In re Iwu, 301 Ga. 52

Iwu admitted practicing law in Georgia while not in good standing due to non-payment of annual dues since September 1, 2013, while filing an answer and counterclaim in Fulton County magistrate court on August 20, 2014.
Iwu has been a Georgia Bar member since 2006 and was administratively suspended for non-payment of dues; he was not eligible to practice during the relevant period.
Iwu violated Rule 5.5(a) by filing the pleadings while not in good standing and admitted making false statements in response to the formal complaint regarding suspension.
Iwu sincerely regrets the violations, apologizes, and asserts remorse; he also notes Tennessee disciplinary action (Public Censure) for the same incident as mitigating context.
The special master recommended a public reprimand under Bar Rule 4-102(b)(3); the Bar supported a public reprimand; the Court rejected the petition for voluntary discipline and indicated harsher discipline may be appropriate.
At filing, Iwu had not paid his annual membership fee for over three years, and the Court emphasized deceit and intent as aggravating factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Iwu violate Rule 5.5(a) by practicing law while not in good standing?	Bar contends he violated Rule 5.5(a) by filing while suspended.	Iwu admits the conduct and asserts remorse, with mitigation.	Yes; Iwu violated Rule 5.5(a) by practicing while not in good standing.
Should deceit in responses to the formal complaint be aggravating in discipline?	Bar relies on deceptive statements as aggravation.	Iwu expresses remorse and disputes heightened accountability beyond admission.	Court treats deceit as aggravating, supporting a more severe discipline than a mild sanction.
Is a public reprimand appropriate discipline for this conduct?	Bar and special master favor public reprimand.	Iwu seeks voluntary discipline (public reprimand under 4-102).	Petition for voluntary discipline rejected; harsher discipline deemed appropriate.

In the Matter of Burgess, 293 Ga. 783 (2013) (considerations for discipline where facts extend beyond negligence)
In the Matter of Levy, 284 Ga. 281 (2008) (discipline standards for misconduct by a lawyer)
In the Matter of Morse, 266 Ga. 652 (1996) (standard for disciplinary standards comparison)
In the Matter of Cummings, 291 Ga. 654 (2012) (deceit under Rule 8.4(a)(4) considered in aggravation)