Inquiry Concerning Judge Jadawnya Baker
S20Z1070
| Ga. | Mar 8, 2022Background
- JaDawnya Baker, appointed Municipal Court of Atlanta judge in 2015, faced JQC investigation after complaints; Director filed formal charges and reached a discipline-by-consent agreement with Baker.
- The agreement admitted that between 2015–2020 Baker periodically dismissed criminal cases presented for guilty pleas when dissatisfied with the prosecutor’s factual basis rather than rejecting pleas.
- Baker also admitted that court security officers and chambers staff occasionally ran personal errands for her (e.g., delivering alcohol, moving a chair, bringing robes home), and that staff contributed to a shared office fund for food and supplies.
- She acknowledged contacting the City Solicitor to give feedback and request reassignment of prosecutors to her courtroom on occasion.
- The JQC Hearing Panel approved a consent disposition recommending a public reprimand; the Supreme Court of Georgia approved the public reprimand based primarily on the improper dismissals, while expressing reservations about whether other counts constituted Code violations.
Issues
| Issue | Director's Argument | Baker's Argument | Held |
|---|---|---|---|
| Personal tasks by security officers/staff (Counts 1–12) | Use of court employees to run personal errands and tasks violated Rules 1.2(A) and 1.3 (undermines integrity and lends prestige). | Assistance was occasional, may have occurred off-duty or voluntarily; disputed facts; not clearly coercive or interfering with duties. | Court expressed hesitation to find a violation on these facts and did not rely on these counts to impose discipline. |
| Office fund and staff contributions (Counts 1–12) | Maintaining a common fund and asking staff to shop or return items improperly used office resources and prestige. | Fund was small, mutual (judge contributed), customary; no authority showing it violates the Code. | Court found no cited authority to treat this as a violation and declined to base discipline on it. |
| Periodic dismissals of guilty-plea cases (Counts 13–15) | Dismissing charges because the prosecutor’s factual recitation was unsatisfactory violated Rule 1.1 and Rule 2.5(A); legal error inconsistent with established law. | Baker acknowledged error and admitted she should have rejected pleas rather than dismissing; mitigation offered. | Court held Baker violated Rules 1.1, 1.2(A), and 2.5(A) for periodically dismissing guilty-plea cases; public reprimand imposed. |
| Communications with City Solicitor (Count 16) | Repeatedly contacting Solicitor to criticize or request reassignment of prosecutors was improper meddling in personnel decisions under Rule 1.2(A). | Baker provided feedback but did not threaten adverse action or condition cases on personnel moves. | Court found no authority to conclude these communications violated Rule 1.2(A) on the record and did not base discipline on this count. |
Key Cases Cited
- Gentry v. Judicial Conduct Commission, 612 S.W.3d 832 (Ky. 2020) (personal tasks performed for judges during work hours relevant to misconduct inquiry)
- In re Brennan, 929 N.W.2d 290 (Mich. 2019) (addressing misuse of court personnel for personal tasks)
- State v. Benton, 305 Ga. App. 332 (2010) (trial court may reject guilty plea for lack of factual basis but dismissing on that ground is error)
- Inquiry Concerning Judge Anderson, 304 Ga. 165 (2018) (precedent on accepting consent discipline and scope of review)
- In re Judicial Qualifications Commission Formal Advisory Opinion No. 239, 300 Ga. 291 (2016) (legal error can constitute judicial misconduct when contrary to clear law)