In the Supreme Court of Georgia

Decided: August 23, 2022

S22Y0943, S22Y0944, S22Y0945, S22Y0946. IN THE MATTER OF 

CANDACE LANETTE SNEED (four cases).

PER CURIAM.

These disciplinary matters are before the Court on the report 

and recommendation of special master William Davis, who 

recommends that the Court accept the petition for voluntary 

discipline filed pursuant to Bar Rule 4-227 (c) by respondent 

Candace Lanette Sneed (State Bar No. 797458) after the filing of a 

formal complaint and that the Court impose a nine-month 

suspension with conditions, nunc pro tunc to May 1, 2020, as 

discipline for Sneed’s admitted violations of Rules 1.3 (lawyer shall 

act with reasonable diligence and promptness in representing a 

client), 1.4 (lawyer shall promptly inform the client of any decision 

or circumstance with respect to which the client’s informed consent
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is required; reasonably consult with the client about the means by 

which the client’s objectives are to be accomplished; keep the client 

reasonably informed about the status of the matter; and promptly 

comply with reasonable requests for information), and 9.3 (lawyer 

shall respond to disciplinary authorities in accordance with State 

Bar Rules during the investigation of a grievance) of the Georgia 

Rules of Professional Conduct, found in Bar Rule 4-102 (d). The 

maximum sanction for a single violation of Rule 1.3 is disbarment, 

while the maximum sanction for a single violation of Rules 1.4 and 

9.3 is a public reprimand. For the reasons discussed below, we accept 

Sneed’s petition for voluntary discipline.

Following the filing by the Bar of formal complaints against 

Sneed, who has been a member of the Bar since 2013, as to four 

client matters, Sneed, in lieu of filing an answer to the complaints, 

filed this petition for voluntary discipline. In her petition, Sneed 

acknowledged her misconduct in these four matters, which she 

largely attributed to the effects of depression, for which she 

eventually sought treatment. Sneed sought a six-month suspension 
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– or, in the alternative, a nine-month suspension – with the 

condition on her reinstatement that she provide a statement from a 

Board-certified psychologist to the Office of the General Counsel 

declaring her fitness to resume the practice of law. The Bar filed a 

response to the petition, recommending acceptance of the petition 

and the imposition of a nine-month suspension. Sneed then filed an

amended petition, requesting that any discipline be imposed nunc 

pro tunc to May 1, 2020.

As recited by the special master, as to State Disciplinary Board 

Docket (“SDBD”) No. 7348, Sneed violated Rule 1.3 by failing to act 

with reasonable diligence in her failure to file a lawsuit and 

countersuit on behalf of her clients, violated Rule 1.4 by failing to 

inform those clients about the status of their matter and by failing 

to communicate with them for an extended period, and violated Rule 

9.3 by failing to respond to the Bar during the investigation of the 

grievance underlying that matter. Regarding No. 7349, Sneed 

violated Rule 1.3 by failing to pay a fee to transfer her client’s case 

between courts, which resulted in the dismissal of the client’s case;
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by failing to notify the client of the dismissal; and by abandoning the 

client when she moved her office without notice to the client of the 

move or her new address. Sneed violated Rule 1.4 by failing to 

communicate with or respond to the client for an extended period of 

time. Concerning SDBD No. 7350, Sneed violated Rule 1.3 by failing 

to promptly file a lawsuit on a client’s behalf and violated Rule 1.4 

when she failed to communicate with the client regarding the status 

of the client’s case. Finally, as to SDBD No. 7351, Sneed violated 

Rule 1.3 by dismissing a lawsuit that she had filed on the client’s 

behalf without her client’s knowledge or consent and violated Rule 

1.4 by failing to consult with and obtain consent from the client prior 

to dismissing the lawsuit and by her failure to notify the client about 

a pending trial in that matter.

1

 

1 The special master’s report and recommendation clearly relied upon,

arguably deferred to, and in some cases adopted verbatim the Bar’s response. 

The Bar’s response and the special master’s report and recommendation are 

primarily based on the facts as recited in the respective formal complaints. 

Both omit, without explanation, numerous facts from Sneed’s petition and 

occasionally assert facts that contradict those asserted by Sneed. This is 

important because the special master is tasked with serving as the factfinder 

with respect to all disputed material questions of fact. In light of this role, it is 

concerning that the report and recommendation of the special master provides 
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In addressing the question of the appropriate sanction to be 

imposed as to these matters, the special master considered the ABA 

Standards for Imposing Lawyer Sanctions. See In the Matter of 

Morse, 266 Ga. 652, 653 (470 SE2d 232) (1996). The special master 

noted that, according to ABA Standard 3.0, when imposing a 

sanction after a finding of lawyer misconduct, a court should 

consider: 1) the duty violated; 2) the lawyer’s mental state; 3) the 

potential or actual injury caused by the lawyer’s misconduct; and 4) 

the existence of aggravating or mitigating factors. The special 

master concluded that Sneed had violated duties that she owed to 

her clients to be diligent and to communicate, which violations 

resulted in the clients suffering financial injuries created by their 

 

no explanation for these discrepancies. Further, Sneed’s citations on the point 

of appropriate discipline focused only on her mental health. Meanwhile, the 

report of the special master failed to include any authority concerning the 

appropriate level of discipline warranted by the violations. In any event, 

pursuant to our unaided and independent review and whether we consider 

Sneed’s admitted conduct or the less favorable allegations of the Bar contained 

in the report and recommendation, we have determined that the discipline 

suggested by Sneed and recommended by the Bar and the special master is 

appropriate. We take this opportunity to remind the Bar and all special 

masters of the importance of resolving factual discrepancies present in these 

cases and in providing legal authority, or noting the lack thereof, 

demonstrating the appropriateness of proposed discipline.
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need to locate and retain new counsel in order to resolve their cases.

As to Sneed’s mental state, the special master concluded that 

Sneed’s conduct in these four matters demonstrated that she 

knowingly failed to perform the legal services for which she was 

retained, particularly given the similarity of her conduct in each 

matter, but also acknowledged Sneed’s assertions that she was 

“overwhelmed” or “always worried” while representing her clients. 

With regard to the injury caused by Sneed’s misconduct, the special 

master pointed to the loss of funds by clients caused by Sneed’s 

retention of attorney fees paid to her until she later refunded them; 

stated that the clients’ financial losses included not only fees paid to 

Sneed but fees paid to obtain new counsel; and noted that Sneed’s 

delayed restitution payments did not account for additional fees for 

new counsel or address her delay in fulfilling clients’ refund 

requests. In aggravation of discipline, the special master noted 

Sneed’s experience in the practice of law, her pattern of misconduct, 

and her failure to refund fees when requested to do so by her clients. 

In mitigation, the special master cited Sneed’s lack of prior 
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disciplinary history, the fact that she sought counseling, the fact 

that she expressed remorse, and the letters that she submitted 

attesting to her good character and reputation. In conclusion, the 

special master recommended that this Court accept Sneed’s petition 

and impose a nine-month suspension with the above-mentioned 

condition on reinstatement.

Having reviewed the record, we accept Sneed’s petition for 

voluntary discipline and hereby impose a suspension of nine months 

with reinstatement conditioned upon compliance with the abovereferenced condition. See generally In the Matter of Kirby, 312 Ga. 

341 (862 SE2d 550) (2021) (accepting petition for voluntary 

discipline and imposing six-month suspension for violating Rules 

1.2, 1.3, 1.4, and 1.16 in four separate matters, where attorney 

addressed his mental health and practice management problems); 

In the Matter of Johnson, 303 Ga. 795 (815 SE2d 55) (2018) 

(accepting petition for voluntary discipline and imposing six-month 

suspension for violating Rules 1.3, 1.4, 1.5, 1.15 (I), 1.16 (d), and 

Rule 5.5 (a) in seven separate matters, where attorney was suffering 
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from personal and emotional problems at time of misconduct and 

had taken intervening efforts to improve himself and his law 

practice); In the Matter of Huggins, 291 Ga. 92 (727 SE2d 500) (2012) 

(accepting petition for voluntary discipline and imposing six-month 

suspension with conditions for reinstatement for violations of Rules 

1.3, 1.4, 1.15, 1.16, and 9.3 in five client matters, where attorney had 

no prior disciplinary history and was receiving treatment for his 

personal issues). Furthermore, as the record shows that Sneed 

voluntarily ceased the practice of law as of May 1, 2020, we agree 

with the special master’s recommendation to impose her nine-month 

suspension nunc pro tunc to that date. See In the Matter of Onipede, 

288 Ga. 156, 157 (702 SE2d 136) (2010) (stating that “when an 

attorney requests entry of a suspension or voluntary surrender 

order nunc pro tunc, it is the lawyer’s responsibility to demonstrate 

that they voluntarily stopped practicing law, the date on which their 

law practice ended, and that they complied with all the ethical 

obligations implicated in such a decision, such as assisting clients in 
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securing new counsel and facilitating the transfer of client files and 

critical information about ongoing cases to new counsel”).

Sneed may seek reinstatement by demonstrating to the State 

Bar’s Office of General Counsel that she has met the condition of

reinstatement.2 If the State Bar agrees that the condition has been 

met, it will submit a notice of compliance to this Court, and this 

Court will issue an order granting or denying reinstatement. Sneed

is reminded of her duties under Bar Rule 4-219 (b).

Petition for voluntary discipline accepted. Nine-month 

suspension. All the Justices concur.

 

2 We note that, although Sneed was paid fees by at least some of the 

clients in these matters, there is no restitution requirement being imposed in 

conjunction with her suspension here. According to Sneed’s petition, she repaid 

the fees paid to her by the clients in the matters underlying SDBD Nos. 7348 

and 7349 in October 2021, she earned the fee paid to her in the matter 

underlying SDBD No. 7350, and she was not paid by the client in the matter 

underlying SDBD No. 7351. The records before this Court contain no evidence 

supporting or contradicting Sneed’s assertions in this regard, and it is not clear 

to what extent the Bar and the special master considered whether Sneed had 

in fact made restitution to the affected clients or whether additional restitution 

might have been appropriate as to these matters. We take this opportunity to 

remind the Bar of the importance of this information to our review of attorney 

disciplinary matters. See In the Matter of Johnson, 282 Ga. 473, 474 (651 SE2d 

82) (2007) (Melton, J., dissenting) (noting that “it is imperative for this Court 

to have some information regarding any efforts made by the disciplined 

attorney to make his or her clients whole” and that “the State Bar should 

ensure that [such information] becomes a part of the record in each disciplinary 

action as a matter of course”).