Incident Tracker

In re R.A. (Iowa Ct. App. 2025), No. 24-1629

referral

An Iowa appellate court struck a reply brief, imposed a $150 penalty (or an AI-ethics CLE alternative), and referred counsel to the Iowa Attorney Discipline Board after AI-driven research tools produced hallucinated citations. The court noted it had reviewed a database of more than 355 global AI-hallucination cases.

Date of decision/order

2025-10-01

Court

Court of Appeals of Iowa

Jurisdiction

US-STATE

AI tool

AI-driven research tools (unspecified)

Conduct

In a private child-in-need-of-assistance termination appeal, mother's counsel filed a reply brief citing nonexistent cases and statutes and inaccurate quotations after relying on secondary AI-driven research tools when she had Westlaw login problems.

Consequence

USD 150

Regulatory outcome

Iowa Attorney Discipline Board: The court struck the reply brief, imposed a $150 penalty (or two hours of AI-ethics CLE in lieu), and directed the clerk to transmit the opinion and counsel's written explanation to the Iowa Attorney Discipline Board. (2025-10-01)