The Georgia Supreme Court issued a per curiam opinion on Jan. 5, 2026, rejecting for the second time a voluntary discipline petition filed by attorney Stephanie Dianne Woodard. The court found that Woodard's proposed public reprimand continues to be inadequate punishment for her admitted violations of professional conduct rules.

This marks the second time the Georgia high court has declined to accept Woodard's proposed discipline. In the court's first opinion, *In the Matter of Woodard*, 321 Ga. 681 (2025), the justices rejected an initial petition for voluntary discipline filed by Woodard prior to any formal complaint being lodged against her.

Woodard, who holds State Bar Number 233695, admitted to violating two specific provisions of the Georgia Rules of Professional Conduct contained in Bar Rule 4-102(d). The violations include Rule 8.4(a)(3), which prohibits attorneys from being "convicted of a misdemeanor involving moral turpitude where the underlying conduct relates to the lawyer's fitness to practice law," and Rule 8.4(a)(4), which bars "professional conduct involving dishonesty, fraud, deceit or misrepresentation."

The professional misconduct stems from conduct that occurred between July 2018 and September 2022. During this period, Woodard engaged in behavior that led to her pleading guilty to one misdemeanor count of violating OCGA § 45-11-4(b)(1), which charges a public officer with "malpractice, misfeasance, or malfeasance in office." She also pleaded guilty to violating OCGA § 45-11-4(b)(5), which addresses public officers "willfully and knowingly demanding more cost than he or she is entitled to by law in the administration and under the color of his or her office."

The Georgia Supreme Court's rejection of Woodard's second petition indicates that the proposed public reprimand does not adequately address the severity of her admitted misconduct. Public reprimands represent one of the lighter forms of attorney discipline available under Georgia's professional conduct framework, typically reserved for less serious violations that do not involve moral turpitude or dishonesty.

In attorney disciplinary matters, the Georgia Supreme Court has the authority to accept or reject proposed voluntary discipline agreements. When the court finds that proposed discipline is insufficient given the nature and severity of the misconduct, it can reject the petition and require either more severe sanctions or proceed with formal disciplinary proceedings.

The case highlights the court's emphasis on maintaining public confidence in the legal profession by ensuring that disciplinary sanctions appropriately match the severity of professional misconduct. Violations involving moral turpitude and dishonesty are considered particularly serious because they directly undermine the trust that clients and the public place in attorneys.

Woodard's case involves her role as a public officer, suggesting she may have held a government position during the time period when the misconduct occurred. The specific charges relate to official duties and the improper demand of costs or fees beyond what was legally authorized, indicating potential abuse of public office for personal gain.

The court's opinion, issued per curiam without individual justices' names attached, reflects unanimous agreement among the justices that the proposed discipline remains inadequate. This approach is common in disciplinary matters where the court speaks with one voice on professional conduct standards.

The rejection of a second voluntary discipline petition is relatively unusual in Georgia's attorney disciplinary system. Most attorneys who file such petitions either have them accepted on the first attempt or work with disciplinary authorities to craft acceptable sanctions before formal court review.

With the second rejection, Woodard now faces the possibility of formal disciplinary proceedings being initiated by the State Bar of Georgia. Such proceedings could result in more severe sanctions, including suspension or disbarment, depending on the full scope of her misconduct and any aggravating factors.

The Georgia Rules of Professional Conduct serve as the foundation for attorney discipline in the state, establishing clear standards for professional behavior and the consequences for violations. Rule 8.4, under which Woodard admitted violations, addresses some of the most serious forms of professional misconduct that can result in disciplinary action.

The case also demonstrates the Georgia Supreme Court's role as the ultimate arbiter of attorney discipline within the state. While the State Bar of Georgia investigates and prosecutes disciplinary cases, the Supreme Court maintains final authority over sanctions and professional conduct standards.

Moving forward, the State Bar of Georgia will likely need to determine whether to pursue formal disciplinary charges against Woodard or work with her to develop a more substantial disciplinary agreement that would meet the court's standards. The case serves as a reminder to Georgia attorneys that violations involving moral turpitude and dishonesty will face serious scrutiny from both disciplinary authorities and the state's highest court.