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Inquiry Concerning Judge Gerald Johnson

2023-08-16

Summary

Holding. The case is dismissed as moot because the Director's request for removal from office cannot be granted after the respondent resigned from judicial office.

In October 2021, Judge Gerald Johnson pointed a loaded AR-15 rifle at a sheriff's deputy who came to his home during an investigation. Johnson was intoxicated, visibly unstable, and admitted to firing the weapon from his porch that evening. A Hearing Panel of the Judicial Qualifications Commission found that Johnson violated rules requiring judges to act with integrity and maintain high standards of conduct, and recommended his removal from office as Chief Judge of Habersham County Magistrate Court.

However, Johnson resigned from his judicial position shortly after the Hearing Panel issued its recommendation, and the Governor accepted his resignation. Because removal from office is the only sanction the Commission sought, and Johnson no longer holds judicial office, the Georgia Supreme Court determined the case had become moot and could not proceed.

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

Key issues

  • Whether a court can remove a former judge from office after resignation
  • Mootness doctrine in judicial discipline proceedings
  • Standards of judicial conduct governing personal conduct outside official duties

Procedural posture

The Georgia Supreme Court reviewed the Judicial Qualifications Commission Hearing Panel's Report and Recommendation finding judicial misconduct and recommending removal, after the respondent resigned from office during the appellate stage.

Authorities cited

No cited authorities resolved to law.co cases yet.

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: August 16, 2023

S22Z0858. INQUIRY CONCERNING JUDGE GERALD

JOHNSON.

PER CURIAM.

This judicial discipline matter is before the Court on the Report

and Recommendation of the Hearing Panel of the Judicial

Qualifications Commission (“JQC”) and timely filed Notices of

Exceptions filed by the Director of the JQC and respondent Gerald

Johnson. The Hearing Panel recommended that Johnson be

removed from office for violating Rules 1.1, 1.2 (A), and 1.2 (B) of the

Georgia Code of Judicial Conduct (“CJC”). Johnson, however,

submitted his resignation to Governor Kemp shortly after the

Hearing Panel filed its Report and Recommendation. Removal from

office is the only sanction the JQC seeks, and we cannot remove a

former judge from an office he no longer holds. Accordingly, we

dismiss.

According to the formal charges, which Johnson admits are

true and correct, on the evening of October 18, 2021, the Habersham

County Sheriff’s Office received a call regarding multiple gunshots

fired in the residential area where Johnson lived. Travis Jarrell, the

Habersham County Sheriff’s Office lieutenant who responded to the

call, knew Johnson and knew that Johnson lived in the area, so he

went to Johnson’s house to ask Johnson whether he had any

information about the gunshots. After Jarrell rang Johnson’s

doorbell, Johnson opened the door and pointed a loaded AR-15 rifle

at Jarrell. Jarrell, who feared for his safety, fled to his patrol vehicle,

and Johnson dropped the rifle. Johnson then spoke with Jarrell but

told Jarrell he did not want their conversation to be recorded. As

Johnson and Jarrell spoke, Johnson called Jarrell by his first name

and several times asked Jarrell to turn off his recording device. Each

time, Jarrell informed Johnson he could not turn off the recording

device. Johnson, who was angry, visibly intoxicated, unstable on his

feet, and spoke with slurred speech, admitted to Jarrell that he had

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fired an AR-15 rifle from his porch that evening while intoxicated.

Eight days after the incident, Johnson told the JQC Chief

Investigator that the day of the incident was a “blur” because he had

been drinking excessively, but he remembered sitting in his chair

and hearing his wife’s “chatter,” which aggravated him and caused

him to “snap.” Johnson admitted he then went to the porch and fired

multiple rounds from the rifle into the ground, and when Jarrell

came to his house in a marked patrol vehicle, he answered the door

with the loaded rifle pointed at Jarrell’s head.

On October 28, 2021, the Investigative Panel filed a consent

motion suspending Johnson pending a final determination of the

JQC’s investigation. Johnson was suspended with pay by order of

this Court on October 29, 2021. On March 31, 2022, the Director

filed a four-count formal complaint against Johnson. Count 1 alleged

Johnson, in violation of Rule 1.2 (A), “failed to act in a manner that

promotes public confidence in the integrity of the judiciary.” Count

2 charged Johnson with a violation of Rule 1.2 (B) by failing “to

establish, maintain, and enforce high standards of conduct and

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personally observe such standards of conduct so the integrity of the

judiciary might be preserved[.]” Count 4 charged Johnson with

failing to respect and comply with the law in violation of Rule 1.11

A formal hearing on the charges against Johnson was held on

November 16, 2022. On January 6, 2023, the Hearing Panel

submitted to this Court its Report and Recommendation in which it

concluded that the Director had proved Counts 1, 2, and 4 by clear

and convincing evidence. Although the Hearing Panel acknowledged

in its Report that all proven misconduct attributed to Johnson was

personal in that it did not occur when Johnson was exercising his

official responsibilities, it concluded that Johnson had “brought the

judicial office into disrepute with his actions,” and “restoring

Johnson to the bench would not ‘respect and honor the judicial office

1 Count 3 of the Formal Complaint charged Johnson with violation of

Rule 1.3 of the CJC by lending the prestige of his office to advance his own

private interests by requesting that a law enforcement officer turn off his

recording device. Rule 1.3 provides: “Judges shall not lend the prestige of their

office to advance the private interests of the judge or others.” Count 3 was

dismissed by the Director prior to the hearing and was not considered by the

Hearing Panel.

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as a public trust,’ nor would it ‘enhance and maintain confidence in

our legal system.’” The Hearing Panel thus issued its

recommendation that Johnson be removed from his position as Chief

Judge of the Magistrate Court of Habersham County. Five days

later, Johnson submitted, and Governor Brian Kemp subsequently

accepted, his letter of resignation.

The matter is now before this Court, where Johnson asserts

that the Hearing Panel made several errors in its findings and

conclusions, and the Director argues that Johnson should be

“removed” from office pursuant to this Court’s authority under

Article VI, Section VII, Paragraph VII (a) of the Georgia

Constitution of 1983 to discipline judges.2 It is unnecessary to

2 One argument raised by the Director is that although Article VI,

Section VII, Paragraph VII (a) of the Georgia Constitution of 1983, the

provision that authorizes us to discipline judges, provides that a “judge may be

removed, suspended, or otherwise disciplined for willful misconduct”

(emphasis supplied), we have authority to discipline Johnson, who is now a

former judge, because JQC Rule 2 (B) (2) grants us “continuing jurisdiction

over former judges.” We need not, and do not, address this argument here

because the Director’s request that Johnson be removed from office was

rendered moot by Johnson’s resignation. See generally Inquiry Concerning

Judge Coomer, 315 Ga. 841, 850 (885 SE2d 738) (2023) (“The [CJC] repeatedly

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address the arguments of either party, however, because once

Johnson’s resignation was accepted by the Governor, the Director’s

request that this Court remove Johnson from office3 became moot.4

See OCGA § 5-6-48 (b) (3) (An appeal shall be dismissed “[w]here the

makes clear that it governs the conduct of only judges and ‘judicial

candidates[.]’”); Inquiry Concerning Judge Crawford, 310 Ga. 403, 405 (851

SE2d 572) (2020) (concluding it was unnecessary to determine whether the

evidence was sufficient to support the Hearing Panel’s conclusions because the

judge resigned from office after the Hearing Panel issued its Report and

Recommendation).

3 The Director’s request that Johnson be “removed,” even though he no

longer holds a judicial position, appears to derive from the Director’s interest

in preventing Johnson from seeking appointment or election to another judicial

position for at least seven years, as well as the Director’s assertion that the

timing of Johnson’s resignation allows Johnson to “circumvent the judicial

disciplinary process.” See OCGA § 15-1-13 (a) (“[I]f a person has been removed

from any judicial office upon order of the Supreme Court after review, that

person shall not be eligible to be elected or appointed to any judicial office in

this state until seven years have elapsed from the time of such removal.”).

4 The attorney discipline process is notably different in this regard. In

bar discipline matters, lawyers who are the subject of pending disciplinary

proceedings generally cannot resign from membership in the bar without the

approval of this Court. See Bar Rule 1-208 (d) (“No petition for leave to resign

shall be accepted if there are disciplinary proceedings or criminal charges

pending against the member, or if the member is not in good standing for

failure to pay child support obligations[.]”). We are able to impose this rule in

attorney discipline matters because we have exclusive authority to supervise

and regulate the practice of law. By contrast, we have no control over the

circumstances in which public officers, including judges, vacate their office.

That process is controlled by the General Assembly through statute. See

generally OCGA § 45-5-1 et seq., especially § 45-5-1 (a) (2) (“All offices in the

state shall be vacated . . . [b]y resignation, when accepted”).

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questions presented have become moot.”); Scarbrough Group v.

Worley, 290 Ga. 234, 236 (719 SE2d 430) (2011) (“A case is moot

when its resolution would amount to the determination of an

abstract question not arising upon existing facts or rights.”)

(citations, punctuation, and emphasis omitted). This matter is,

therefore, dismissed.5

Dismissed. All the Justices concur, except Colvin, J., not

participating.

5 Our dismissal is without prejudice to the JQC reinstating charges

against Johnson in the event he becomes a judge or judicial candidate in the

future. This Court is not aware of any applicable statute of limitation or

doctrine of estoppel that would prevent the JQC from revisiting any of the

misconduct alleged in Counts 1, 2, or 4 of the Formal Complaint should

Johnson again become a judge or judicial candidate because there has not been

a final disposition of those charges on the merits.

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