Atlanta, GA – The U.S. Court of Appeals for the Eleventh Circuit has revived a significant civil rights lawsuit filed by Georgia attorney Marsha Mignott, accusing the State Bar of Georgia of racial bias in its disciplinary proceedings. The appellate panel unanimously reversed a lower district court’s dismissal of the case for lack of jurisdiction.
In a ruling issued Wednesday, a three-judge panel found that the district court erred in dismissing Mignott’s suit, which alleges the State Bar favors white attorneys over Black attorneys in disciplinary matters. The lower court had ruled that the Supreme Court of Georgia holds exclusive authority over attorney disciplinary issues, thus barring federal court jurisdiction.
However, the Eleventh Circuit clarified that federal courts retain jurisdiction over civil rights claims, emphasizing that Georgia law cannot override federal-question jurisdiction. Chief Judge William Pryor Jr. authored the opinion, stating, “Mignott’s complaint arises under federal law, which supplies her cause of action,” and that federal courts “must… determine their jurisdiction and powers without regard to state law.”
The court declined to address other potential jurisdictional issues or the merits of the case, instead remanding those questions to the district court for further review.
The case stems from allegations that the State Bar operates a discriminatory two-tier disciplinary system based on race. Mignott contends that she would not have faced disciplinary action if she were white, noting that the complaint against her was supported by forged evidence. Previously, a special master had substantiated claims against her, but Georgia’s Supreme Court ultimately cleared Mignott of wrongdoing and dismissed recommended sanctions.
After the district court dismissed her class action suit in December 2023, Mignott appealed. Oral arguments were heard in July 2025 in Atlanta, where the Eleventh Circuit judges signaled they were inclined to reinstate the case.
Marsha W. Mignott represents herself in the matter. The State Bar of Georgia is represented by attorneys Patrick N. Arndt and Robert L. Goldstucker of Nall & Miller LLP.
