The Georgia Supreme Court issued a per curiam opinion Monday in the ongoing disciplinary matter of attorney Paul Jason York, marking the second time his case has appeared before the state's highest court. The court is now reviewing York's newly-filed petition for voluntary surrender of his law license after previously rejecting his request for a three-year suspension.
In the current proceeding, *In the Matter of Paul Jason York* (S25Y0932), decided Feb. 3, 2026, the court is considering a report and recommendation from a special master who recommends accepting York's petition to voluntarily surrender his license. York, who has been a member of the State Bar of Georgia since 2014, admits to violating multiple rules of professional conduct in connection with a criminal matter.
The case represents a significant shift from York's previous attempt to resolve his disciplinary issues. In *In the Matter of York*, 318 Ga. 784 (2024), referred to as "York I" in the current opinion, the Georgia Supreme Court rejected Special Master Michael J. Blakely's recommendation to accept York's petition for voluntary discipline. In that earlier petition, York sought a three-year suspension from the practice of law, with the suspension backdated to May 1, 2020, the date he ceased practicing law.
The court's rejection of York's initial petition centered on timing concerns related to his pretrial diversion agreement. The court held that "the public [would be] likely to lose respect for the legal system" if York was permitted to resume practicing law before his pretrial diversion agreement expired. The PDA was set to continue beyond the end of York's proposed suspension period, creating what the court viewed as an inappropriate timeline for his return to practice.
According to the current court filing, York admits to violating several specific rules of the Georgia Rules of Professional Conduct. These violations include Rule 1.7(a), which governs conflicts of interest; Rule 3.3(a), which addresses candor toward a tribunal; Rule 4.1, concerning truthfulness in statements to others; and Rule 8.4(a)(4), which prohibits conduct prejudicial to the administration of justice. The violations occurred "in connection with a criminal matter," though the court's opinion does not provide additional details about the underlying conduct.
The current opinion notes that disbarment represents the maximum penalty for the violations York has admitted. This acknowledgment suggests the severity of the conduct underlying the disciplinary charges, though York's petition for voluntary surrender of his license could potentially resolve the matter without a formal disbarment proceeding.
Voluntary surrender of a law license differs significantly from suspension in that it typically represents a permanent relinquishment of the right to practice law, rather than a temporary prohibition. Under Georgia Bar Rules, attorneys may petition for voluntary discipline or surrender when facing formal disciplinary charges, though such petitions require court approval.
The special master's recommendation to accept York's voluntary surrender petition suggests a recognition that this resolution may be appropriate given the nature of the violations and York's admission of wrongdoing. Special masters in Georgia disciplinary proceedings serve as fact-finders and make recommendations to the Supreme Court, which retains ultimate authority over attorney discipline matters.
York's case illustrates the complexities that can arise when attorney disciplinary matters intersect with criminal proceedings. The presence of a pretrial diversion agreement in his earlier petition created timing issues that ultimately led to the court's rejection of his proposed suspension. Pretrial diversion agreements typically allow defendants to avoid prosecution by completing certain requirements, such as community service, restitution, or counseling.
The Georgia Supreme Court's handling of attorney disciplinary matters reflects its role in maintaining public confidence in the legal profession. The court's previous concern about public respect for the legal system demonstrates its consideration of broader implications beyond the individual attorney's circumstances.
Professional conduct violations involving truthfulness and conflicts of interest strike at the core of attorney ethical obligations. Rule 3.3(a) requires lawyers to avoid making false statements of fact to a tribunal, while Rule 1.7(a) addresses situations where representation of one client may be materially limited by the lawyer's responsibilities to other clients or third parties.
The outcome of York's current petition will determine whether he permanently relinquishes his license to practice law in Georgia. If the court accepts his voluntary surrender, it would resolve the disciplinary matter without proceeding to formal sanctions such as disbarment. The court's decision will likely consider factors including the nature of the violations, York's cooperation with the disciplinary process, and the protection of public interests.
The Georgia Supreme Court's opinion is subject to modification under Supreme Court Rule 27, which allows for reconsideration motions and editorial revisions. The final version will be published in the Georgia Reports advance sheets and will replace any prior versions on the court's website and docket.