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Incident Tracker / United States (state)

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

·Court of Appeals of Iowa·US-STATERegulatory 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.

Court
Court of Appeals of Iowa
Date
2025-10-01
Who used the AI
Not recorded
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.
Outcome
Regulatory referral
Penalty
US$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)
Status
Verified against listed sources
Last checked
2026-09-11

What was fabricated or misused

  • Mother's reply brief — citations to cases and statutes that did not exist, quotations from real authorities that were inaccurate, and other authorities described so erroneously that no reasonable attorney could have made the error

What the court said

“And in this case, we are confronted with an attorney who did not fulfill that duty to verify AI-generated work product.”
Court of Appeals of Iowa, p. 5
“Particular to this case, our court discovered while preparing for oral argument that the mother’s reply brief appeared to include citations to cases and statutory text that do not exist and described other authorities so erroneously that no reasonable attorney could have made the error.”
Court of Appeals of Iowa, p. 6
“Her reply brief contained “citations to cases and statutes that do not exist, or are not accurately quoted.””
Court of Appeals of Iowa, p. 7
“we direct the clerk of appellate courts to transmit a copy of this opinion and counsel’s written explanation to the Attorney Discipline Board (ADB) when this opinion is filed.”
Court of Appeals of Iowa, p. 9

Timeline

  1. At oral argument, counsel said she was humbled by the court's discovery of the AI errors.
  2. The Iowa Court of Appeals affirmed both termination appeals.
  3. The court struck the mother's reply brief and imposed a $150 penalty or AI-ethics CLE.
  4. The clerk was directed to transmit the opinion and counsel's explanation to the Attorney Discipline Board.

Why this case matters

In re R.A. brings AI hallucinations into a private termination appeal, a setting where the court was careful not to penalize the parent for counsel's filing. The Iowa court struck only the reply brief, imposed a low $150 penalty or two hours of AI-ethics CLE, and referred the matter to the Attorney Discipline Board. Compared with Johnson v Dunn, the order is lighter, but it is significant because the court tied verification to appellate volume and child-welfare merits rather than commercial litigation costs.

Practice note

When access to a paid database fails, counsel should ask for more time or use another verified source rather than rely on secondary AI research notes. The remedial plan the court quoted is concrete: full access to verified databases or a line-by-line cite check against official sources before filing any brief.

Primary sources for this incident

Related regulation records for this incident

No related regulation record has been linked to this incident yet.

Similar incidents on the record

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  • Prososki v. Regan, 321 Neb. 38 (2026)2026-03-20 · Nebraska Supreme Court · Regulatory referralThe Nebraska Supreme Court struck an appellant's brief in a divorce appeal after finding 57 of 63 citations defective, including about 20 AI hallucinations and three fabricated cases, dismissed the appeal, and referred…
  • Mezu v. Mezu (Md. App. Ct. 2025), No. 361 Sept. Term 20252025-10-29 · Appellate Court of Maryland · Regulatory referralMaryland's intermediate appellate court referred an attorney to the state Attorney Grievance Commission after his client's brief cited multiple fictitious ChatGPT-generated cases and he conceded he routinely did not rea…

Cite this record

SafeLegalAI Global Legal AI Incident Tracker, “In re R.A. (Iowa Ct. App. 2025), No. 24-1629”, safelegalai.com/tracker/in-re-ra-iowa (accessed 2026-09-16). Data: CC BY 4.0.

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