Iowa: AI Ethics Guidance for Law Firms

Bottom line for Iowa firms: Iowa has no ethics opinion and no court rule on AI in attorney filings; the one AI-specific court rule, chapter 27, was adopted on July 21, 2026 and takes effect January 1, 2027, and it applies to judges and their adjudicative assistants. Discipline has nonetheless followed AI-related citation failures under the existing Iowa Rules of Professional Conduct: the Attorney Disciplinary Board publicly reprimanded one lawyer under rules 32:3.3(a)(1), 32:5.3(b) and 32:8.4(d), and another under 32:1.1 and 32:8.4(d). ABA Formal Opinion 512 (July 2024) is the most detailed guidance available.

Firms documenting compliance may wish to start with: a written AI use policy, a citation verification log for every court filing, and vendor due-diligence records for each AI tool in use.

No operative bar opinion (pending activity)

The Iowa State Bar Association has issued no formal or informal ethics opinion on attorney use of generative AI. The ISBA ethics opinions index lists no AI-specific opinion as of 2026-09-29; its only AI item is a link to ABA Formal Opinion 512.

The ISBA Board of Governors, at its December 10, 2025 meeting (Iowa Bar Blog, posted December 17, 2025), approved a request “to establish an artificial intelligence committee to help members better understand both the opportunities and challenges presented by rapidly evolving AI technologies.” The committee is to review and recommend AI-powered tools and services the ISBA may offer and is “tasked with identifying, developing, and recommending CLE programs, training, and other educational resources”; it sunsets in December 2027 unless extended. Separately, the ISBA ran an AI CLE series from October to December 2025 and a 2026 AI Training Series of six live programs from January 14 through May 15, 2026, including a session on AI policy and vendor selection for law firms. The ISBA also published an Iowa Bar Blog summary of ABA Formal Opinion 512 on August 7, 2024.

In the absence of a state opinion, the Iowa Rules of Professional Conduct in Chapter 32 of the Iowa Court Rules apply directly. Iowa’s rules closely track the ABA Model Rules, and comment 8 to rule 32:1.1 states that a lawyer should keep abreast of “the benefits and risks associated with relevant technology.” ABA Op 512’s analysis maps to Iowa RPC 32:1.1 (competence), 32:1.4 (communication), 32:1.5 (fees), 32:1.6 (confidentiality), 32:3.3 (candor), 32:5.1 and 5.3 (supervision), and 32:8.4 (misconduct).

What federal courts in Iowa require for AI use in filings

No district-wide AI standing order has been identified in either the Northern District of Iowa or the Southern District of Iowa. The Southern District of Iowa publishes advisory AI guidance and FAQs: AI use is not prohibited and “The Southern District of Iowa does not currently require disclosure regarding the use of AI in court filings,” but “all litigants are personally responsible for verifying the accuracy of the AI generated material, including quotations, citations, paraphrased assertions, and legal analysis,” and failure to verify could result in Rule 11 sanctions. The court notes it could require disclosure by order in a specific case. Chief Judge C.J. Williams (N.D. Iowa) co-authored an article on AI in federal courts in the December 2025 issue of The Iowa Lawyer. The operative federal default is Fed. R. Civ. P. 11. Individual judge standing orders are not fully catalogued; firms with federal matters may wish to check the assigned judge’s standing orders at iand.uscourts.gov or iasd.uscourts.gov before filing.

What Iowa state courts require for AI use in filings

Iowa has no court rule on AI use in attorney filings. The Iowa Supreme Court orders index, reviewed 2026-09-29, lists no statewide filing rule on AI. The Iowa Supreme Court’s AI rule, Iowa Court Rules chapter 27 (adoption order; tracker entry), adopted July 21, 2026 and effective January 1, 2027, applies from that date to judicial officers and their adjudicative assistants, not filers (see Section 6).

The Iowa Court of Appeals has addressed AI-fabricated citations directly. In In re R.A. (No. 24-1629, Oct. 1, 2025; tracker entry) it struck a reply brief, imposed a $150 penalty (or, at counsel’s election, two hours of AI ethics training), and sent the opinion to the Attorney Disciplinary Board. In Luke v. Department of Health and Human Services (No. 24-1421, Aug. 6, 2025) it stressed that “self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools.” In Wilkinson v. Schmelzer (No. 25-0799, Aug. 19, 2026; tracker entry) it declined sanctions premised on suspected AI use, observing that “absent the presence of a hallucinated case, it is difficult to differentiate poor human drafting from unverified generative AI.”

Iowa attorney discipline involving AI

Pazdernik (No. 25-1618). On October 31, 2025 the Iowa Supreme Court ordered the Board’s public reprimand of attorney Richard Louis Pazdernik, Jr. made public. The Board found that a brief contained fictitious and miscited authority, that he told the district court the problem was a transcribing error when he knew his staff’s use of ChatGPT was the cause, and that he did not check the citations in an amended brief; it cited rules 32:3.3(a)(1), 32:5.3(b) and 32:8.4(d). See the tracker entry.

Siebrecht (No. 26-0525). On April 9, 2026 the court filed the Board’s February 9, 2026 letter of public reprimand of attorney Cathleen Jane Siebrecht. The Board found that she used AI in drafting a reply brief in Case No. 24-1629 (In re R.A., above), that “two cases you cited were entirely hallucinated,” and that she did not independently verify them. It stated that “Lawyers may use AI-assisted tools, but they remain fully responsible for the accuracy of every citation and legal assertion submitted to a court,” and found violations of rules 32:1.1 and 32:8.4(d), citing comment 8 to rule 32:1.1.

Turner reinstatement (No. 18-0352). In a motion dated July 9, 2025, the Board asked the court to strike three filings by suspended attorney Royce D. Turner in his reinstatement proceeding, each citing “In re Mears,” which the Board described 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 in the filings.” The Iowa Courts Online docket records a September 26, 2025 order denying reinstatement and barring a new application for one year, and a November 5, 2025 order denying reconsideration. The order texts are not public, so the court’s reasoning is not known. Turner filed a new reinstatement application on September 26, 2026. See the tracker entry.

What AI-related rules are pending in Iowa?

ISBA AI committee (approved December 10, 2025). No ISBA ethics opinion or model AI policy has issued from the committee as of 2026-09-29. The Iowa Bar Blog is where its work is likely to be announced.

Iowa Judicial Branch AI Working Group and chapter 27. In the 2026 Condition of the Judiciary (January 14, 2026), Chief Justice Susan Larson Christensen noted that Justice Christopher McDonald “is leading the judicial branch’s Artificial Intelligence Working Group which helps determine how AI should be used—and regulated—to ensure our courts remain both efficient and fair.” According to the court’s adoption order, the working group was established by administrative directive on August 28, 2025 and recommended rules to the court in April 2026; on July 21, 2026 the court adopted them as Iowa Court Rules chapter 27, Judicial Use of Artificial Intelligence Tools, effective January 1, 2027. From that date, chapter 27 requires judicial officers to keep independent decision-making responsibility, requires judicial officers and adjudicative assistants to “independently verify the accuracy of all factual or legal sources in any work product prepared by an artificial intelligence tool,” and limits use of AI tools with judicial case information to tools approved by a governance committee. It does not address filings by attorneys or parties.

Iowa SF 2417 (conversational AI services). Signed by Governor Reynolds on May 2, 2026 as Acts Chapter 1068, effective July 1, 2026 with an applicability date of July 1, 2027 (legislative bill history). The act regulates “operators,” meaning persons who develop and make a conversational AI service available to the public. It includes a general disclosure duty toward users who would believe they are talking to a human, additional duties toward minor account holders, a protocol for suicide and self-harm, and a bar on representing that the service provides licensed mental-health services. The attorney general enforces it; a violating operator is liable for the greater of actual damages or a civil penalty of $1,000 per violation, up to $500,000 per operator. SF 2417 does not impose ethics duties on attorneys directly, and it excludes several categories of service, including tools used for internal purposes and some tools designed for business use with customers. A firm offering a public-facing AI intake tool may wish to consider whether it is an “operator” under the act.

The December 2025 issue of The Iowa Lawyer covers AI in legal practice, including Rule 11 in federal court, drafting firm AI policies, and ethical duties. The articles are not ethics opinions and carry no binding authority.

How do malpractice carriers in Iowa treat AI use?

The ISBA Insurance Program, developed with Lockton Affinity, places coverage with CNA (program page); ALPS also writes lawyers’ professional liability coverage in Iowa, and other carriers are active in the state. No Iowa-specific AI guidance from CNA or ALPS was identified in this review. Industry-wide, AI-specific exclusions are beginning to appear in some professional liability policies, so Iowa firms may wish to review their policy for AI exclusions or limitations before relying on coverage for AI-related claims.

What does my Iowa malpractice carrier ask about AI at renewal?

No Iowa malpractice carrier has published specific AI application items in materials reviewed for this entry. Firms preparing for renewal questions may wish to have four artifacts ready: a written AI use policy, vendor due-diligence records for each AI tool, citation-verification logs for court filings, and training records for attorneys and staff. Application items and AI exclusion language are best confirmed directly with the ISBA insurance program or a broker before binding.

What documentation should an Iowa firm keep on file?

Month one (foundational)

1. (Owner: managing partner + firm administrator) Written AI use policy. Cover approved tools, prohibited uses (no client-identifying information in consumer AI tools), verification requirements for AI output, citation-checking procedures, and signed acknowledgments. Anchored in Iowa RPC 32:5.1 and 32:5.3 and the ABA Op 512 framework.
2. (Owner: litigation lead) Citation verification log or checklist for every court filing, recording independent verification of each AI-generated citation against primary sources before submission. Both Iowa AI reprimands turned on unverified citations.
3. (Owner: firm administrator) Attorney and staff training records documenting AI ethics training: hallucination risks, competence under Iowa RPC 32:1.1 and its comment 8, candor under 32:3.3, confidentiality under 32:1.6, and the firm’s AI use policy. Addresses 32:5.3 supervision of nonlawyer staff.

Months two and three (operational documentation)

1. (Owner: firm administrator + outside IT) AI vendor due-diligence records for each tool processing client information: privacy policy version reviewed, data retention and training practices, and whether a data processing agreement is executed. Anchored in Iowa RPC 32:1.6.
2. (Owner: managing partner) Supervision protocol for associate and staff AI use under Iowa RPC 32:5.1 and 32:5.3, including who reviews and approves AI output before it reaches a client or a tribunal. The Pazdernik reprimand applied rule 32:5.3(b) to a lawyer whose staff used ChatGPT.
3. (Owner: matter lead attorney) Engagement letter AI disclosure. Describe that the firm may use AI tools, the supervision and verification procedures, and how the firm obtains client consent for processing client information through third-party AI platforms. Addresses Iowa RPC 32:1.4 and 32:1.6.

Months four to six (per-matter discipline)

These are recurring practices, not one-time projects: each new matter exercises them.

1. (Owner: matter lead attorney) Per-matter AI use notes recording which AI tools were used, for what task (research, drafting, summarization), and which attorney verified and approved the output.
2. (Owner: billing partner) Billing disclosures for AI tool costs under Iowa RPC 32:1.5: subscription costs as overhead, time displaced by AI not billed at unadjusted hourly rates, AI-driven efficiency reflected in the bill.
3. (Owner: matter lead attorney) Judge-specific AI order check at each new federal matter in N.D. Iowa or S.D. Iowa, reviewing the assigned judge’s individual standing orders for AI disclosure requirements and documenting the check.

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