practice of law. However, as Jackson needed more time to resolve his mental health crisis, he suspended his law practice indefinitely. At the time he terminated his practice, he believed that his staff had informed his clients that they needed to seek new counsel. Not all clients were properly notified, which resulted in the following eight grievances filed against him.
State Disciplinary Board Docket (“SDBD”) No. 7851: In December 2021, the client hired Jackson to represent her in a criminal matter and paid him a $1,500 retainer. When Jackson took his emergency medical leave in May 2022, no hearings or other actions had been scheduled and, while Jackson was on medical leave, the client was noticed for a hearing. The client attempted to communicate with Jackson but had difficulties because Jackson's practice had been shut down. In August 2022, Jackson and the client exchanged emails, at which time Jackson confirmed that he had terminated his practice. The client subsequently retained new counsel who had the case against her dismissed. Jackson states that he regrets that he failed to communicate his intent to withdraw earlier, which forced the client to rush to obtain new counsel, and he regrets that he could not refund the client her retainer sooner. However, in June 2023, he provided the client a full refund.
SDBD No. 7852: The client initially retained a partner at Jackson's previous law firm to handle a name change petition for her son, and a petition was filed in June 2021. The matter was subsequently transferred to Jackson. In May 2022, Jackson's assistant texted the client to inform her that Jackson would be taking a leave of absence due to mental health issues but would return by August 3, 2022. However, in early August 2022, the client was informed via text message that Jackson was leaving the practice of law indefinitely, which resulted in the client having to suddenly and unexpectedly find new counsel. During this time, Jackson blocked further communication with the client. Jackson states that he regrets not informing the client of his departure from the practice of law in a proper manner and for blocking further communication with her.
SDBD No. 7853: The client retained Jackson in April 2022 to represent her in a custody dispute and paid him a $2,500 retainer. A hearing was scheduled for May 3, 2022, but the day before the hearing, Jackson filed the emergency leave of absence and informed the client that the hearing would be rescheduled. After Jackson's 90-day leave of absence expired in early August, the client tried to contact him. On August 18, 2022, Jackson texted the client informing her that he could no longer represent her and that a hearing was scheduled for August 23, 2022. The court ultimately delayed the hearing until October 6, 2022, in order to give the client time to find new counsel. However, Jackson failed to ensure that a formal motion to withdraw was filed. To Jackson's knowledge, the client proceeded pro se at the hearing and for the remainder of the matter. A final order was granted in the case in November 2022. Jackson states that he regrets his sudden withdrawal and poor communication, that he was not able to refund the client sooner, and the inconvenience he caused the court system and the other parties in having to reschedule the hearing. Further, Jackson admits that his late withdrawal may have prejudiced the case. The client was fully refunded on June 9, 2023.
SDBD No. 7854: On December 10, 2021, the client hired Jackson to represent him in a child support matter and paid him a $3,000 retainer. Jackson filed an entry of appearance that same day and attended a hearing in March 2022. In April 2022, the court entered a consent temporary order setting the client's monthly child support obligations at $800 and requiring him to pay a past-due lump sum of $1,500 and complete a hair follicle drug test. On May 4, 2022, Jackson filed his emergency leave of absence in this case. On May 10, 2022, opposing counsel filed a motion for contempt, alleging that the client failed to comply with the order. The court initially scheduled a hearing on this motion for June 14, 2022, but delayed it until August 8, 2022, to accommodate Jackson's emergency leave of absence. On August 2, 2022, Jackson informed the court that he would not be returning to the practice of law and on August 8, 2022, the client failed to appear at the hearing. The court subsequently scheduled another hearing for August 25, 2022, at which the court granted Jackson's withdrawal from the case and held the client in contempt for failure to pay child support and to submit to the drug test. The client was incarcerated for five days until he paid $5,000 to the court. Jackson states that he “deeply regrets the distress that his late withdrawal and failure to properly communicate caused” his client and the trouble caused to the court and opposing counsel by having to reschedule the hearing. Jackson also regrets that he was unable to return to the client his unearned portion of the initial retainer sooner. However, on June 28, 2023, Jackson sent the client a check for $500, reflecting the return of the unearned portion of the initial retainer.
SDBD No. 7855: The client hired Jackson to represent her in a criminal matter in June 2021, paying Jackson a $5,000 fee. On May 9, 2022, Jackson filed his emergency medical leave in this case and on August 8, 2022, Jackson texted the client to inform her that he was no longer practicing law due to his mental health troubles. However, Jackson failed to file a motion to withdraw until January 30, 2023, such that the client was unable to obtain a public defender while Jackson was still her counsel of record. The client subsequently obtained new counsel and her case was disposed of on October 25, 2024. Although Jackson regrets that he could not refund the client sooner, on August 29, 2023, he sent the client a check for the entire $5,000.
SDBD No. 7856: In December 2021, the client paid Jackson $5,000 to represent her in a custody dispute. Jackson worked on the matter until he filed his emergency motion for leave on May 5, 2022. After that leave ended, Jackson did not return to the practice of law, but he failed to move to withdraw from the representation. As a result, his client appeared pro se at a hearing. On April 27, 2023, the trial court issued an order granting the opposing party primary custody. Jackson regrets how his failure to properly withdraw inconvenienced the court and prejudiced his client, potentially resulting in an adverse outcome that she otherwise would not have received. Although he regrets that he could not reimburse the client sooner, he sent her a check for $3,500 on July 25, 2023, reflecting the unearned portion of the retainer.
SDBD No. 7857: In September 2020, the client hired Jackson to represent her son in a felony drug trafficking case and a probation revocation and paid him $3,000. Jackson performed some work in the revocation matter, but the State had not yet sent him discovery in the drug trafficking case when he filed his notice of emergency leave of absence in May 2022. Jackson notified the client and her son of his decision not to return to the practice of law and gave them referrals to other attorneys. Eventually, a public defender was assigned to defend the son. Although Jackson believed that his work justified the $3,000 fee, in recognition of how abrupt his withdrawal was, Jackson offered the client $500 as a partial refund on June 26, 2023. However, the client never responded to any of Jackson's attempts at communication regarding the refund.
SDBD No. 7892: On February 10, 2021, the client hired Jackson to defend her in a criminal case, paying him $800. Jackson performed some work in the case until filing his emergency leave of absence on May 4, 2022. On July 14, 2022, the trial court set a pretrial conference for August 5, 2022. On August 2, 2022, Jackson emailed the client, informing her that he was no longer able to practice law and that she would need to retain a new attorney. However, subsequently, the prosecutor offered her a plea deal to a lesser charge, which he stated would be his offer regardless of whether she hired new counsel, and the client accepted this offer. Jackson states that he deeply regrets how this last-minute withdrawal left the client without counsel for the hearing. And while the prosecutor stated that the deal would have been the same regardless, Jackson acknowledges that it remains possible that his actions prejudiced the client and could have led to worse consequences. Although he regrets that he failed to respond to the client's initial inquiries about her refund, he gave her a complete refund on June 6, 2024.
2. Admitted Rule Violations
Based on the conduct described above, Jackson admits that he violated Rule 1.1 1 by not providing competent representation to his clients during his mental health crisis; Rule 1.2 2 by failing to consult with his clients to ensure that they had a plan to obtain new counsel or otherwise continue to pursue their objectives once he withdrew his representation; Rule 1.3 3 by improperly withdrawing from representing his clients; Rule 1.4(a)4 by abruptly cutting off communications with his clients and blocking communications; Rule 1.16(a)5 because his ability to practice law was likely impaired before he withdrew from representation; Rule 1.16(c)6 due to his abrupt and immediate withdrawals; Rule 1.16(d)7 because his abrupt withdrawal provided insufficient notice to his clients and he did not take reasonable steps to protect his clients’ interests; and Rule 3.2 8 because his improper withdrawal led to unreasonable delays. Additionally, Jackson admits that Rule 4-104 9 is applicable, because his mental health had reached a point where he could no longer competently practice law.
3. ABA Standards
Regarding the framework set out in the ABA Standards for Imposing Lawyer Sanctions (1992) (“ABA Standards”),10 Jackson admits that he violated his duty of diligence and his duty owed as a professional; that his conduct was negligent due to his mental health crisis and not intentional attempts to harm his clients; and that his sudden withdrawals and poor communication injured his clients by causing them stress and potentially prejudicing them regarding their cases. As for aggravating factors, Jackson admitted that a pattern of misconduct and multiple offenses are applicable. See ABA Standard 9.22(c) and (d). As for mitigating factors, Jackson alleged that the following are applicable: absence of a disciplinary record; absence of a dishonest motive, personal or emotional problems; cooperative attitude towards disciplinary proceedings; inexperience in the practice of law; character or reputation; mental illness or addiction; imposition of other penalties or sanctions 11 ; and remorse. See ABA Standard 9.32(a), (b), (c), (e), (f), (g), (i), (k), and (l). Jackson provided some evidentiary support for his claimed mitigation involving personal or emotional problems and mental illness or addiction. Jackson included with his petition letters from his psychiatrist, his counselor, and from Dr. Matthew W. Norman, who evaluated Jackson in May 2025 at the Bar's request and found him fit to practice law. Those letters supported that Jackson's misconduct was caused by his declining mental health and that he has since sought treatment. In support of his character and reputation, Jackson included with his petition several letters of support from community members, attesting to his honesty, competency as an attorney, and commitment to his recovery.
4. Requested Discipline
Jackson requests a six-month suspension, nunc pro tunc to his voluntary cessation of the practice of law on October 20, 2023. In support of the nunc pro tunc request, Jackson included with his petition an affidavit, in which he states that he voluntarily stopped practicing law on October 20, 2023 “to focus on overcoming the personal health challenges that interfered with [his] ability to practice law” and resumed the practice of law in August 2025, several months after being declared fit to practice law by Dr. Norman. Along with his affidavit, Jackson attached the October 19, 2023, order entered in his final case, unrelated to any of the cases forming the basis of this matter, before his hiatus from the practice of law began.
5. Analysis
Having reviewed the record in this case—specifically the documentation provided by Jackson's psychiatrist, Jackson's counselor, and Dr. Norman—we agree that the imposition of a six-month suspension is appropriate under these circumstances and that such a sanction has been imposed in similar matters. See In the Matter of Kirby, 312 Ga. 341, 862 S.E.2d 550 (2021) (on petition for voluntary discipline, accepting attorney's request for a six-month suspension for his violations of Rules 1.2, 1.3, 1.4, and 1.16 in connection with four client matters where attorney abandoned his clients due to mental health challenges and where attorney submitted the report of a psychologist who found him to be fit to practice law); In the Matter of Johnson, 303 Ga. 795, 815 S.E.2d 55 (2018) (on petition for voluntary discipline, accepting attorney's request for a six-month suspension for his violations of Rules 1.3, 1.4, 1.5, 1.15(I), 1.16(d), and 5.5 in connection with six separate client matters where attorney—with a prior disciplinary offense and substantial experience in the practice of law—neglected his clients and stopped communicating with them due to emotional and personal problems but since refunded unearned fees to clients, lacked a dishonest or selfish motive, cooperated with disciplinary authorities, had a good reputation, and expressed remorse); In the Matter of Brantley, 299 Ga. 732, 735, 791 S.E.2d 783 (2016) (on report and recommendation of Special Master, imposing 180-day suspension for attorney's violations of Rules 1.3, 1.4, 1.15(c)(1), 1.16(d), 5.5(a), 8.1, and 9.3 in connection with five client matters where attorney with prior disciplinary history engaged in improper or incomplete communication with her clients and, in mitigation, attorney's violations were “the result of negligence as opposed to willful behavior[ ] and most arose at a time of great emotional stress and/or physical impairment”); In the Matter of Huggins, 291 Ga. 92, 93, 727 S.E.2d 500 (2012) (on petition for voluntary discipline, accepting attorney's request for a six-month suspension for his violations of Rules 1.3, 1.4, 1.15(I), 1.15(II), 1.16, and 9.3 in connection with five client matters where attorney had no prior disciplinary record, had a good reputation, and, at the time of the misconduct, was struggling with mental health issues and addiction “which impaired his judgment and effectiveness” and had since sought treatment).
Jackson has requested that his suspension be imposed nunc pro tunc to October 20, 2023, when he voluntarily stopped practicing law. When an attorney requests that discipline be imposed nunc pro tunc, it is his responsibility to show that he voluntarily stopped practicing law and the date on which he did so, and that he has complied with all ethical obligations involved in such a decision, such as helping clients secure new counsel and working to transfer the client's case to a new lawyer. See In the Matter of Onipede, 288 Ga. 156, 157, 702 S.E.2d 136 (2010). While Jackson has not complied with all ethical obligations arising from the cessation of his law practice, he has presented evidence that his noncompliance resulted, at least in substantial part, from his mental health crisis that he sought treatment for. This evidence, along with the other mitigating evidence above, leads us to conclude that nunc pro tunc suspension is appropriate. Therefore, we conclude that Jackson has made the required showing to have discipline imposed nunc pro tunc. We further note that because Jackson has sufficiently shown that he voluntarily stopped practicing law from October 2023 until August 2025, he has completed his suspension. See In the Matter of Matteson, 316 Ga. 879, 892 S.E.2d 27 (2023) (on petition for voluntary discipline, accepting attorney's request for a six-month suspension imposed nunc pro tunc where attorney voluntarily stopped practicing law from April 1, 2019 through September 30, 2019).
For these reasons, Jeffrey Jackson is hereby suspended from the practice of law for six months nunc pro tunc as of October 20, 2023, and he is hereby reinstated.
Petition for voluntary discipline accepted. Six-month suspension nunc pro tunc. Reinstated.
FOOTNOTES
1. Rule 1.1 provides that “[a] lawyer shall provide competent representation to a client.” The maximum sanction for a violation of this Rule is disbarment.
2. 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 ․ shall consult with the client as to the means by which they are to be pursued.” The maximum sanction for a violation of this Rule is disbarment.
3. Rule 1.3 provides, in pertinent part, that “[a] lawyer shall act with reasonable diligence and promptness in representing a client.” The maximum sanction for a violation of this Rule is disbarment.
4. 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.” The maximum sanction for a violation of this Rule is a public reprimand.
5. Rule 1.16(a) provides, in relevant part, that a lawyer shall withdraw from representation if “the lawyer's physical or mental condition materially impairs the lawyer's ability to represent the client.” The maximum sanction for a violation of this Rule is a public reprimand.
6. Rule 1.16(c) provides, in relevant part, that “[w]hen a lawyer withdraws it shall be done in compliance with applicable laws and rules.” The maximum sanction for a violation of this Rule is a public reprimand.
7. 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.” The maximum sanction for a violation of this Rule is a public reprimand.
8. Rule 3.2 provides that “[a] lawyer shall make reasonable efforts to expedite litigation consistent with the interests of the client.” The maximum sanction for a violation of this Rule is a public reprimand.
9. Rule 4-104 provides, in relevant part, that “[m]ental illness, cognitive impairment, alcohol abuse, or substance abuse, to the extent of impairing competency as a lawyer, shall constitute grounds for removing a lawyer from the practice of law.”
10. See ABA Standard 3.0 (when imposing a sanction, “a court should consider the following factors: (a) the duty violated; (b) the lawyer's mental state; (c) the potential or actual injury caused by the lawyer's misconduct; and (d) the existence of aggravating or mitigating factors”).
11. Jackson states that he voluntarily ceased the practice of law, foregoing a substantial amount of potential income for a period of 22 months. However, we decline to consider this factor in mitigation. See In the Matter of Tucker, 295 Ga. 357, 359, 759 S.E.2d 854 (2014) (Nahmias, J., concurring) (“[T]he ‘imposition of other penalties or sanctions’ mitigating circumstance[ ] ․ is properly interpreted, and has been interpreted by this Court, as applying only to other penalties arising during the disciplinary proceeding itself.”) (citations omitted).
Per Curiam.
All the Justices concur.
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Docket No: No. S26Y1385
Decided: October 14, 2026
Court: Supreme Court of Georgia.
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