In the Matter of Johnbull Okechukwu Nwosu
S25Y0715
| Ga. | May 28, 2025Background
- Johnbull Okechukwu Nwosu, a member of the Georgia Bar since 2014, was charged with multiple violations of the Georgia Rules of Professional Conduct for knowingly altering and submitting false evidence in a court proceeding.
- In a 2021 business dispute, Nwosu submitted undated contract exhibits to a court, hand-writing different dates on each version to affect the statute of limitations.
- The discrepancies were exposed during a hearing, at which point Nwosu admitted to modifying the documents but claimed ignorance and negligence, instead of willful misconduct.
- The Special Master, after an evidentiary hearing, found Nwosu acted intentionally to deceive the court and recommended disbarment, citing significant harm to the profession and public trust.
- The State Disciplinary Review Board questioned the completeness of the Special Master’s analysis regarding mitigating and aggravating factors but did not challenge the factual findings.
- The Supreme Court of Georgia affirmed the findings of intentional deceit and ordered Nwosu’s disbarment, rejecting his arguments regarding intent and mitigation.
Issues
| Issue | Nwosu's Argument | State Bar's Argument | Held |
|---|---|---|---|
| Completeness of ABA Standards analysis | Special Master did not consider all mitigating factors | Special Master made sufficient findings on aggravating/mitigating factors | Special Master’s analysis was sufficient; remand not required |
| Intent required for Rule violations | "Knowingly" requires intent to deceive | "Knowingly" only requires actual knowledge, not specific intent | Knowledge of falsity suffices; intent to deceive not required |
| Appropriateness of sanction (disbarment) | Conduct was due to ignorance/negligence, not willful; reprimand | Intentional deceit to mislead the court warrants disbarment | Disbarment is appropriate given the intentional misconduct |
| Consideration of additional mitigation | Should factor in no prior discipline, remorse, inexperience | Record shows inexperience not credible, and remorse not established | Additional mitigation rejected, disbarment remains |
Key Cases Cited
- In the Matter of Dogan, 282 Ga. 783 (2007) (disbarment for falsifying documents to deceive courts)
- In the Matter of Koehler, 297 Ga. 794 (2015) (disbarment for deceitful, misleading statements in court)
- In the Matter of Jones-Lewis, 295 Ga. 861 (2014) (court upheld disbarment for false statements to court)
- In the Matter of Minsk, 296 Ga. 152 (2014) (disbarment for a pattern of knowingly false statements)
- In the Matter of Manning-Wallace, 291 Ga. 96 (2012) (disbarment for submitting forged documents and false statements)
- In the Matter of David-Vega, 318 Ga. 600 (2024) (disbarment for fabricated evidence, even with no prior record)