SUMMARY
On April 23, 2023, Marsha W. Mignott filed a putative class action in the Northern District of Georgia alleging race discrimination arising from the State Bar disciplinary process, under 42 U.S.C. § 1981. These are allegations in her filed complaint, not judicial findings.
The federal case names the State Bar of Georgia Foundation, Inc., the State Bar of Georgia Office of the General Counsel, and an assistant general counsel in his official capacity. The public federal case number is 1:23-cv-01834-ELR.
Status as of October 11, 2026
The latest filing I have verified is Doc. 56, filed October 9, 2026. I pulled the docket entries since September 28 from PACER on October 11, 2026, and found no ruling on Doc. 46 (the defendants’ renewed motion to dismiss) or on Doc. 53 (a motion for leave to file a supplemental response). Free court sources lag PACER, so I have verified nothing later. Doc. 55, an October 8 order, referred the recusal issue back to Judge Eleanor L. Ross and describes it as pending. A later filing on the federal docket would not appear here until I add it.
What the federal case concerns
Doc. 1, page 2, paragraph 1, plaintiff’s own words:
Defendants violated the Civil Rights Act of 1866, 42 U.S.C. § 1981 by engaging in racial discrimination against African American attorneys who are members of the State Bar of Georgia, such as Plaintiff (“Mignott”).
The case timeline
| Doc | Date | Filed by | What it is | Limit or status |
|---|---|---|---|---|
| Doc. 1 | April 23, 2023 | Plaintiff | Class Action Complaint with jury demand, alleging racial discrimination under § 1981 in the Bar’s disciplinary process. Docket entered April 24; document filed April 23. | The allegations are not court findings. |
| Georgia Supreme Court S23Y0974, 317 Ga. 764 | October 24, 2023; reconsideration November 16, 2023 | Supreme Court of Georgia | Separate disciplinary decision declining to impose discipline and dismissing the matter. | The state disciplinary disposition does not decide the federal discrimination allegation. |
| Doc. 26 | December 27, 2023 | Judge Eleanor L. Ross | District order dismissing the action without prejudice for lack of subject matter jurisdiction. Source: docket entry. | This was a jurisdictional dismissal, not an adjudication of the merits. |
| Eleventh Circuit No. 24-10327 | July 30, 2025 | United States Court of Appeals for the Eleventh Circuit | Published opinion vacating the district dismissal and remanding. Mandate issued August 28, 2025 (district Doc. 36); judgment entered September 2, 2025 (Doc. 38). | The court did not adjudicate the pleaded racial discrimination allegations. |
| Doc. 44 | May 6, 2026 | Judge Eleanor L. Ross | Order, as described in the docket entry, partly permitting a renewed motion to dismiss while refusing the proposed Rooker Feldman ground, and setting a seven day filing deadline. | The court did not grant the renewed dismissal motion. |
| Doc. 45 | May 11, 2026 | Plaintiff | Motion for recusal with brief and attachments. Source: docket entry and Doc. 55. | A motion to recuse does not mean recusal was granted. |
| Doc. 46 | May 12, 2026 | Defendants through Nall & Miller, LLP | Renewed Motion to Dismiss and Brief in Support. | Defense arguments are not court rulings. |
| Doc. 48 | May 18, 2026, entered May 20 | Judge Eleanor L. Ross | Order, as described in the docket entry, reassigning the recusal motion to another district judge. | It does not resolve the merits of the discrimination claim. |
| Doc. 49 | May 20, 2026 | Chief Judge Leigh Martin May | Order, as described in the docket entry, returning the case to Judge Ross. Doc. 55 describes a procedural deficiency under § 144 and referral of the § 455 issue. | It did not decide the main renewed motion to dismiss. |
| Doc. 50 | May 26, 2026 | Plaintiff | Response opposing the renewed motion to dismiss. | A brief is an argument, not a ruling. |
| Doc. 51 | May 31, 2026 | Plaintiff | Motion for reconsideration of Doc. 49 concerning recusal. Source: docket entry. | Filing reconsideration does not establish a new recusal order. |
| Doc. 52 | June 9, 2026 | Defendants through Nall & Miller, LLP | Reply supporting the renewed motion to dismiss. Page 4 presents state control and arm of the state arguments; signed by Patrick N. Arndt (page 15). | Those propositions are representations in a brief, not findings by a court. |
| Doc. 53 | September 14, 2026 | Plaintiff | Motion for Leave to File Supplemental Response to Defendants’ Renewed Motion to Dismiss, eleven pages, with three attachments. Its page 3, paragraph 7, identifies ADA Matters as the published source of Exhibit B. | No ruling found through October 11, 2026. |
| Doc. 53-1 | September 14, 2026 | Plaintiff | Exhibit A Supplemental Motion, the docket’s label. The attached fifteen page proposed supplemental response refers to ADA Matters on page 4. | No ruling found through October 11, 2026. |
| Doc. 53-2 | September 14, 2026 | Plaintiff | Exhibit B May 2026 Email, two pages: a cover and, on page 2, the ADA Matters reproduction of the May 12 email. | No ruling found through October 11, 2026. |
| Doc. 53-3 | September 14, 2026 | Plaintiff | Text of Proposed Order attached to Document 53. It is a proposed order, not a signed ruling. | No ruling found through October 11, 2026. |
| Doc. 54 | September 28, 2026 | Defendants through Nall & Miller, LLP | Response opposing plaintiff’s motion for leave. | Defendants’ assertions do not constitute judicial findings. |
| Minute order | October 7, 2026 | The court, by docket entry only | Minute order, as described in the PACER docket entry, referring the Doc. 51 motion for reconsideration to the Chief Judge for review. | A referral, not a ruling. It does not decide Doc. 46 or Doc. 53. |
| Doc. 55 | October 8, 2026 | Chief Judge Leigh Martin May | Order denying Doc. 51 reconsideration and referring the case back to Judge Ross. | The order concerns recusal. It does not decide Doc. 46 or Doc. 53. |
| Doc. 56 | October 9, 2026 | Plaintiff | Reply Brief in Support of Motion for Leave to File Supplemental Response to Defendants’ Renewed Motion to Dismiss. Pages 8 and 9 address the defendants’ authentication argument. | No ruling found through October 11, 2026. |
Key words from the docketed record
Separate Georgia disciplinary decision, October 24, 2023. Supreme Court of Georgia, opinion page 2: “We therefore impose no discipline and dismiss this matter.” Reconsideration was decided November 16, 2023, per page 8.
Federal appellate decision, July 30, 2025. Eleventh Circuit, published opinion page 2: “Because federal, not state, law governs the subject-matter jurisdiction of the district court, we vacate and remand for further proceedings.”
Defendants’ state control representation, June 9, 2026. Doc. 52, page 4: “For factor 2, the State, through the Georgia Supreme Court, controls the State Bar and its agents and employees. The Georgia Supreme Court promulgates the Rules of Professional Conduct.” Filed by counsel for the three defendants, not by a court.
Defendants’ counsel on relevance, September 28, 2026. Doc. 54, page 6: “Again, comments in an email in the context of a member of the public asking about accommodations pursuant to the Americans With Disabilities Act have no relevance to this matter.” Filed by counsel for the three defendants, not by a court.
The recusal decision, October 8, 2026. Doc. 55, page 5: “Accordingly, Plaintiff’s Motion for Reconsideration [51] is DENIED. The Clerk is DIRECTED to REFER this case back to Judge Eleanor L. Ross for further proceedings.” Page 2 describes the § 455 issue as pending before Judge Ross.
Plaintiff on where Exhibit B came from, September 14, 2026. Doc. 53, page 3, paragraph 7:
The correspondence was published on the public website ADA Matters, www.adamatters.com, by a third-party grievant who filed grievances with the State Bar’s Office of the General Counsel.
Filed by the plaintiff, not by a court.
Plaintiff on authentication, October 9, 2026. Doc. 56, page 9:
Should the Court deem further authentication necessary, Plaintiff will promptly supply it.
Filed by the plaintiff, not by a court. It states what she said she would do. It is not an offer by ADA Matters.
What kind of record each one is
The state disciplinary decision, the federal appellate ruling, the plaintiff’s discrimination allegations and the defendants’ dismissal positions are different kinds of record. The federal appellate ruling concerns jurisdiction. It does not resolve the merits. The defendants’ June 9 argument about state control appears in a court filing, not a court holding. Whether the State Bar is a public entity under ADA Title II and whether it is an arm of the state for Eleventh Amendment purposes are different legal questions. The records I hold through October 19, 2026, show no court ruling deciding the State Bar’s Title II public entity status and no ruling on the renewed motion to dismiss.