The Supreme Court of Georgia has issued a definitive order of disbarment against attorney Dell Jackson for a severe breach of professional duty that centered on client abandonment and a complete failure to communicate. The March 2025 ruling concluded a disciplinary matter that exposed a fundamental neglect of the core responsibilities an attorney owes to their client.
The Charges: A Case of Complete Client Abandonment
The disciplinary action stemmed from Jackson’s representation of a single client in a direct appeal case before the Georgia Supreme Court. The facts, which Jackson effectively admitted by defaulting on the formal complaint, demonstrated a pattern of profound neglect over the course of the representation:
- Failure to Deliver Essential Documents: Jackson failed to provide her client with a copy of his trial transcript despite his specific requests. For a client pursuing an appeal, this document is fundamental to exploring all available legal remedies, including potential post-conviction relief like federal or state habeas corpus petitions.
- Refusal to Consult: She refused to communicate with the client regarding the status of his appeal, the legal issues being raised, or the overall strategy for the case. This conduct violated the rule requiring attorneys to keep their clients reasonably informed.
- Ultimate Silence: After the Supreme Court issued its opinion on the appeal, Jackson failed to notify the client of the final ruling and ceased all communication permanently, effectively abandoning him and leaving him uninformed about the final status of his case.
The court found that this conduct violated multiple Georgia Rules of Professional Conduct (GRPC), including:
- Rule 1.2(a): Abiding by a client’s decisions and consulting on the scope of representation.
- Rule 1.3 (Diligence): Failure to act with reasonable diligence and willfully abandoning a legal matter.
- Rule 1.4(a) (Communication): Failure to keep a client reasonably informed and promptly comply with reasonable requests for information.
The Procedure: Disbarment by Default
A critical factor in this case was Attorney Jackson’s failure to participate in the disciplinary process.
- Non-Response to Complaint: After the State Bar filed a formal complaint, Jackson failed to respond, leading to a default order by the Special Master.
- Admission of Guilt: Under Georgia Bar rules, a default means the factual allegations and the corresponding ethical violations charged in the complaint are deemed admitted as true.
- Failure to Appear: Jackson was notified but also failed to appear at her scheduled hearing on aggravation and mitigation.
In recommending the sanction, the Special Master cited numerous aggravating factors:
- The commission of multiple offenses in a single client matter.
- Jackson’s substantial experience in the practice of law (admitted in 1993).
- The vulnerability of the client who was reliant on her for his appeal.
- Her obstruction of the disciplinary proceeding by failing to participate.
The court determined that the severe injury caused to the client, particularly the potential loss of future legal remedies due to the lack of the transcript and timely notice, outweighed the mitigating factor of her otherwise clean disciplinary record.
Conclusion: The Non-Negotiable Standard of Candor
The Supreme Court of Georgia affirmed that when an attorney admits (by default or otherwise) to violating the rules requiring diligence and communication, and causes serious potential injury to the client—especially when coupled with a failure to cooperate with disciplinary authorities—disbarment is the appropriate and necessary sanction.
The disbarment of Dell Jackson is a powerful reminder that an attorney’s duty to advocate ends where the line of ethical neglect begins. Her case reinforces the message to the legal profession: client abandonment, silence, and non-cooperation with the State Bar will not be tolerated and will result in the ultimate professional penalty. Her name has been permanently removed from the rolls of persons authorized to practice law in the state of Georgia.