IN RE: George R. KNOX (2026)

ATTORNEY DISCIPLINARY PROCEEDING

This disciplinary matter arises from formal charges filed by the Office of Disciplinary Counsel (“ODC”) against respondent, George R. Knox, an attorney licensed to practice law in Louisiana, but currently suspended from practice.

PRIOR DISCIPLINARY HISTORY

Before we address the current charges, we find it helpful to review respondent's prior disciplinary history. Respondent was admitted to the practice of law in Louisiana in 1991.

On December 21, 2023, we granted a petition for interim suspension filed jointly by respondent and the ODC. In re: Knox, 23-1675 (La. 12/21/23), 420 So. 3d 1. In the petition, the parties represented that two separate sets of formal charges were then pending against respondent, and that he wished “to cooperate with the ODC moving forward and be placed on interim suspension pending resolution of the formal charges.”

On February 6, 2024, we accepted a petition for consent discipline addressing respondent's misconduct in the pending formal charges. Respondent stipulated that he practiced law while ineligible to do so and failed to cooperate with the ODC's investigation of seven complaints. For this misconduct, which occurred between August 2022 and October 2023, we suspended respondent from the practice of law for one year and one day, retroactive to the date of his interim suspension. In re: Knox, 23-1674 (La. 2/6/24), 378 So. 3d 740 (“Knox I”). We further ordered in Knox I that prior to seeking reinstatement, respondent “shall comply with the conditions set forth in the petition for consent discipline,” namely that respondent submit to an evaluation facilitated by the Judges and Lawyers Assistance Program (“JLAP”) and comply with any recommendations made by JLAP.¹

Respondent has served the period of suspension imposed in Knox I; however, he has not filed a petition for reinstatement, and thus he remains suspended from the practice of law.

Against this backdrop, we now turn to consideration of the instant misconduct.

FORMAL CHARGES

In May 2019, Consandra Charles retained respondent to represent her in a child support and alimony matter. Ms. Charles paid respondent an advance fee of $5,000 for the representation. Thereafter, respondent failed to move the matter forward and failed to provide Ms. Charles with updates regarding her case. Ms. Charles went to respondent's office on several occasions in an attempt to meet with him, but his office was either closed or vacant. On the few occasions that she was able to contact him, respondent made promises to Ms. Charles, but he did not follow through with same.

On one occasion, respondent scheduled a meeting with the opposing party and his attorney, but because he failed to inform Ms. Charles of the date and time of the meeting, she did not attend and the meeting did not go forward, causing more delay. On another occasion, a conference was scheduled for both parties and their attorneys to discuss child support and alimony, but respondent did not show up.

Respondent's last court appearance in Ms. Charles’ legal matter took place on March 30, 2023, approximately nine months before he was placed on interim suspension. Ms. Charles asked respondent to refund the money she paid, to no avail.

In July 2024, Ms. Charles filed a complaint against respondent with the ODC. The ODC sent a copy of the complaint and a request for a reply to respondent's primary and preferred registered addresses with the Louisiana State Bar Association (“LSBA”), but the correspondence was returned as unable to forward. Another letter was sent to respondent at his LSBA secondary-registered address, but he failed to respond. The ODC sent respondent two emails to his LSBA-registered email address, but he did not respond to the first email, and delivery of the second was rejected.

DISCIPLINARY PROCEEDINGS

In May 2025, the ODC filed formal charges against respondent, alleging that his conduct as set forth above violated Rules 1.1(a) (failure to provide competent representation to a client), 1.1(c) (a lawyer is required to comply with all of the requirements of the Supreme Court's rules regarding annual registration, including timely notification of changes of address), 1.3 (failure to act with reasonable diligence and promptness in representing a client), 1.4(a)(2)(3)(4) (failure to communicate with a client), 1.5(f)(5) (failure to refund an unearned fee), and 8.1(c) (failure to cooperate with the ODC in its investigation) of the Rules of Professional Conduct.

Respondent failed to answer the formal charges. Accordingly, the factual allegations contained therein were deemed admitted and proven by clear and convincing evidence pursuant to Supreme Court Rule XIX, § 11(E)(3). No formal hearing was held, but the parties were given an opportunity to file with the hearing committee written arguments and documentary evidence on the issue of sanctions. Respondent filed nothing for the committee's consideration.

Hearing Committee Report

After reviewing the ODC's deemed admitted submission and the exhibits in the record, the hearing committee acknowledged that the factual allegations as set forth in the formal charges have been deemed admitted. Based on these facts, the committee determined that respondent violated the Rules of Professional Conduct as charged in the formal charges.

The committee determined respondent violated duties owed to his client, the public, and the legal profession. He acted knowingly, if not intentionally, causing actual harm to Ms. Charles in the form of delay in the resolution of her legal matter. His failure to cooperate with the ODC in its investigation caused actual harm to the disciplinary system. Based on the ABA's Standards for Imposing Lawyer Sanctions, the committee determined the baseline sanction is suspension.

The committee found the following aggravating factors are present: a prior disciplinary record,² a dishonest or selfish motive, a pattern of misconduct, multiple offenses, bad faith obstruction of the disciplinary process by intentionally failing to comply with rules or orders of the disciplinary agency, refusal to acknowledge the wrongful nature of the conduct, and substantial experience in the practice of law. The committee found no evidence of mitigating factors.

Turning to the issue of an appropriate sanction, the committee noted that the misconduct here occurred within the same time frame as the misconduct at issue in Knox I, and therefore, the discipline to be imposed should be determined as if both cases had been charged together.³ The committee determined that given the breadth and repeated nature of respondent's misconduct, the overall discipline to be imposed should be a lengthy period of actual suspension.

After further considering the court's prior jurisprudence addressing similar misconduct, the committee recommended that respondent be suspended from the practice of law for three years, retroactive to December 21, 2023, the date of his interim suspension. The committee also recommended that respondent be ordered to render an accounting and restitution of any unearned portion of the advanced deposit to Consandra Charles, as appropriate. The committee further recommended that respondent be assessed with the costs and expenses of this proceeding.

Neither respondent nor the ODC filed an objection to the committee's report and recommendation. Therefore, pursuant to Supreme Court Rule XIX, § 11(G), the disciplinary board submitted the committee's report directly to the court for review.

DISCUSSION

Bar disciplinary matters fall within the original jurisdiction of this court. La. Const. art. V, § 5(B). Consequently, we act as triers of fact and conduct an independent review of the record to determine whether the alleged misconduct has been proven by clear and convincing evidence. In re: Banks, 09-1212 (La. 10/2/09), 18 So. 3d 57.

In cases in which the lawyer does not answer the formal charges, the factual allegations of those charges are deemed admitted. Supreme Court Rule XIX, § 11(E)(3). Thus, the ODC bears no additional burden to prove the factual allegations contained in the formal charges after those charges have been deemed admitted. However, the language of § 11(E)(3) does not encompass legal conclusions that flow from the factual allegations. If the legal conclusion the ODC seeks to prove (i.e., a violation of a specific rule) is not readily apparent from the deemed admitted facts, additional evidence may need to be submitted in order to prove the legal conclusions that flow from the admitted factual allegations. In re: Donnan, 01-3058 (La. 1/10/03), 838 So. 2d 715.

The record in this deemed admitted matter supports a finding that respondent failed to provide competent representation to a client, failed to comply with his professional obligations, neglected a legal matter, failed to communicate with a client, failed to refund an unearned fee, and failed to cooperate with the ODC in its investigation. This conduct amounts to a violation of the Rules of Professional Conduct as charged.

Having found evidence of professional misconduct, we now turn to a determination of the appropriate sanction for respondent's actions. In determining a sanction, we are mindful that disciplinary proceedings are designed to maintain high standards of conduct, protect the public, preserve the integrity of the profession, and deter future misconduct. Louisiana State Bar Ass'n v. Reis, 513 So. 2d 1173 (La. 1987). The discipline to be imposed depends upon the facts of each case and the seriousness of the offenses involved considered in light of any aggravating and mitigating circumstances. Louisiana State Bar Ass'n v. Whittington, 459 So. 2d 520 (La. 1984).

Respondent violated duties owed to his client, the public, and the legal profession. He acted knowingly, and his conduct caused actual harm. Therefore, the baseline sanction is suspension. The aggravating factors found by the committee are supported by the record, and we agree that no mitigating factors are present.

We also agree with the committee that the approach set forth in Chatelain is applicable here. Respondent's current misconduct occurred during the same time frame as his misconduct in Knox I. Therefore, based upon our holding in Chatelain, the appropriate sanction would take into account respondent's combined misconduct from this matter as well as from Knox I. With the addition of the current misconduct, we believe a lengthier suspension is warranted.

Accordingly, we will adopt the hearing committee's recommendation and suspend respondent from the practice of law for three years, retroactive to December 21, 2023, the date of his interim suspension. We will also order respondent to render an accounting and restitution of any unearned portion of the advanced deposit to Consandra Charles, as appropriate.⁴

DECREE

Upon review of the findings and recommendation of the hearing committee, and considering the record, it is ordered that George R. Knox, Louisiana Bar Roll number 20594, be suspended from the practice of law for three years, retroactive to December 21, 2023, the date of his interim suspension. We further order respondent to provide an accounting and refund any unearned portion of the advanced deposit to Consandra Charles, as appropriate. All costs and expenses in the matter are assessed against respondent in accordance with Supreme Court Rule XIX, § 10.1, with legal interest to commence thirty days from the date of finality of this court's judgment until paid.

FOOTNOTES

1.   Respondent had informed the ODC that he suffered from depression, which he asserted had contributed to his failure to cooperate in the disciplinary investigations.

2.   In addition to his 2024 suspension in Knox I, respondent also has a 2019 diversion.

3.   In Louisiana State Bar Ass'n v. Chatelain, 573 So. 2d 470 (La. 1991), this court held that when a second disciplinary proceeding against an attorney involves misconduct which occurred during the same time period as the first proceeding, “the overall discipline to be imposed should be determined as if both proceedings were before the court simultaneously.”

4.   Should respondent wish to seek reinstatement in the future, he shall be required to demonstrate that he has provided the accounting and restitution to Ms. Charles and that he has complied with the conditions of Knox I.

PER CURIAM

McCallum, J., dissents and would reject the proposed discipline as too lenient.