Iowa Supreme Court Attorney Disciplinary Board v. Pazdernik
Iowa Supreme Court · Iowa · Iowa bar guidance
Verified April 26, 2026
- Citation
- Iowa Sup. Ct. Att'y Disciplinary Bd. v. Pazdernik, No. 25-1618 (Iowa Oct. 31, 2025)
- Decided
- October 31, 2025
Summary
Cedar Rapids attorney Richard Louis Pazdernik, Jr. was publicly reprimanded after filing a September 30, 2024 brief in Iowa County Case No. MRNTA0048564 containing citations that did not support the propositions asserted, were miscited (an Indiana case offered as Iowa authority), or were entirely fictitious. After the trial court ordered him to produce the cited cases, Pazdernik filed a response blaming a transcription error even though he knew his legal assistant had used ChatGPT to edit the brief. His amended brief repeated the same citation defects, and the court admonished him for failing to submit accurate citations and misrepresenting the law.
- AI tool:
- ChatGPT
What sanction did the court impose?
Public reprimand entered by the Iowa Supreme Court Attorney Disciplinary Board (Grievance Commission No. 2024-24310) for violations of Iowa Rules of Professional Conduct 32:3.3(a)(1) (candor to the tribunal), 32:5.3(b) (supervision of nonlawyer assistants), and 32:8.4(d) (conduct prejudicial to the administration of justice). The Iowa Supreme Court, per Justice Thomas D. Waterman, ordered the reprimand made public on October 31, 2025 after Pazdernik did not file an exception.
Why does Iowa Supreme Court Attorney Disciplinary Board v. Pazdernik matter for law firms using AI?
Pazdernik is a clean illustration of the supervision failure mode managing partners should plan for: the AI use was by a legal assistant, not the attorney of record, and the misconduct compounded when the lawyer told the court the problem was a transcription error after he already knew ChatGPT was the cause. Iowa charged the rule on supervising nonlawyers (32:5.3(b)) alongside candor and administration-of-justice violations, signaling that firms cannot insulate the supervising lawyer by routing AI use through support staff.
Sources
Further reading
Source PDF is a Westlaw printout mirrored from the Damien Charlotin hallucination database. We are working to add the underlying court docket (PACER, CourtListener, or court website) as a second source.