Iowa Sup. Ct. Att'y Disciplinary Bd. v. Turner (reinstatement)

How did the court address the AI-related conduct?

The July 18, 2025 order set a reinstatement hearing for September 11, 2025; a July 31, 2025 order canceled that hearing, and the docket comment records that the "court reiterates respondent must meet noted requirements before court will schedule another hearing." The Board filed compliance reports and requests for an order on July 25 and August 14, 2025. On September 26, 2025, the court entered an order recorded on the docket as "reinstatement denied; prohibited frm filing application for 1 yr." Turner moved for reconsideration; a November 5, 2025 order is recorded as "motion to reconsider denied; prohibited from filing reinstatement appl until 09/26/26," with the note that the court "will not consider any filings from Turner until after 9-26-2026." Only these docket comments are public; the orders' reasoning, including whether the AI-flagged citation played any part, is not available. Turner filed another motion to reconsider on January 27, 2026, with no ruling docketed. The current posture is a new application for reinstatement filed September 26, 2026, with a motion to grant it without a hearing.

Why does Iowa Sup. Ct. Att'y Disciplinary Bd. v. Turner (reinstatement) matter for law firms using AI?

Turner is an unusual AI-citation matter because the filer was a suspended lawyer seeking his own reinstatement, and the party raising the problem was the disciplinary board rather than an opposing litigant. The Board’s July 9, 2025 motion is short: it identifies one citation, “In re Mears, 979 N.W.2d 122 (Iowa 2022),” across three filings, describes it as “what appears to be at least one AI-generated citation to a case that does not exist or does not stand for the proposition asserted,” and asks that the filings be stricken while reserving the Board’s other objections to reinstatement.

What the court did with that motion is not visible on the public record. The docket shows a hearing set and then canceled, a denial of reinstatement on September 26, 2025 with a one-year bar on new applications, and a denial of reconsideration. The Board’s other docketed filings in the same period are titled as compliance reports and requests for orders, and the docket comments do not tie the denial to the flagged citation. The entry therefore records the citation and the Board’s motion as the AI event, and the reinstatement denial as the outcome of the 2025 application, without attributing a cause the record does not show.

Turner filed a new reinstatement application on September 26, 2026, the date named in the November 5, 2025 order. Firms documenting compliance may wish to consider that citation-verification practices apply equally to a lawyer’s own filings in disciplinary and reinstatement proceedings, where the reviewing body is the same court that regulates the license.