In the Interest of R.A.
Iowa Court of Appeals · Iowa Ct. App. · Iowa bar guidance
Verified May 5, 2026
- Citation
- In the Interest of R.A., No. 24-1629, 2025 Iowa App. LEXIS 860 (Iowa Ct. App. Oct. 1, 2025)
- Decided
- October 1, 2025
Summary
Attorney Cathleen J. Siebrecht of Siebrecht Law Firm, representing the appellant mother in a private termination of parental rights appeal, filed a reply brief containing citations to nonexistent cases and statutes along with inaccurate quotations from real authorities. Judge Buller, writing for a panel that included Chief Judge Tabor and Judge Greer, identified the defective citations while preparing for oral argument and ordered counsel to produce the authorities or explain her conduct. Counsel acknowledged she had relied on prior research notes and "secondary AI-driven research tools" after experiencing Westlaw login issues, and conceded the citations should have been verified before filing.
- AI tool:
- Unspecified generative AI
- Sanction amount:
- $150
What sanction did the court impose?
The court struck the mother's reply brief, imposed a $150 monetary penalty payable to the clerk of appellate courts within sixty days, and directed transmission of the opinion and counsel's written explanation to the Iowa Attorney Discipline Board. Counsel was permitted to elect two hours of legal ethics training specific to AI within sixty days in lieu of the $150 penalty, with written certification under oath required.
Why does In the Interest of R.A. matter for law firms using AI?
In re R.A. illustrates how appellate panels are now catching AI-fabricated citations during their own preparation for oral argument, not merely when opposing counsel flags them. The Iowa Court of Appeals expressly characterized its sanctions as “very much toward the bottom of the spectrum” and reserved the option of harsher penalties on different facts, signaling that the leniency here turned on counsel’s candor and the novelty of the conduct rather than on any tolerance for unverified AI output. For firms with appellate practices, the case underscores that an unreliable research workflow, here a Westlaw login failure backfilled with AI tools, is not a mitigating circumstance the court will excuse without a referral to discipline authorities.
Sources
Primary 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.