On Wednesday, January 17, 2024, the Supreme Court of Georgia rejected the discipline recommendations and sent attorney Christopher Ryan Breault’s case back to the State Disciplinary Review Board.
The case is entitled “In the Matter of Christopher Ryan Breault,” with case no. S23Y0807.
Breault faced allegations of professional misconduct related to his representation of clients in a personal injury lawsuit filed in federal district court in 2017. The underlying conduct led the district court to hold a disciplinary hearing in October 2017 and revoke Breault’s pro hac vice admission for that case. The district court referred the matter to the State Bar of Georgia, which initiated a formal disciplinary process against Breault. In January 2019, the State Disciplinary Board found probable cause to file a complaint against Breault for violating Rules of the Georgia Rules of Professional Conduct.
A Special Master was appointed to hear the case and issue a recommendation. After an evidentiary hearing in March 2022, the Special Master submitted a report in October 2022. He concluded Breault had violated Rules 1.6, 1.16, and 3.5 based on his disclosures of privileged client information without consent and failure to timely withdraw from representation after being terminated. The Special Master recommended Breault receive a one-month suspension. However, he did not fully analyze Breault’s conduct under the framework of the American Bar Association Standards for Imposing Lawyer Sanctions. These standards guide the appropriate sanction based on the lawyer’s duties violated, mental state, and harm caused.
In March 2023, the State Disciplinary Review Board adopted the Special Master’s findings and recommendation. Breault sought Supreme Court review. In its January 17, 2024, decision, the Supreme Court rejected the recommendations, finding the Special Master did not adequately apply the ABA Standards analysis. The Court remanded the case back to the Review Board with direction to send it to a new Special Master. The new Special Master must conduct a full analysis of Breault’s conduct under the ABA Standards framework and issue a new discipline recommendation consistent with the Court’s opinion.
By remanding the case, the Supreme Court declined to currently determine the appropriate sanction for Breault’s conduct or rule on the alleged rule violations at this stage. The order indicates further fact-finding and analysis are needed before the Court will make a final ruling in the high-profile disciplinary matter. It remains to be seen what discipline, if any, Breault may ultimately receive for his alleged misconduct.
According to avvo.com, Mr. Breault is a car accident attorney in Columbus, Georgia. He attended the University of Georgia School of Law, graduating in 2012. He acquired his law license in Georgia in 2013.
A copy of the original filing can be found here.