In evaluating discipline, the Special Master did not analyze three components of the ABA Standards: (1) the duty violated, (2) the lawyer’s mental state, and (3) the actual or potential injury to the clients. See In the Matter of Morse, 265 Ga. 353, 354 (2), 456 S.E.2d 52 (1995), superseded on other grounds by Rule as stated in Cook, 311 Ga. at 207-08 (1), 857 S.E.2d 212. Instead, he analyzed only the applicable aggravating and mitigating factors.

But we afford no such deference to the conclusions of law made by the Special Master or the Review Board. See In the Matter of Morse , 265 Ga. 353, 354 (1), 456 S.E.2d 52 (1995) ("[w]hether an attorney has violated a particular standard of conduct is a legal question"), superseded on other grounds as stated in Cook , 311 Ga. at 207-208 (1), 857 S.E.2d 212. Therefore, we generally defer to the Special Master's findings of fact (as adopted by the Review Board here) so long as they are supported by the record, but we review de novo the conclusions of law reached below on what rules were violated and what level of discipline is appropriate.

Thus, if factual findings "are supported by the record," we will generally not disturb them. In the Matter of Cook, 311 Ga. 206, 207 (1) (857 S.E.2d 212) (2021). But we afford no such deference to the conclusions of law made by the Special Master or the Review Board. See In the Matter of Morse, 265 Ga. 353, 354 (1) (456 S.E.2d 52) (1995) ("[w]hether an attorney has violated a particular standard of conduct is a legal question"), superseded on other grounds as stated in Cook, 311 Ga. at 207-208 (1). Therefore, we generally defer to the Special Master's findings of fact (as adopted by the Review Board here) so long as they are supported by the record, but we review de novo the conclusions of law reached below on what rules were violated and what level of discipline is appropriate.

A review of the applicable rules and case law shows that we are to defer to the special master's findings. We have often cited In the Matter of Morse , 265 Ga. 353 (1), 456 S.E.2d 52 (1995), for the proposition that we are "bound by the [R]eview [Board]’s findings of fact when there is ‘any evidence’ to support them." Id. at 353 (1), 456 S.E.2d 52.

In determining the appropriate level of discipline, the Board appropriately considered the ABA Standards for Imposing Lawyer Sanctions, including the existence of aggravating or mitigating factors. See In the Matter of Morse, 265 Ga. 353, 354 (2) (456 S.E.2d 52) (1995), superseded by rule on other grounds as stated in In the Matter of Cook, 311 Ga. 206, 214-215 (1) (857 S.E.2d 212) (2021). We agree with the Board's determination that the following factors should be considered in aggravation: Greene's prior disciplinary history, see In the Matter of Greene, 293 Ga. 897 (750 S.E.2d 367) (2013) (accepting petition for voluntary discipline and imposing 18-month suspension based on his admitted violations of Rules 1.3, 1.4, 1.15 (I), 1.15 (II), 1.16 (d), and 8.4 related to two client matters); his pattern of misconduct; his commission of multiple offenses; his substantial experience in the practice of law; and his obstruction of the disciplinary proceedings in bad faith based on his failure to respond to the Notice of Investigation and his failure to appear for a mental health evaluation as directed by the Bar.

Applying the ABA Standards for Imposing Lawyer Sanctions ("ABA Standards"), the Special Master examined (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. See In the Matter of Morse, 265 Ga. 353, 354 (2), 456 S.E.2d 52 (1995). Barksdale admitted to violating Rule 1.3 by failing to promptly prepare and present the proposed order, parenting plan, and child support worksheet as directed by the court on July 22, 2019; failing to communicate with the client about her delay in presenting the proposed order to the court; and failing to collaterally attack the July 6, 2020 order after receiving notice of the issues caused by the father’s counsel mailing service copies to an incorrect address.

In determining the appropriate level of discipline, the Board appropriately considered the ABA Standards for Imposing Lawyer Sanctions, including the existence of aggravating or mitigating factors. See In the Matter of Morse, 265 Ga. 353, 354 (456 S.E.2d 52) (1995), superseded by Rule on other grounds as stated in In the Matter of Cook, 311 Ga. 206, 214-215 (857 S.E.2d 212) (2021). We agree with the Board's determination that the following factors should be considered in aggravation: Cleveland's prior disciplinary record; his pattern of misconduct; his commission of multiple offenses; the vulnerability of his clients; his substantial experience in the practice of law; and his indifference to making restitution to the client in SDBD No. 7679.

Compare In the Matter of Edward Davis, 303 Ga. 564 (814 SE2d 383) (2018) (rejecting petition seeking Review Panel reprimand where attorney admitted violations of Rules l.15 (I) (a) and 1.15 (II) (b), but denied violating Rule 8.4 (a) (4) even though he knowingly notarized a signature on a deed, thereby falsely attesting that the deed had been signed in his presence by the person whose signature appeared thereon). Aware that this Court looks to the American Bar Association's Standards for Imposing Lawyer Sanctions for guidance in determining the appropriate sanction to impose, see In the Matter of Morse, 265 Ga. 353, 354 (456 SE2d 52) (1995), the Bar adds that a reprimand is generally appropriate when a lawyer knowingly engages, as Cherry did in SDB Docket No. 7136, in conduct that involves dishonesty, fraud, deceit, or misrepresentation that adversely reflects on the lawyer's fitness to practice law (see ABA Standard 5.13), or when a lawyer's negligence in dealing with client property causes injury or potential injury to a client, as Cherry did in SDB Docket No. 7135 when she deliberately disregarded the doctor's lien at the behest of her client and in apparent ignorance of the rules that prohibit such conduct (see ABA Standard 4.13). Cherry asserts that her conduct did not appear ultimately to harm either her client or her potential client, and that Cherry's proposed resolution of these disciplinary matters is the result of negotiation between the Bar and Cherry. The Bar asserts that a public reprimand is sufficient to act as a penalty for Cherry, a deterrent to others, and an indication to laymen t

The special master correctly noted that this Court relies on the American Bar Association’s Standards for Imposing Lawyer Sanctions for general guidance in determining the appropriate level of discipline. See In the Matter of Morse, 265 Ga. 353, 354, 456 S.E.2d 52 (1995). See, e.g., In the Matter of Lank, 300 Ga. 479, 482, 796 S.E.2d 252 (2017).

This Court considers the ABA Standards as providing useful guidance in determining the appropriate sanction. See In the Matter of Morse, 265 Ga. 353 (2), 456 S.E.2d 52 (1995).(a) the duty violated;