311 Ga. 65
Ga.2021Background
- Supreme Court of Georgia disciplinary proceeding against attorney George Michael Plumides (State Bar No. 582274); Plumides was personally served but defaulted by failing to file a Notice of Rejection.
- Plumides admitted to the Bar in 1990 and previously received a Formal Letter of Admonition (2002) and a Confidential Reprimand (2019); prior discipline was used as aggravation.
- Defaulted allegations show a pattern of abandoning clients: missed calendar calls in multiple criminal matters (one led to a contempt arrest and five weeks in jail) and a missed traffic appearance that caused a client’s license/registration suspension.
- Financial misconduct: settled two personal-injury cases but failed to account and disburse proceeds to at least one client; failed to maintain client funds in an IOLTA account; attempted to pay filing fees with a check on an account lacking sufficient funds.
- Communication and process failures: failed to respond to clients’ requests, failed to timely respond to grievances and Notices of Investigation (one untimely, nonresponsive reply), and otherwise ignored disciplinary proceedings.
- The State Disciplinary Board found violations of Rules 1.1, 1.2(a), 1.3, 1.15(I)-(III), 8.4(a)(4), and 9.3; multiple ABA aggravating factors applied and no mitigation was found; the Court ordered disbarment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effect of default | Bar: Plumides’s default admits allegations and waives right to an evidentiary hearing | None — Plumides failed to respond | Default; allegations deemed admitted; hearing waived |
| Rule violations | Bar: Pattern of client abandonment, mishandling client funds, failures to communicate/investigate violated listed Rules | None — no defense submitted | Court agreed violations occurred (Rules 1.1, 1.2(a), 1.3, 1.15(I)-(III), 8.4(a)(4), 9.3) |
| Appropriate sanction | Bar: Disbarment warranted given severity, prior discipline, and pattern of misconduct | None | Disbarment imposed; name removed from bar rolls |
| Aggravating/mitigating factors | Bar: Multiple aggravators (prior offenses, dishonest/selfish motive, pattern, multiple offenses, refusal to acknowledge wrongdoing, vulnerable victims, substantial experience, indifference to restitution); no mitigation | None | Court found the aggravators applicable and no mitigating factors; aggravated sanction supported |
Key Cases Cited
- In the Matter of Morse, 266 Ga. 652 (1996) (endorsing use of ABA Standards in lawyer-discipline sanctions)
- In the Matter of Rambeau, 302 Ga. 367 (2017) (disbarment for pattern of abandoning clients and misusing client funds)
- In the Matter of Gibson, 297 Ga. 44 (2015) (disbarment where attorney abandoned clients and failed to respond in disciplinary proceedings)
