One office inside the State Bar of Georgia screens every grievance and decides who is investigated and who is cleared. This is how that office handled three people in three protected categories. The facts are from court opinions and the Bar’s own words. I am showing the record. I am not assigning a motive.
1. A Black attorney charged under rules that did not reach her conduct
Marsha W. Mignott has been a member of the State Bar of Georgia since 2005, “without prior disciplinary history” (ABA Journal). The Office of the General Counsel charged her with violating Georgia Rules of Professional Conduct 1.8(b) and 1.9(c)(2). The Supreme Court of Georgia dismissed the case unanimously:
“By their plain text, Rules 1.8 (b) and 1.9 (c) (2) apply only to clients and former clients, not prospective clients.” … “We therefore impose no discipline and dismiss this matter.” … “All the Justices concur.”
The conduct dated to March 2018. The notice of probable cause issued in October 2020. The case was not dismissed until October 24, 2023.
Her federal suit cited a State Bar investigator’s email to a white attorney accused of misconduct. As reported by the ABA Journal, the investigator wrote (an allegation drawn from her complaint):
“As soon as I receive your response (you don’t have to go into great detail), I will draft a dismissal letter and send you a copy.”
Mignott filed a putative class action under 42 U.S.C. § 1981. The Eleventh Circuit, quoting her complaint, described the claim:
She alleged the defendants “discriminated against her and other black attorneys by pursuing ‘fraudulent grievances’ against them and by subjecting them ‘to unequal grievance and disciplinary proceedings relative to their white peers.’”
The Bar’s outside counsel responded: “The bar denies the allegations… Race plays no role in state bar disciplinary matters.” On July 30, 2025, the Eleventh Circuit (Pryor, C.J., published) vacated the dismissal of her suit:
“Because federal, not state, law governs the subject-matter jurisdiction of the district court, we vacate and remand for further proceedings.” … “Indeed, she prevailed in the Supreme Court of Georgia, which held that she did not violate any rule of professional conduct.”
The court expressly reserved the remaining questions, including immunity, for the district court. The case is alive on remand.
2. A disabled complainant: evidence lost, then accused of “outcome-seeking”
A disabled member of the public filed a grievance against a municipal court solicitor. The Bar’s own intake confirmed receipt of his rebuttal submissions by grievance number, then dismissed the grievance stating no rebuttal had been received. It later admitted, in writing:
“As a result of this misclassification, your submissions were not added to the grievance file at that time.”
The dismissal was never corrected. When he invoked ADA access, a Deputy General Counsel wrote that his requests appeared “directed less toward obtaining accommodation for a functional limitation and more toward securing a particular substantive outcome.” On the same disability, in the same weeks, the Bar’s ADA Coordinator granted accommodations, then wrote that the Bar is “not subject to Title II.” He had never threatened litigation.
3. The language gap
Older Spanish-language grievance materials published by the Bar include ADA Coordinator contact information: a name, a phone number, a toll-free number. The current English-language grievance pathway publishes none of it. The Bar has not explained the discrepancy.
4. The pattern
| Marsha Mignott (race) | The disabled complainant | Spanish vs English (language) | |
|---|---|---|---|
| Protected category | Black attorney | Disabled member of the public | Language-access gap |
| What happened | Charged under rules the Georgia Supreme Court said do not apply; cleared unanimously after years | Evidence lost after intake confirmed receipt; dismissed on a false non-receipt; admitted, never corrected | ADA contact info appears in the Spanish materials, missing in the English ones |
| How the office characterized the person | Defendant in a prosecution the court said had no basis | “Outcome-seeking,” “litigation-oriented,” “does not appear to require assistance” | N/A |
| The answer when challenged | “Race plays no role.” Lost at the 11th Circuit; case alive | Denied Title II coverage; stripped the State ADA Coordinator from emails; shut down communication | No response to the discrepancy |
| Who reviewed it | The same office accused of bias | The same Deputy GC whose conduct was complained about | No public mechanism |
| Record retention | Destroyed after one year | Destroyed after one year | Destroyed after one year |
| Complainant appeal | None | None | None |
5. The question
The Bar says race plays no role. The Bar says it is not subject to Title II. The Bar says its ADA Coordinator contact information is not required to be published. If all of that is true, then by coincidence a Black attorney with no prior discipline was charged for years under rules the Georgia Supreme Court said did not apply to her; a disabled member of the public whose evidence the Bar lost was told his access requests were “outcome-seeking” while the Bar granted accommodations for the same disability; and ADA contact information appears in the Bar’s Spanish materials but not its English ones. One office. One screening process. One expiration rule. No appeal.
Sources
| Item | Source |
|---|---|
| “apply only to clients and former clients, not prospective clients”; “impose no discipline and dismiss”; “All the Justices concur” | Ga. Supreme Court, per curiam, In re Mignott, 893 S.E.2d 891 (Ga. Oct. 24, 2023) |
| “federal, not state, law governs the subject-matter jurisdiction… we vacate and remand”; her allegations of “fraudulent grievances” and “unequal grievance and disciplinary proceedings relative to their white peers”; immunity reserved | 11th Cir., published, Pryor, C.J., Mignott v. State Bar of Ga. Found., Inc., No. 24-10327 (11th Cir. July 30, 2025) |
| Investigator “draft a dismissal letter” email; “shine a light on the racial injustices”; “Race plays no role”; “without prior disciplinary history” | ABA Journal, Apr. 25, 2023 |
| “your submissions were not added to the grievance file at that time” | Bar correspondence, Apr 21 / May 5, 2026 |
| “directed less toward obtaining accommodation… more toward securing a particular substantive outcome” | Bar correspondence, May 12, 2026 |
| “not subject to Title II” | Bar correspondence, May 29, 2026 |
Court holdings are adjudicated facts. The investigator email and the racial-discrimination claims are Marsha Mignott’s allegations, as reported and as quoted in her complaint; her federal case is ongoing on remand, with immunity and the merits unresolved. Corrections: if any fact here is incomplete or inaccurate, identify the page, the sentence, and the supporting source, and I will review and correct the record.