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In the Matter of Stephen Anthony Power

2022-08-23

Summary

Holding. The Court affirmed the recommendation for disbarment and removed Stephen Anthony Power from the rolls of persons authorized to practice law in Georgia.

Stephen Anthony Power, a Georgia attorney admitted in 2009, failed to respond to disciplinary notices served upon him by publication after personal service attempts were unsuccessful. By failing to file a Notice of Rejection, Power defaulted in the disciplinary proceeding and admitted the factual allegations against him. The admitted facts established that Power engaged in a pattern of misconduct across three matters: he retained client funds totaling over $4,200 without performing promised legal services or responding to client communications, failed to file a petition after accepting a flat fee and having his client sign verification documents, and maintained an overdrawn trust account without responding to State Bar inquiries.

Power's conduct violated multiple Georgia Rules of Professional Conduct governing scope of representation, diligence, communication, fees, and trust account management. The State Disciplinary Board found probable cause for violations and recommended disbarment. The Georgia Supreme Court determined that disbarment was the appropriate sanction, noting the seriousness of client abandonment, trust account violations, and Power's intentional failure to comply with bar rules through non-responsiveness.

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

Key issues

  • Service of disciplinary notice by publication and consequences of default
  • Client abandonment and failure to perform contracted legal services
  • Mishandling of client funds and trust account violations
  • Attorney non-responsiveness to clients and bar inquiries

Procedural posture

The case came before the Georgia Supreme Court on a Notice of Discipline recommending disbarment, with Power in default after failing to respond to notice served by publication.

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 23, 2022

S22Y0536. IN THE MATTER OF STEPHEN ANTHONY POWER.

PER CURIAM.

This disciplinary matter is before the Court on a Notice of

Discipline (“Notice”), recommending the disbarment of Stephen

Anthony Power1 (State Bar No. 600565) in connection with three

matters set out in State Disciplinary Board Docket (“SDBD”) Nos.

7532, 7533, and 7534. After the State Bar requested that Power

acknowledge service of the Notice and he failed to respond, the State

Bar made several attempts to personally serve Power at the address

on record with the State Bar, but was unable to perfect personal

service. The State Bar then properly served Power by publication

Power was admitted to the State Bar in 2009 and was administratively

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suspended on July 2, 2021 for nonpayment of license fees. Power is also

deficient in Continuing Legal Education credits.

pursuant to Bar Rule 4-203.1 (b) (3) (ii), but Power failed to file a

Notice of Rejection. Therefore, he is in default, has waived his right

to an evidentiary hearing, and is subject to such discipline and

further proceedings as may be determined by this Court. See Bar

Rule 4-208.1 (b).

The facts, as deemed admitted by Power’s default, are as

follows:

In connection with SDBD No. 7532, in May 2018, a client

retained Power to represent him in a divorce proceeding and paid

Power $1,258. However, Power never performed any legal services

in the matter, failed to respond to his client’s requests for

information, failed to respond when his client terminated the

representation in October 2019, and failed to refund the fee.

In connection with SDBD No. 7533, in July 2019, a client

retained Power to represent him in a child custody modification

action. After the client’s former spouse declined to consent to

modification, Power advised his client to file a contested petition for

modification. Power’s client executed a legal services contract for

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the representation and paid Power a $3,000 flat fee. Power

performed some work on the matter in the fall of 2019. However,

after Power had his client sign a verification form on November 9,

2019 to accompany the petition and indicated that the petition

would be filed, Power never filed the petition. Power also failed to

communicate with his client again or respond to any of his client’s

repeated communications seeking information about the status of

the matter.

In connection with SDBD No. 7534, in April 2020, the State

Bar received notification that Power’s trust account was overdrawn

by $1,500, and in May 2020, the State Bar received notification of

an additional overdraft of $3,000. Power did not respond to any of

the State Bar’s inquiries about the overdrafts.

In connection with each of the above matters, Power failed to

acknowledge service of the Notices of Investigation. Additionally,

Power failed to file sworn, written responses to the Notices as

required by Bar Rule 4-204.3 after Power was served by publication

when personal service could not be completed.

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Based on these facts, the State Disciplinary Board found

probable cause to believe that Power violated Rules 1.2 (a), 1.3, 1.4,

1.5 (a), 1.15 (I), 1.15 (II), 1.15 (III), 1.16 (d), and 9.3 of the Georgia

Rules of Professional Conduct found in Bar Rule 4-102 (d). The

maximum sanction for a violation of Rules 1.2, 1.3, 1.15 (I), 1.15 (II),

and 1.15 (III) is disbarment, and the maximum sanction for a

violation of Rules 1.4, 1.5, 1.16, and 9.3 is a public reprimand.

The Board considered as aggravating factors Power’s 12 years

of practice, his “repetitive pattern of misconduct” in the above

matters, and his intentional failure to comply with Bar Rules as

demonstrated by his failure to respond to the State Bar and his

clients and his failure to keep his contact information with the State

Bar up to date; the Board considered as a mitigating factor Power’s

lack of a prior disciplinary history. See ABA Standards for Imposing

Sanctions 9.32 (c), (i) and 9.33 (a); In the Matter of Morse, 266 Ga.

652, 653 (470 SE2d 232) (1996) (stating that this Court looks to the

ABA Standards for guidance in determining appropriate

disciplinary sanction).

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Having reviewed the record, we conclude that disbarment is

the appropriate sanction in this matter and is consistent with

similar cases in which a lawyer abandons clients, violates the rules

related to trust accounts, and defaults during the disciplinary

process. See, e.g., In the Matter of Proctor, 313 Ga. 637 (872 SE2d

691) (2022) (disbarring attorney who defaulted under notice of

discipline for abandonment of three clients and violations of trust

account rules); In the Matter of Plumides, 311 Ga. 65 (855 SE2d 651)

(2021) (disbarring attorney who defaulted under notice of discipline

and who engaged in pattern of abandoning clients and violating

trust account rules). Accordingly, it is hereby ordered that the name

of Stephen Anthony Power be removed from the rolls of persons

authorized to practice law in the State of Georgia. Power is

reminded of his duties pursuant to Bar Rule 4-219 (b).

Disbarred. All the Justices concur.

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