The Georgia Supreme Court has rejected a proposed public reprimand for attorney W. McCall Calhoun, Jr., ruling that harsher disciplinary action is warranted after he admitted to violating professional conduct rules following his conviction on federal charges related to the January 6, 2021 Capitol events.
In a per curiam opinion decided January 21, 2026, the court disagreed with both Calhoun and the State Bar of Georgia, who had agreed that a public reprimand would be sufficient punishment under the circumstances. The case, *In the Matter of W. McCall Calhoun, Jr.* (S25Y1501), stems from Calhoun's participation in events at the U.S. Capitol on January 6, 2021.
Calhoun, who has been a member of the Georgia Bar since 1990 and holds State Bar No. 103915, filed a petition for voluntary discipline after a formal complaint was lodged against him. In his petition, he admitted to violating Rule 8.4(a)(8) of the Georgia Rules of Professional Conduct, which is found in Bar Rule 4-102(d). He requested a public reprimand pursuant to Bar Rule 4-102(b)(3).
The disciplinary matter came before the court based on the report and recommendation of Special Master LaRae Dixon Moore, who recommended that the court accept Calhoun's petition for voluntary discipline. However, the court noted that the maximum penalty for violating Rule 8.4(a)(8) is disbarment, indicating the serious nature of the violation.
"Having carefully reviewed the record, we disagree that a public reprimand is adequate for the reasons discussed more fully below," the court wrote in its opinion.
The case has a complex procedural history involving multiple disciplinary matters. Calhoun was initially convicted of both felony and misdemeanor federal offenses in connection with his participation in the January 6, 2021 events at the U.S. Capitol. This led to an earlier disciplinary case where the Georgia Supreme Court suspended him pending the outcome of his appeal, based on his violation of Rule 8.4(a)(2), which states that it is a violation of Bar Rules for a lawyer to "be convicted of a felony."
That initial case, *In the Matter of Calhoun*, was decided in 2023 and resulted in Calhoun's temporary suspension from practice. The court's opinion references this prior case as "Calhoun I," indicating this current matter represents a continuation of disciplinary proceedings against the attorney.
According to the court's opinion, in 2025, Calhoun filed an amended motion to lift his temporary suspension based on the vacatur of his felony conviction by the U.S. Court of Appeals for the District of Columbia Circuit. This suggests that while his felony conviction was overturned on appeal, he still faced consequences for the underlying conduct and remaining misdemeanor convictions.
The State Bar of Georgia supported Calhoun's request for a public reprimand, agreeing with his assessment that this level of discipline was appropriate given the circumstances. However, the Georgia Supreme Court's rejection of this agreed-upon recommendation suggests the justices viewed the conduct as warranting more serious consequences.
Rule 8.4(a)(8) of the Georgia Rules of Professional Conduct addresses conduct that reflects adversely on a lawyer's fitness to practice law. The rule is designed to maintain public confidence in the legal profession by ensuring attorneys meet certain standards of behavior both in their professional and personal conduct.
The court's decision to impose harsher discipline than requested by both parties is relatively uncommon in disciplinary proceedings. Typically, when both the respondent attorney and the State Bar agree on appropriate sanctions, courts give considerable deference to that agreement. The Georgia Supreme Court's rejection of the proposed public reprimand indicates the justices believed Calhoun's conduct warranted more severe consequences.
Public reprimands represent one of the lighter forms of attorney discipline, designed to formally censure an attorney's conduct while allowing them to continue practicing law. More serious sanctions can include suspension of varying lengths or, in the most severe cases, disbarment.
The case highlights the ongoing legal and professional consequences faced by attorneys who participated in the January 6, 2021 events at the U.S. Capitol. Legal professionals are held to high ethical standards, and conduct that might result in criminal charges can also trigger professional disciplinary proceedings with separate consequences.
The court's opinion indicates that a more detailed explanation of its reasoning for rejecting the proposed public reprimand will be provided in the full opinion. The decision demonstrates the Georgia Supreme Court's commitment to maintaining professional standards within the state's legal community, even when it means imposing discipline that exceeds what both parties considered appropriate.
This case serves as a reminder that attorney disciplinary proceedings can continue even after criminal appeals are resolved, and that professional conduct violations can carry consequences independent of the ultimate outcome of related criminal cases.