In Re: Christopher Antonio Tyson

Supreme Court of Louisiana
September 10, 2025
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
IN RE: CHRISTOPHER ANTONIO TYSON
No. 2025-B-00678
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_ _ _ _
I
N RE: Office of Disciplinary Counsel - Applicant Other; Notice of Discipline in
Another Jurisdiction Pursuant to Rule XIX, Section 21 and Motion to Initiate
Reciprocal Discipline Proceedings;
_ _ _ _ _ _
September 10, 2025
Reciprocal discipline imposed. See per curiam.
CRC
JLW
JDH
WJC
JBM
PDG
JMG
09/10/2025 "See News Release 040 for any Concurrences and/or Dissents."

SUPREME COURT OF LOUISIANA
NO. 2025-B-0678
IN RE: CHRISTOPHER ANTONIO TYSON
ATTORNEY DISCIPLINARY PROCEEDING
PER CURIAM
This matter arises from a Petition to Initiate Reciprocal Discipline
Proceedings filed by the Office of Disciplinary Counsel (“ODC”) against
respondent, Christopher Antonio Tyson , an attorney licensed to practice law in
Louisiana and Georgia, based upon discipline imposed by the Supreme Court of
Georgia.
UNDERLYING FACTS AND PROCEDURAL HISTORY
Respondent filed a petition for voluntary discipline with the Supreme Court
of Georgia, admitting that he had committed misconduct by mishandling client funds
during his representation of a plaintiff in a personal injury lawsuit. Specifically,
respondent admitted that he settled his client’s case in November 2020 for
$6,300.00. Upon receiving the settlement check, respondent deposited the check
into his client trust account. Respondent notified the client of the receipt of funds;
however, he did not notify a chiropractor from whom the client sought treatment and
who had an interest in any settlement funds in the matter. Respondent paid a lien
for medical benefits on behalf of the client, but did not promptly disburse the
settlement funds owed to his clie nt or the chiropractor. Respondent also failed to
maintain sufficient funds in his client trust account and used client trust account
funds for personal expenses.

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For the above misconduct, respondent filed a petition for voluntary discipline
with the Supreme Court of Georgia, wherein respondent stipulated that he violated
the Georgia Rules of Professional Conduct. Specifically, respondent stipulated that
he violated Rules 1.15 (I)(a) by failing to safeguard the settlement funds owed to the
client and the chiropractor in his IOLTA account, 1.15 (I)(b) by disregarding the
chiropractor's interest in the funds from the settlement, 1.15 (I)(c) by failing to
promptly noti fy the chiropractor of the receipt of the settlement and failing to
promptly disburse the funds owed to the client and the chiropractor, and 1.15 (II)(b)
by withdrawing from the IOLTA account unearned funds for personal use. For his
misconduct, respondent proposed that he be suspended from the practice of law for
six months. However, the Supreme Court of Georgia rejected the petition, finding
that a six -month suspension was insufficient based on the facts of the case and in
light of respondent’s failure to pay restitution and prior disciplinary history (a 2013
private reprimand). See In the Matter of Tyson, 319 Ga. 527, 904 S.E. 2d 503 (2024).
Respondent then filed an amended petition for voluntary discipline, seeking a
one-to-two-year suspension contingent upon his restitution in attorney fees to his
former client. In his amended petition, respondent admitted that out of the $6,300.00
settlement, he paid $1,227.47 to satisfy an ERISA lien, $2,100.00 to the client, and
$2,100.00 to the chiropractor. Respondent included with his amended petition a
copy of said payments and correspondence from the client’s chiropractor stating he
is satisfied with his portion of the settlement proceeds. Respondent admitted that he
disbursed the remaining $872.53 to himself for attorney fees.
On February 18, 2025, the Supreme Court of Georgia accepted the amended
petition and suspended respondent from the practice of law for two years, with his
reinstatement conditioned upon respondent providing restitution in the amount of
$872.53 to his form er client and upon the successful completion of the terms and

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conditions to lift his administrative suspension. In the Matter of Tyson, 321 Ga. 64,
912 S.E. 2d 637 (2025).
After receiving respondent’s self-report of the Georgia order of discipline, the
ODC filed a motion to initiate reciprocal discipline proceedings in Louisiana,
pursuant to Supreme Court Rule XIX, § 21. A copy of the decision issued by the
Supreme Court of Georgia was attached to the motion. On May 29, 2025, this court
rendered an order giving respondent thirty days to demonstrate why the imposition
of identical discipline in this state would be unwarranted.
Respondent filed an answer to this court, admitting all of the statements made
in the petition.

DISCUSSION
The standard for imposition of discipline on a reciprocal basis is set forth in
Supreme Court Rule XIX, § 21(D). That rule provides:
Discipline to be Imposed. Upon the expiration of thirty
days from service of the notice pursuant to the provisions
of paragraph B, this court shall impose the identical
discipline … unless disciplinary counsel or the lawyer
demonstrates, or this court fi nds that it clearly appears
upon the face of the record from which the discipline is
predicated, that:

(1) The procedure was so lacking in notice or opportunity
to be heard as to constitute a deprivation of due
process; or
(2) Based on the record created by the jurisdiction that
imposed the discipline, there was such infirmity of
proof establishing the misconduct as to give rise to the
clear conviction that the court could not, consistent
with its duty, accept as final the concl usion on that
subject; or
(3) The imposition of the same discipline by the court
would result in grave injustice or be offensive to the
public policy of the jurisdiction; or
(4) The misconduct established warrants substantially
different discipline in this state; …

If this court determines that any of those elements exists,
this court shall enter such other order as it deems

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appropriate. The burden is on the party seeking different
discipline in this jurisdiction to demonstrate that the
imposition of the same discipline is not appropriate.

In the instant case, respondent has made no showing of infirmities in the
Georgia proceeding, nor do we discern any from our review of the record.
Furthermore, we feel there is no reason to deviate from the sanction imposed in
Georgia as only under extraordinary circumstances should there be a significant
variance from the sanction imposed by the other jurisdiction. In re: Aulston , 05-
1546 (La. 1/13/06), 918 So. 2d 461. See also In re Zdravkovich, 831 A. 2d 964, 968-
69 (D.C. 2003) (“there is merit in according deference, for its own sake, to the
actions of other jurisdictions with re spect to the attorneys over whom we share
supervisory authority”).
Under these circumstances, we believe it is appropriate to defer to the Georgia
judgment imposing discipline upon respondent. Accordingly, we will impose
reciprocal discipline in the form of a two-year suspension, subject to the conditions
set forth by the Supreme Court of Georgia in its order imposing discipline.

DECREE
Considering the Petition to Initiate Reciprocal Discipline Proceedings filed by
the Office of Disciplinary Counsel and the record filed herein, it is ordered that
respondent, Christopher Antonio Tyson, Louisiana Bar Roll number 28249, be and
he hereby is suspended from the practice of law for two years, governed by the
conditions set forth by the Supreme Court of Georgia in its order imposing discipline
in In the Matter of Tyson, 321 Ga. 64, 912 S.E. 2d 637 (2025).