Iowa

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Iowa Ct. App. – Judge Tyler J. Buller 10/1/2025  Generative AI Generative AI Usage In In the Interest of R.A., 2025 Iowa App. LEXIS 860 (Iowa Ct. App. Oct. 1, 2025), the attorney for the mother-appellant included citations to non-existent case law and statutes and poorly worded citations in the reply brief on appeal of the private termination of the mother’s parental rights. In response to the court’s request to provide copies of the cited authorities, counsel admitted that she had improperly relied upon “secondary AI-driven research tools,” conceded that monetary sanctions were appropriate in light of her actions, and “apologized for the burden she had imposed on the court.” As part of her remorse, counsel also stated that she would not submit any filing “without full access to verified research databases or conducting a rigorous line-by-line cite check.” Judge Buller appreciated the attorney’s apology and remediation plan but noted that the AI misuse required the court to expend resources “to this side quest that could have been deployed rendering decisions on the merits.” The court reviewed hundreds of AI misuse opinions that have been issued to date and found the following sanctions to be appropriate in this case: (i) striking the reply brief; (ii) imposing a $150 penalty, or, in the alternative, requiring attendance at 2 hours of CLE trainings focused on AI; and (iii) sending a copy of this opinion to the Attorney Discipline Board.
Applies to AI Used for Filings/Drafting
Court-Imposed Consequences – Attorneys/Law Firms