Iowa Supreme Court Attorney Disciplinary Board v. Pazdernik
Iowa Supreme Court · Iowa · Iowa bar guidance
Verified September 30, 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?
The Iowa Supreme Court Attorney Disciplinary Board issued the public reprimand, by letter dated July 21, 2025 (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). By order signed October 31, 2025, the Iowa Supreme Court ordered "that the reprimand of Richard Louis Pazdernik, Jr. be included in the records of this court as a public document."
Why does Iowa Supreme Court Attorney Disciplinary Board v. Pazdernik matter for law firms using AI?
Pazdernik is a reprimand in which the AI use was by a legal assistant, not the attorney of record. The Board found that when counsel told the court the problem was a transcribing error, counsel already knew the cause “was misuse of AI,” having told the assistant to stop using it, and that the transcribing account “was not true.” The reprimand cites the rule on supervising nonlawyers (32:5.3(b)) alongside the candor and administration-of-justice rules, noting that counsel “did not check the citations in the amended brief before filing it.” Firms that allow staff to use AI tools may wish to note that the reprimand treated the lawyer’s oversight of the assistant as a separate violation.