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In the Matter of Stephanie Dianne Woodard

2025-05-28

Summary

Holding. The petition for voluntary discipline was rejected without prejudice to allow Woodard to file a renewed petition seeking a sanction more consistent with applicable precedent.

Stephanie Dianne Woodard, a former Hall County Solicitor General, submitted a petition seeking voluntary discipline after being indicted on 24 felony counts of misconduct involving improper reimbursement requests totaling approximately $2,219. She subsequently entered a guilty plea to a single misdemeanor count involving violation of her duties as a public officer, a charge that establishes violations of professional conduct rules prohibiting dishonesty and fraud. Woodard requested a public reprimand and presented numerous mitigating factors, including her lack of disciplinary history, cooperation with authorities, timely restitution, and community service.

The Georgia Supreme Court declined to accept Woodard's petition, finding that a public reprimand was insufficient punishment for her conduct. The court emphasized that violations of the relevant professional conduct rule—particularly those involving dishonesty and fraud—represent serious breaches warranting more substantial sanctions. The court noted Woodard's position as a public official responsible for taxpayer funds and the need to maintain public confidence in the legal profession. The court identified her case as analogous to prior decisions imposing six-month to eighteen-month suspensions rather than cases warranting only public reprimands.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Appropriate sanction for attorney convicted of misdemeanor involving moral turpitude relating to misuse of public funds
  • Whether mitigating factors justify public reprimand versus suspension for Rule 8.4 violations
  • Heightened ethical obligations and sanctions for attorneys serving as public officials
  • Distinguishability of comparable disciplinary cases

Procedural posture

The case arose from a voluntary discipline petition filed by an attorney prior to a formal complaint, following her guilty plea to criminal charges arising from improper reimbursements while serving as a public official.

Authorities cited

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: May 28, 2025

S25Y0649. IN THE MATTER OF STEPHANIE DIANNE

WOODARD.

PER CURIAM.

This disciplinary matter is before the Court on the petition for

voluntary discipline filed by Stephanie Dianne Woodard (State Bar

No. 233695) prior to the filing of a Formal Complaint. See Bar Rule

4-227 (b). Woodard has been a member of the State Bar since 1996

and served as the Solicitor General of the Hall County State Court

for 15 years. In her petition, Woodard admits that, between July

2018 and September 2022, she received 11 improper

reimbursements from the Prosecuting Attorneys’ Council of Georgia

and Hall County and that she entered a guilty plea to one

misdemeanor count of a violation of OCGA § 45-11-4 (b) (1) (a public

officer may be criminally charged for malpractice, misfeasance, or

malfeasance in office) and (5) (a public officer may be criminally

charged for willfully and knowingly demanding more cost than she

is entitled to by law), which constitutes a violation of Rule 8.4 (a) (3)

and (4) of the Georgia Rules of Professional Conduct (“GRPC”),

found in Bar Rule 4-102 (d). The maximum sanction for a violation

of these Rules is disbarment. While acknowledging that her conduct

was a breach of her duty as a public official, Woodard asserts that

several mitigating factors are applicable and requests that the Court

impose a public reprimand for her Rule violations. In response, the

Bar states that Woodard’s request for a public reprimand is

appropriate but notes that the presumptive penalty for her

violations is a short suspension. Upon careful review, we decline to

accept Woodard’s petition for the reasons explained below.

In her petition, Woodard states that, on June 18, 2024, she was

indicted by a Hall County Grand Jury on 24 felony counts of criminal

misconduct, which was comprised of 13 counts involving alleged

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violations of OCGA § 16-10-201 and 11 counts involving alleged

violations of OCGA § 16-8-2.2 The 24 counts alleged that, on 11

occasions, Woodard—while serving as the Solicitor General of the

Hall County State Court—made requests and received

reimbursement for expenses which were not official expenses for

which she was entitled to reimbursement. Specifically, Counts 1-11

related to reimbursements from the Prosecuting Attorneys’ Council,

the circumstances of which Woodard contends she has “scant

1 OCGA § 16-10-20 provides that:

A person who knowingly and willfully falsifies, conceals, or covers

up by any trick, scheme, or device a material fact; makes a false,

fictitious, or fraudulent statement or representation; or makes or

uses any false writing or document, knowing the same to contain

any false, fictitious, or fraudulent statement or entry, in any

matter within the jurisdiction of any department or agency of state

government or of the government of any county, city, or other

political subdivision of this state shall, upon conviction thereof, be

punished by a fine of not more than $1,000.00 or by imprisonment

for not less than one nor more than five years, or both.

2 OCGA § 16-8-2 provides that:

A person commits the offense of theft by taking when he

unlawfully takes or, being in lawful possession thereof, unlawfully

appropriates any property of another with the intention of

depriving him of the property, regardless of the manner in which

the property is taken or appropriated.

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information,” but believes may have resulted because she

improperly sought reimbursement from both the Prosecuting

Attorneys’ Council and Hall County. Counts 12 and 13 related to an

improper charge for the cremation of a dog, which Woodard contends

was an inadvertent and improper charge. Counts 14 and 15 related

to cleaning supplies provided to someone Woodard was rehoming,

which she contends was a legitimate reimbursement request

pursuant to the Legal Victim Assistance Program and which

resulted in an indictment because of the State’s misunderstanding

of the Program. Counts 16 and 17 related to a meal at a restaurant,

which Woodard also contends was a legitimate reimbursement

request. Counts 18-223 related to an improper charge for an LSAT

prep course for Woodard’s daughter, which she contends happened

because someone on her staff saw the receipt and mistakenly

3 Woodard mistakenly states in her petition that only Counts 18-21 in

the indictment were related to the LSAT prep course, but Count 22 was also

related to the same reimbursement.

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pursued reimbursement. Counts 23 and 244 related to a pillow

purchased for Woodard’s son, which she contends happened because

she mistakenly used the wrong credit card. In total, the amount of

misappropriated funds was $2,219.28 (with $1,190.48 from the

Prosecuting Attorneys’ Council and $1,028.80 from Hall County).

Following the indictment, Woodard and the State began

negotiations and agreed that the matter would be best settled by a

nolle prosequi of the felony charges and Woodard entering a guilty

plea to one misdemeanor count of a violation of OCGA § 45-11-4 (b)

(1) and (5). According to Woodard, the State was concerned as to

whether there was sufficient evidence to prove scienter or intent, as

required for the indicted felony charges. Nevertheless, as Woodard

admitted that her conduct constituted a breach of her duty as a

public official, such that there was enough showing of criminal

culpability to sustain a misdemeanor conviction under OCGA § 45-11-4, she entered her guilty plea under the First Offender Act and

4 Similar to the previous mistake, Woodard inadvertently omits Count

24 in her description of the counts in her petition, but Counts 23 and 24 are

the correct counts related to the reimbursement for the pillow.

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received 12 months on probation, which was to be terminated upon

full and timely payment of restitution.5

Based on her conduct, Woodard admits to violating Rule 8.4 (a)

(3) (it shall be a violation of the GRPC for a lawyer to “be convicted

of a misdemeanor involving moral turpitude where the underlying

conduct relates to the lawyer’s fitness to practice law”) and (4) (it

shall be a violation of the GRPC for a lawyer to “engage in

professional conduct involving dishonesty, fraud, deceit, or

misrepresentation”). Further, relying on the ABA Standards for

Imposing Lawyer Sanctions (1992), Woodard offers in mitigation

that she has no disciplinary history; that she lacked a dishonest or

selfish motive; that she was experiencing personal or emotional

problems due to suffering from a physical ailment and the death of

a family member; that she made a timely good faith effort to make

restitution and rectify the consequences of her misconduct; that she

5 Because Woodard provided full restitution at the time of the plea, no

probation sentence was ever initiated. Further, because Woodard fully

complied with the Georgia First Offender Act, she is now exonerated and has

no criminal record.

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cooperated fully with the Georgia Bureau of Investigation and the

State Bar and is petitioning for voluntary discipline; that her

character and reputation are good, as she has volunteered her time

in many laudable activities for her community;6 that she was

suffering a physical disability; that she received additional penalties

and sanctions for her conduct, including negative public attention in

the media and her resignation from her position as Solicitor General;

and that she has expressed remorse for her misconduct. See ABA

Standard 9.32 (a), (b), (c), (d), (e), (g), (h), (k) & (l). Woodard also

notes in mitigation that the State and trial court recognized that her

conduct was more appropriately characterized as a misdemeanor, as

evident by the State agreeing to nolle prosequi all 24 felony counts

and accept the plea to one count of a misdemeanor, and the court

sentencing Woodard as a first offender for which she received a

sentence of probation. Woodard does not state any factors in

aggravation.

6 Woodard states that she has served as a member or in a leadership role

for several government entities and nonprofit organizations.

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In addressing the sanction to be imposed, Woodard requests a

public reprimand “instead of a harsher punishment” due to the

applicable mitigating factors and contends that this Court has

imposed public reprimands for similar Rule violations. Woodard

relies on In the Matter of Cherry, 305 Ga. 667 (827 SE2d 239)

(2019)—in which we accepted a petition for voluntary discipline

seeking public reprimand where the attorney admitted to violating

Rule 8.4 (a) (4) by sending a letter to an insurance company in which

she falsified a signature—and In the Matter of Davis, 306 Ga. 381

(830 SE2d 734) (2019)—in which we imposed a public reprimand

where the attorney violated Rule 8.4 (a) (4) by improperly notarizing

a signature that he did not witness.

In response, the State Bar recommends that this Court accept

Woodard’s petition for voluntary discipline seeking a public

reprimand, although it states that the presumptive penalty for

Woodard’s violations is a short suspension. Further, the State Bar

notes that it agrees that eight out of the nine mitigating factors

Woodard listed in her petition apply to her case; the State Bar does

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not address whether the absence of a dishonest or selfish motive was

applicable. Additionally, the State Bar found that two of the

aggravating factors listed in ABA Standard 9.22 are applicable—

substantial experience in the practice of law, and illegal conduct. See

ABA Standard 9.22 (i) and (k).

Although the State Bar supports Woodard’s request for a public

reprimand, we do not agree that a public reprimand for Woodard’s

violations of Rules 8.4 (a) (3) and (4) is sufficient as “a penalty to the

offender, a deterrent to others, and an indication to laymen that the

courts will maintain the ethics of the profession.” See In the Matter

of Dowdy, 247 Ga. 488, 493 (277 SE2d 36) (1981) (cleaned up). As an

initial matter, we have explained that “a violation of Rule 8.4 (a) (4)

is among the most serious violations with which a lawyer can be

charged.” In the Matter of West, 300 Ga. 777, 778 (798 SE2d 219)

(2017). We have also explained that for a Rule 8.4 (a) (3) violation

“either suspension or disbarment is an appropriate sanction,

depending on the circumstances.” In the Matter of Gardner, 286 Ga.

623, 624 (690 SE2d 611) (2010). Further, as a public official,

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Woodard was in a position of power and responsibility, and when

considering the appropriate sanction to impose “[t]his Court is . . .

concerned . . . about the public’s confidence in the profession.” In the

Matter of Blitch, 288 Ga. 690, 692 (706 SE2d 461) (2011). See also

In the Matter of Skandalakis, 279 Ga. 865, 867 (621 SE2d 750)

(2005) (noting in aggravation that the attorney’s misconduct “arose

out of his actions as an elected public official”).

Additionally, the two cases upon which Woodard relies to

support her request for a public reprimand—Cherry and Davis—are

easily distinguishable from the situation here, as these cases neither

involved a lawyer being convicted of a misdemeanor involving moral

turpitude nor a lawyer’s repeated misuse of government funds.

Rather, we conclude that this case is most similar to In the Matter

of Williams, 284 Ga. 96 (663 SE2d 181) (2008)—in which we

accepted the petition for voluntary discipline seeking a six-month

suspension for the violation of Rule 8.4 (a) (3) filed by an assistant

district attorney who “participated in a scheme initiated by his boss,

the then-District Attorney, to obtain from [the county] money to

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which the District Attorney was not entitled” and “pled guilty to a

single violation of OCGA § 45-11-5 (misdemeanor for a public officer

to receive money not due [to] him through the use of his office).” 284

Ga. at 96-97. See also In the Matter of Adams, 291 Ga. 768, 768 (732

SE2d 446) (2012) (imposing 18-month suspension where attorney

misrepresented the number of hours worked representing indigent

clients and overbilled the judicial circuit’s Indigent Defense

Program over $10,000). Because Woodard’s case is more akin to

cases which resulted in 6-month and 18-month suspensions than to

cases which resulted in a public reprimand, we are rejecting

Woodard’s petition without prejudice to allow her to file a renewed

petition seeking voluntary discipline more consistent with the cases

we cite as applicable.

We therefore reject the petition for voluntary discipline.

Petition for voluntary discipline rejected. Peterson, CJ, Warren,

PJ, and Bethel, Ellington, McMillian, LaGrua, Colvin, and Pinson,

JJ, concur.

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