Background
Brandon Andrew Cline had been a member of the Georgia Bar since 2003. The disciplinary matter arose from two distinct categories of misconduct. First, in 2021 and 2022, Cline obtained several loans, deposited the proceeds into his attorney trust account, and used those funds to pay personal and business expenses. He also transferred money from his business account to cover loan payments and authorized automatic debits to creditors from the trust account, resulting in numerous overdrafts. This conduct violated Rules 1.15(I)(a) and 1.15(II)(b) of the Georgia Rules of Professional Conduct, which govern the maintenance, holding, and disbursement of client and third-party funds.
Second, Cline abandoned a client who had retained him to contest a traffic citation. He failed to appear at a scheduled hearing, causing an arrest warrant to be issued against the client. After being notified of the warrant, Cline made only a couple of unsuccessful attempts to contact the court and then ceased all communication with the client. This conduct violated Rules 1.2(a), 1.3, 1.4(a), and 1.4(b), governing a lawyer’s duties of diligence, communication, and scope of representation.
Cline filed a petition for voluntary surrender of his law license, admitting to all of the foregoing violations. The State Bar supported acceptance of the petition, and Special Master Thomas E. Cauthorn III issued a report and recommendation that the Court accept it. Under Georgia Bar Rule 1.0(u), a voluntary surrender of license is tantamount to disbarment.
The Court’s Holding
The Supreme Court of Georgia, reviewing the record, agreed with the special master’s recommendation and accepted Cline’s petition for voluntary surrender of his license. The Court found acceptance to be in the best interests of the Bar and the public, and consistent with prior precedent. The Court cited In the Matter of Stuhler, 291 Ga. 660 (2012), which accepted a voluntary surrender involving similar trust account violations, as well as In the Matter of Arrington, 314 Ga. 696 (2022), and In the Matter of Jackson, 321 Ga. 256 (2025), both of which resulted in disbarment for analogous misconduct.
The Court ordered Cline’s name removed from the rolls of persons entitled to practice law in Georgia and reminded him of his obligations under Bar Rule 4-219(b), which governs an attorney’s duties following disbarment or suspension, including notifying clients and returning files. The decision was unanimous, with all justices concurring.
Key Takeaways
- Using a client trust account to deposit personal loan proceeds and pay personal or business expenses — even without directly stealing client funds — constitutes trust account misuse in violation of Rules 1.15(I)(a) and 1.15(II)(b) and can warrant disbarment.
- Failing to appear at a client hearing, causing an arrest warrant to issue, and then abandoning all communication with the client violates the core duties of diligence and communication under Rules 1.2(a), 1.3, 1.4(a), and 1.4(b).
- A voluntary surrender of license is treated as the equivalent of disbarment under Georgia Bar Rule 1.0(u) and carries the same consequences, including removal from the rolls of licensed attorneys.
- Georgia courts treat trust account misuse and client abandonment as serious offenses meriting the most severe sanction regardless of whether the attorney has a prior disciplinary history.
Why It Matters
This case reinforces the Georgia Supreme Court’s consistent and strict approach to trust account violations. Attorneys sometimes assume that misusing a trust account for personal purposes is less serious when no client funds are directly involved, but the Court’s precedent — including Stuhler, Arrington, and now Cline — makes clear that depositing personal loan proceeds and paying personal expenses through a trust account is itself a disbarring offense. The rules exist to preserve the integrity of a mechanism clients and third parties depend on.
The combination of trust account misconduct and client abandonment underscores that cumulative ethical failures across multiple rules and multiple clients will not be treated leniently. Practitioners should take note that even a voluntary surrender — which might appear to be a cooperative resolution — carries the full weight of disbarment, including the duties and stigma that follow under Bar Rule 4-219(b).