In the Matter of Jonnie Mae Graham, 306 Ga. 380

Johnnie Mae Graham (admitted 1981) was served with a Notice of Discipline seeking disbarment; she failed to acknowledge personal service and did not file a Notice of Rejection after service by publication, resulting in default.
Facts deemed admitted by default: Graham was retained in 2013 for a car-accident suit, filed suit in December 2013, then failed to communicate with the client despite repeated contacts.
Graham did not respond to a defendant motion to dismiss in August 2015 and failed to appear at an October 2015 hearing; the client’s case was dismissed for her failure to appear.
The State Disciplinary Board found she failed to perform work, abandoned the client’s matter to the client’s detriment, failed to return the client’s file, and failed to respond to the Bar’s investigative requests.
The Board concluded probable cause to believe Graham violated Georgia Rules of Professional Conduct Rules 1.3, 1.4, 1.16(d), and 3.2; aggravating factors included long experience and prior discipline (a 2013 Review Panel reprimand).
The Court, after review, ordered disbarment and removal of Graham’s name from the roll; all justices concurred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Graham’s failures warrant disciplinary sanctions	State Bar: Graham abandoned client, failed to communicate, failed to prosecute, failed to return file, and failed to cooperate with investigation — violations of Rules 1.3, 1.4, 1.16(d), 3.2	Graham defaulted and filed no response or defenses	Court found violations proven by default and disciplinary sanctions appropriate
Whether default service procedures were proper	State Bar followed Bar Rule 4-203.1(b)(3)(ii) (service by publication) after no acknowledgement; default rules then applied	No response from Graham to contest service or default	Service by publication and default procedures were valid; Graham was in default under Bar Rule 4-208.1(b)
Appropriate level of discipline for the violations	State Bar: Given abandonment, noncooperation, prior discipline, and experience, disbarment is appropriate (Rule 1.3 violation carries potential disbarment)	Graham offered no mitigating or contrary argument due to default	Court concluded disbarment appropriate and ordered removal from the rolls
Role of aggravating/mitigating factors in sanction	State Bar: Aggravation — extensive experience, prior reprimand; no mitigating evidence presented	No mitigating evidence from Graham because of default	Court relied on aggravation and precedent to impose disbarment

In the Matter of Mays, 303 Ga. 152 (2018) (illustrates disbarment imposed for comparable attorney misconduct)
In the Matter of Miller, 302 Ga. 366 (2017) (supports disbarment where lawyer abandoned representation and failed to participate in disciplinary process)
In the Matter of Graham, 292 Ga. 901 (2013) (prior disciplinary history: Review Panel reprimand)