Per Curiam. Jenny Lindsay appeals the denial by the Board of Bar Examiners (“Board”) of her petition for waiver of certain educational eligibility requirements prescribed under the Supreme Court of Georgia Rules Governing Admission to the Practice of Law (“Rules”). For the reasons discussed below, we conclude that the Board did not abuse its discretion in denying Lindsay’s waiver petition. Therefore, we affirm. Lindsay was educated at De Montfort University in Leicester, United Kingdom and is licensed to practice law in England, Wales, and parts of the Caribbean. In the fall of 2018, she enrolled in an LL.M. program at Emory University School of Law (“Emory”). Following the completion of her LL.M. program, Lindsay sought to apply to take the Georgia Bar Exam. All applicants seeking to take the Georgia Bar Examination are required, among other things, to satisfy various educational requirements as a condition of eligibility to take the exam. See generally Rules, Part B, § 4. One such requirement is the conferral of a professional degree in law – i.e., a J.D. or an LL.B. – from a law school approved by the American Bar Association (“ABA”). See id. at § 4 (b) (1). For lawyers educated outside of the United States, the Rules provide that the requirement of § 4 (b) (1) may be satisfied if the lawyer (1) “[r]eceived his or her legal education and graduated from a foreign law school” meeting certain criteria; (2) “[i]s authorized to practice law in a foreign jurisdiction”; and (3) has been awarded an LL.M. by an ABA-approved law school. See id. at § 4 (c). In addition, for all applicants, the Rules provide that “[a]n applicant shall not be permitted to take the examination unless evidence is first received directly from the schools involved showing that he or she meets the educational requirements of these Rules.” Id. at § 4 (d). The “evidence” so required must be in the form of an official transcript. See id.[1] Thus, the Rules require both the fulfillment of the educational requirements and the corresponding documentation in the form of an official transcript. Lindsay was unable to obtain an official transcript from Emory by the published deadline for the Bar Exam she sought to take, which was administered in October 2020.[2] As detailed in Lindsay’s waiver petition, she was involved in a dispute with Emory, which arose after she was involuntarily withdrawn from a mandatory contracts class for failure to comply with the class attendance policy. Lindsay filed a grievance – which was ultimately unsuccessful – and she maintained that this dispute remained unresolved and warranted her nonpayment of university fees. Although Lindsay was ultimately permitted to register for courses and apparently completed her degree requirements, she continued to withhold payment, and a hold was placed on her student account. As a result of the hold, Emory’s Registrar refused to release Lindsay’s official law school transcript, and she missed the applicable deadline for submission of her transcript to the Office of Bar Admissions, which made her ineligible to take the October 2020 Bar Exam. Consequently, Lindsay submitted a petition to the Board for a “waiver of the educational requirements of the Bar Examinations and/or the official transcript.”[3] In her petition, Lindsay contended that there was good cause to waive the educational requirements due to her legal education and “long years of practical legal service in common law jurisdictions,” and because her inability to obtain an official law school transcript was the result of Emory’s “recalcitrant disregard” for her “civil, human, and constitutional rights.” Lindsay detailed at length her experience in the practice of law in the United Kingdom and the Caribbean and her efforts to resolve the dispute with Emory. Contending that these factors established good cause for a waiver, Lindsay proposed that a waiver could take one of three forms: (1) a waiver of the transcript requirement altogether; (2) the substitution of an unofficial transcript for the official transcript; or (3) the filing of an official transcript “after court proceedings and/or amicable settlement.” The Board denied the petition. In its denial letter, the Board stated that Lindsay did not satisfy [her] burden of demonstrating good cause for waiver of the clearly posted transcript deadline and . . . failed to demonstrate good cause for waiver of the requirement that [she], as a lawyer educated at a law school located outside the United States and its territories, [was] awarded, by a law school fully approved by the American Bar Association, an LL.M. degree for the Practice of Law in the United States in a degree program that meets the Board’s requirements. See [Rules], Part B, [§] 4 (c). This appeal ensued. As a preliminary matter, this Court has the inherent authority to set requirements for the admission to practice law in the State of Georgia. See In re Oliver, 261 Ga. 850, 851 (2) (413 SE2d 435) (1992). “[A]dmission to the State Bar is governed by the Rules promulgated by this Court, which place the burden on the applicant to establish the fitness to practice law.” In re G.E.C., 269 Ga. 744, 745 (1) (506 SE2d 843) (1998). The Board may waive any of these Rules, including the educational eligibility requirements to sit for the Bar Exam, “for good cause shown by clear and convincing evidence.” Rules, Part F, § 5. The good cause standard for a waiver is flexible and judged according to the circumstances of the individual case. See id. at 745 (2). According to the Board’s published Waiver Process and Policy,[4] the Board considers waivers of the educational requirements on a case-by-case basis. Applicants for a waiver of educational requirements are required, among other things, to submit a “Dean’s letter” that “analyz[es] the legal education [the applicant] received and stat[es] whether or not it is the equivalent of an ABA-approved legal education.” See Waiver Process & Policy. The Board has published detailed guidelines for the content of such a Dean’s letter.[5] Here, it appears that Lindsay was requesting either (a) a waiver of the official transcript requirement – i.e., a waiver of the documentation required to establish her fulfillment of the educational requirements in one of the three ways she suggests in her petition; or (b) a waiver of the actual educational requirement that she receive an LL.M. from an ABA-approved law school, if she was unable to document her fulfillment thereof by providing official documentation. On appeal, the Board’s denial of these waiver requests will be affirmed absent an abuse of discretion. See In re G.E.C., 269 Ga. at 744. With regard to the transcript requirement, Lindsay asserts that she “made every attempt” to obtain her transcript from Emory and that the substance of her dispute with Emory demonstrates the good cause warranting a waiver of the transcript requirement. The record indicates that Lindsay failed to pay the outstanding amounts on her student account, which prevented Emory from releasing her transcript. Although Lindsay reached out to Emory’s Dean on the day of the transcript deadline, that deadline passed. We see no abuse of discretion in the Board’s refusal to second-guess Emory’s decision not to release Lindsay’s transcript or in the Board’s refusal to waive the requirement that she provide proof of the conferral of her LL.M. degree by the published deadline. With regard to Lindsay’s request that the Board waive that educational requirement altogether, we also see no abuse of discretion. It is undisputed that Lindsay did not submit a Dean’s letter conforming to the Board’s guidelines.[6] Lindsay argues that there is good cause for a waiver because she is in good standing in foreign countries; is an LL.M. graduate of Emory[7]; has no history of criminal conduct or professional malfeasance; has passed the Multistate Professional Responsibility Examination; has worked in law firms and commenced her own practice in foreign countries; and has attended the Hugh Wooding Law School in Trinidad. However, we see no abuse of discretion in the Board’s determination that Lindsay’s own assertions about her education and experience are not a proper substitute for the Dean’s letter and thus that Lindsay failed to establish good cause for a waiver of the educational requirements. See In re Batterson, 286 Ga. 352, 353-354 (687 SE2d 477) (2009) (no abuse of discretion in denying a petition for an educational waiver where the applicant submitted a Dean’s letter containing only general conclusions that the applicant’s education was equal to the requirements of an ABA-approved school). Denial of waiver petition affirmed. All the Justices concur.
