In the Matter of David Thomas Dorer, 304 Ga. 442

David Thomas Dorer, a Georgia lawyer since 2012, petitioned for voluntary discipline after pleading guilty to a misdemeanor for failing to confirm a signer’s identity in a notarization (OCGA § 45-17-8(e)).
The underlying matter involved Dorer preparing a verified answer in a forfeiture proceeding and signing the client’s verification; his assistant notarized the signature.
Dorer admitted he signed the verification and pled guilty to the misdemeanor but maintained he had the client’s permission and sought a Review Panel reprimand for a Rule 8.4(a)(4) violation (dishonesty, fraud, deceit, or misrepresentation).
The State Bar agreed a Review Panel reprimand was appropriate, treating the misconduct as a Rule 8.4(a)(4) violation and citing similar precedents.
The Supreme Court majority rejected the petition because the petition’s factual admissions were too sparse to establish dishonesty, fraud, deceit, or misrepresentation necessary for Rule 8.4(a)(4), and it declined to infer lack of client permission or moral turpitude from the misdemeanor plea alone.
Chief Justice Melton dissented, arguing the admissions and precedent supported a violation of Rule 8.4(a)(4) and that a Review Panel reprimand was appropriate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether petitioned conduct violated Rule 8.4(a)(4) (dishonesty/fraud)	State Bar: conduct shows dishonesty and warrants reprimand	Dorer: signed with client’s express permission and notation disclosed signature; no deceit	Rejected — petition lacks sufficient factual admissions to establish dishonesty/fraud for Rule 8.4(a)(4)
Whether misdemeanor plea proves Rule 8.4(a)(3) (crime involving moral turpitude)	State Bar: unclear but implied possible applicability	Dorer: plea was to a misdemeanor not involving moral turpitude; he sought only Rule 8.4(a)(4) discipline	Court refused to infer moral-turpitude or fitness-to-practice issue from plea absent clearer facts
Whether voluntary-discipline petition should be accepted without fuller record	State Bar & Dorer: accept petition and impose Review Panel reprimand per precedent	Majority: petition too sparse; cannot responsibly impose sanction for serious charge without fuller facts	Petition for voluntary discipline rejected; fuller factual record required
Appropriate sanction if violation established	Dorer & State Bar: Review Panel reprimand (citing analogous cases)	Majority: would not reach sanction question because violation not established	If violation proved, precedent indicates Review Panel reprimand has been used; but court did not accept petition here

In the Matter of Davis, 291 Ga. 169 (Review Panel reprimand for falsifying client signatures and notarizations)
In the Matter of West, 301 Ga. 901 (Review Panel reprimand for signing client’s name on asylum application without intent to deceive)
In the Matter of Swain, 290 Ga. 678 (public reprimand for notarizing signature executed outside signer’s presence)
In the Matter of Braziel, 303 Ga. 154 (rejecting voluntary-discipline petition where underlying facts were uncertain)
In the Matter of Ellis, 296 Ga. 83 (reprimand for failing to supervise an employee who signed client’s name without authorization)
In the Matter of Nicholson, 299 Ga. 737 (discussing severity of Rule 8.4(a)(4) and disbarment risk)
In the Matter of Youn, 300 Ga. 134 (contrast where voluntary discipline for Rule 8.4(a)(3) accepted)