In re West, 301 Ga. 901

West admitted the same underlying facts as in prior petitions.
In 2014, an individual paid West $3,500 to represent her Guatemalan-son in an immigration matter; West prepared asylum papers.
West signed the client’s name on the asylum application and supporting documents, including a perjury-attestation, without the client’s signature in the client’s language.
West claimed he intended to supplement with the client’s real signature later and relied on anticipated amendments.
Prior petitions were rejected; the renewed petition sought a Review Panel reprimand for admitted violations of Rules 1.2(a) and 1.4, among others.
The Bar recommended a Review Panel reprimand, agreeing West did not prove a Rule 8.4(a)(4) intent element, and the court ultimately accepted a sanction of a Review Panel reprimand for admitted violations of Rules 1.2(a) and 1.4.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether West violated 1.2(a) and 1.4 based on admitted facts	West violated 1.2(a) and 1.4 by failing to adequately communicate and consult	Bar contends the admitted facts support 1.2(a) and 1.4 violations	Yes; violations established; sanctions appropriate for 1.2(a) and 1.4
Whether Rule 8.4(a)(4) was proven	West argues no intent to deceive; 8.4(4) not proven	Bar asserts 8.4(a)(4) could be proven	Not proven; court rejects finding of 8.4(a)(4) violation
Appropriate sanction for the admitted violations	West seeks Review Panel reprimand; mitigating factors support this	Bar agrees on reprimand but disputes severity	Review Panel reprimand appropriate; sanction for 1.2(a) and 1.4 established

In the Matter of Morse, 266 Ga. 652 (Ga. 1996) (ABA standards guide sanctions; suspension not automatic)
In the Matter of Woodham, 296 Ga. 618 (Ga. 2015) (8.4(a)(4) requires intent; evidentiary standard discussed)
In the Matter of Suttle, 288 Ga. 14 (Ga. 2010) (attendant considerations in discipline; honesty issues)
In the Matter of Davis, 291 Ga. 169 (Ga. 2012) (discusses aggravating factors in discipline)
In the Matter of Eddings, 300 Ga. 419 (Ga. 2016) (aggravation and mitigation in sanctions)