Iowa Sup. Ct. Att'y Disciplinary Bd. v. Turner (reinstatement)
Iowa Supreme Court Attorney Disciplinary Board · Iowa Sup. Ct. · Iowa bar guidance
Verified May 1, 2026
- Citation
- In re Reinstatement of Turner (Iowa Sup. Ct., pending); see also Iowa Sup. Ct. Att'y Disciplinary Bd. v. Turner, 918 N.W.2d 130 (Iowa 2018) (underlying suspension)
- Filing date
- July 9, 2025
Summary
Royce David Turner, a Des Moines attorney suspended by the Iowa Supreme Court in December 2016, applied for reinstatement on July 5, 2025. His brief in support of the application cited a fabricated case styled In re Mears, which the Iowa Supreme Court Attorney Disciplinary Board (ADB) characterized in subsequent filings as appearing to be an AI-generated citation to a case that does not exist or does not stand for the proposition asserted. Turner cited the same fabricated authority in two additional court filings. On July 9, 2025, the ADB filed a motion to strike all three submissions and requested that the court set 2026 as the earliest date for any future reinstatement application. The Iowa Supreme Court canceled the reinstatement hearing originally scheduled for July 2025, finding Turner had not established convincing proof of fitness to practice.
- AI tool:
- AI (unspecified generative tool)
What is the current procedural posture?
Pending as of 2026-05-01. The Iowa Supreme Court has not issued a public order resolving the reinstatement application or ruling on the ADB's motion to strike; no Iowa Supreme Court reinstatement opinion has been located on iowacourts.gov. The ADB's August 2025 opposition to reinstatement (citing both the AI-generated citation and unrelated mental-health-evaluation gaps) remains the most recent public filing of record. When decided, the ruling will be the first Iowa Supreme Court matter to address the disciplinary consequences of a respondent's AI-generated citation in a board-supervised proceeding.
Why does Iowa Sup. Ct. Att'y Disciplinary Bd. v. Turner (reinstatement) matter for law firms using AI?
Turner is the first reported Iowa Supreme Court matter where AI-generated citations form part of the predicate for opposing reinstatement of a suspended attorney. The case sits at an unusual intersection: the respondent is already suspended, the conduct occurred in a respondent-controlled filing rather than an active practitioner’s litigation, and the ADB’s argument is that the AI hallucination is itself further evidence of unfitness rather than a freestanding sanctions predicate. For Iowa firms, the practical signal in Turner is not the eventual reinstatement ruling but the ADB’s stated willingness to characterize an unverified AI citation as a candor and competence failure even outside an active matter, which maps directly onto how the board will likely frame a future first-impression hallucination case against an actively practicing Iowa lawyer.
Sources
Primary sources
Further reading
- ABA (secondary source)
- https://iowacapitaldispatch.com/2025/08/21/former-lawyer-seeks-reinstatement-after-sanctions-arrest-and-contempt-findings/
- https://nonpareilonline.com/news/state-regional/crime-courts/article_70717481-46e6-415b-a527-250d5ce29b2a.html
- The full text of the ADB's July 9, 2025 motion to strike has not been located as a public court document on iowacourts.gov; the quoted language ('what appears to be at least one AI-generated citation...') is reported by ABA Journal and Iowa Capital Dispatch from filed briefs but has not been independently verified against a primary court PDF.
- The Iowa Supreme Court has not issued a public order resolving the motion to strike or the reinstatement application as of the verification date; iowacourts.gov opinion search returns no Turner reinstatement opinion.
- The 2018 underlying disciplinary opinion at 918 N.W.2d 130 has not been independently re-verified at a primary URL in this verification pass; reference is included for procedural context.