attorney violated rule in Iowa

2017We have recognized violations “when an attorney fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528, 537 (Iowa 2013); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Ackerman, 786 N.W.2d 491, 495 (Iowa 2010) (holding the attorney violated rule 32:1.3 for the dilatory handling of estates, despite receiving notices and inquiries from beneficiaries); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Hauser, 782 N.W.2d 147, 150-53 (Iowa 2010) (finding the attorney violated ru

2017We have recognized violations “when an attorney fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528, 537 (Iowa 2013); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Ackerman, 786 N.W.2d 491, 495 (Iowa 2010) (holding the attorney violated rule 32:1.3 for the dilatory handling of estates, despite receiving notices and inquiries from beneficiaries); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Hauser, 782 N.W.2d 147 , 150–53 (Iowa 2010) (finding the attorney violated r

2017We have recognized violations “when an attorney fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528, 537 (Iowa 2013); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Ackerman, 786 N.W.2d 491, 495 (Iowa 2010) (holding the attorney violated rule 32:1.3 for the dilatory handling of estates, despite receiving notices and inquiries from beneficiaries); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Hauser, 782 N.W.2d 147, 150-53 (Iowa 2010) (finding the attorney violated ru

2017We have recognized violations “when an attorney fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528, 537 (Iowa 2013); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Ackerman, 786 N.W.2d 491, 495 (Iowa 2010) (holding the attorney violated rule 32:1.3 for the dilatory handling of estates, despite receiving notices and inquiries from beneficiaries); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Hauser, 782 N.W.2d 147 , 150–53 (Iowa 2010) (finding the attorney violated r

2017In Engelmann-, we found an attorney violated rule 32:8,4(b) because he . acted with intent to defraud, there was significant financial harm, and the attorney’s repeated failure to disclose the true sale prices on the HUD-1 forms demonstrated a pattern of criminal conduct. 840 N.W.2d at 163 .

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Engelmann, 840 N.W.2d 156 , 162–63 (Iowa 2013) (finding an attorney violated this rule when he misrepresented information in property transactions and failed to withdraw despite numerous opportunities to do so).

2015See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kieffer-Garrison, 847 N.W.2d 489, 492 (Iowa 2014) (finding an attorney violated rule 32:1.3 when she failed “to comply with deadlines . . . in nine separate criminal cases” and also failed to pay court-imposed penalties in a prompt manner); Conroy, 845 N.W.2d at 65 (finding an attorney violated rule 32:1.3 when he “failed to timely file documents to pursue [six] appeals to which he was appointed”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kennedy, 837 N.W.2d 659, 668 (Iowa 2013) (finding an attorney violated rule 32:1.3 when her handling

2015See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kieffer-Garrison, 847 N.W.2d 489, 492 (Iowa 2014) (finding an attorney violated rule 32:1.3 when she failed “to comply with deadlines ... in nine separate criminal cases” and also failed to pay court-imposed penalties in a prompt manner); *Conroy, 845 N.W.2d at 65 (finding an attorney violated rule 32:1.3 when he “failed to timely file documents to pursue [six] appeals to which he was appointed”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kennedy, 837 N.W.2d 659, 668 (Iowa 2013) (finding an attorney violated rule 32:1.3 when her handling o

2014See id.

2012Prof'l Conduct 32:1.5(c); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Netty 797 N.W.2d 591, 598-99 (Iowa 2011) (finding that an attorney violated rule 32:1.5(c) by failing to execute a written contingent fee agreement with a client).

2021In Rhinehart, we found that an attorney violated rule 32:8.4(c) and (d), in addition to rules related to client property, during his dissolution of marriage proceeding when he committed extrinsic fraud after failing to deposit disputed funds into a trust account. 827 N.W.2d at 180–82.

2021In Rhinehart, we found that an attorney violated rule 32:8.4(c) and (d), in addition to rules related to client property, during his dissolution of marriage proceeding when he committed extrinsic fraud after failing to deposit disputed funds into a trust account. 827 N.W.2d at 180–82.

2024See Conroy, 845 N.W.2d at 65–66 (holding that an attorney violated rule 32:1.3 when he only spoke with a client once during the year he represented him and filed nothing on his behalf). 2.

2024See id. r. 32:1.4(a)(4); Conroy, 845 N.W.2d at 65 (holding that the attorney violated the rule because he only communicated with his client once and did not respond to any requests for information or updates on the case). 3.

2021The allegations were false, and we concluded the attorney violated the rule because she had no “ ‘objectively reasonable basis’ for her false attacks on the integrity of public officers.” Id. at 671 (quoting Weaver, 750 N.W.2d at 90 ).

2021The allegations were false, and we concluded the attorney violated the rule because she had no “ ‘objectively reasonable basis’ for her false attacks on the integrity of public officers.” Id. at 671 (quoting Weaver, 750 N.W.2d at 90 ).

2017We have recognized violations “when an attorney fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528, 537 (Iowa 2013); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Ackerman, 786 N.W.2d 491, 495 (Iowa 2010) (holding the attorney violated rule 32:1.3 for the dilatory handling of estates, despite receiving notices and inquiries from beneficiaries); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Hauser, 782 N.W.2d 147, 150-53 (Iowa 2010) (finding the attorney violated ru

2017We have recognized violations “when an attorney fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528, 537 (Iowa 2013); see also Iowa Supreme Ct. Att’y Disciplinary Bd. v. Ackerman, 786 N.W.2d 491, 495 (Iowa 2010) (holding the attorney violated rule 32:1.3 for the dilatory handling of estates, despite receiving notices and inquiries from beneficiaries); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Hauser, 782 N.W.2d 147 , 150–53 (Iowa 2010) (finding the attorney violated r

2025Iowa Rule of Professional Conduct 32:1.15(d) provides: “[A] lawyer shall promptly deliver to the client or third person any funds or other property that the client or third person is entitled to receive and, upon request by the client or third person, shall promptly render a full accounting regarding such property.” See also Boles, 808 N.W.2d at 439 (agreeing with the commission that an attorney violated rule 32:1.15(d) where the attorney “took seventeen months and ignored numerous refund requests before refunding” client funds).

2016In Iowa Supreme Court Attorney Disciplinary Board v. Boles, we found an attorney violated rule 32:1.15(d) when he failed to return fees to clients for seventeen months, in addition to other rule violations. 808 N.W.2d 431, 439 (Iowa 2012).

2024Id.

2018See Weiland , 885 N.W.2d at 210 (finding the attorney violated rule 32:1.4(a)(4) for lying to his client that he had filed the petition when the client asked for an update and for continuing to mislead her by blaming the delay on the process server).

2018We have found that an attorney violated this rule by withdrawing advance fees before they had been earned, noting that “[t]aking fees in advance of earning them is illegal.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Parrish, 801 N.W.2d 580, 586 (Iowa 2011) (quoting Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. D’Angelo, 619 N.W.2d 333, 337 (Iowa 2000)); cf. Iowa Supreme Ct. Att’y Disciplinary Bd. v. Rhinehart, 827 N.W.2d 169, 181 (Iowa 2013) (concluding attorney collected an unreasonable fee in violation of this rule by failing to deduct fees the client previously paid, as was required b

2018We have found that an attorney violated this rule by withdrawing advance fees before they had been earned, noting that "[t]aking fees in advance of earning them is illegal." Iowa Supreme Ct. Att'y Disciplinary Bd. v. Parrish , 801 N.W.2d 580 , 586 (Iowa 2011) (quoting Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. D'Angelo , 619 N.W.2d 333 , 337 (Iowa 2000) ); cf. Iowa Supreme Ct. Att'y Disciplinary Bd. v. Rhinehart , 827 N.W.2d 169 , 181 (Iowa 2013) (concluding attorney collected an unreasonable fee in violation of this rule by failing to deduct fees the client previously paid, as was req

2015See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kieffer-Garrison, 847 N.W.2d 489, 492 (Iowa 2014) (finding an attorney violated rule 32:1.3 when she failed “to comply with deadlines . . . in nine separate criminal cases” and also failed to pay court-imposed penalties in a prompt manner); Conroy, 845 N.W.2d at 65 (finding an attorney violated rule 32:1.3 when he “failed to timely file documents to pursue [six] appeals to which he was appointed”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kennedy, 837 N.W.2d 659, 668 (Iowa 2013) (finding an attorney violated rule 32:1.3 when her handling

2015See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kieffer-Garrison, 847 N.W.2d 489, 492 (Iowa 2014) (finding an attorney violated rule 32:1.3 when she failed “to comply with deadlines ... in nine separate criminal cases” and also failed to pay court-imposed penalties in a prompt manner); *Conroy, 845 N.W.2d at 65 (finding an attorney violated rule 32:1.3 when he “failed to timely file documents to pursue [six] appeals to which he was appointed”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kennedy, 837 N.W.2d 659, 668 (Iowa 2013) (finding an attorney violated rule 32:1.3 when her handling o

2019We considered a claim that an attorney violated this rule in Iowa Supreme Court Attorney Disciplinary Board v. Casey, 761 N.W.2d 53, 60 (Iowa 2009) (per curiam).

2019We considered a claim that an attorney violated this rule in Iowa Supreme Court Attorney Disciplinary Board v. Casey , 761 N.W.2d 53 , 60 (Iowa 2009) (per curiam).

2017See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelissen, 871 N.W.2d 694, 700 (Iowa 2015) (finding an attorney violated rule 34:8.4(c) when she “knew her firm was not doing monthly reconciliations, even though she claimed it was”).

2016See Nelissen, 871 N.W.2d at 700 (concluding an attorney violated this rule when “the Board sent a series of letters ..., as to which it received no response”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Humphrey, 812 N.W.2d 659, 665 (Iowa 2012) (concluding an attorney violated this rule when he disregarded a letter from the Board - seeking information and “also failed to reply to a second Board letter sent three months later seeking the same ... information”).

2016In McCarthy , we found the attorney violated rule 32:1.15(d) by not returning a client’s funds for eleven months. 814 N.W.2d at 607 .

2015We have also concluded an attorney violated rule 32:1.3 when he “failed to appear at a pretrial conference and a hearing.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCarthy, 814 N.W.2d 596, 606 (Iowa 2012); see also Nelson, 838 N.W.2d at 537 (finding .an attorney violated rule 32:1.3 when he “did not attend three pretrial hearings”); Iowa Supreme Ct. Att’y Disci *118 plinary Bd. v. Hauser, 782 N.W.2d 147, 150, 152 (Iowa 2010) (finding an attorney committed neglect when he failed to ap-pearfor his client’s civil trial); Adams, 749 N.W.2d at 669 (finding an attorney violated rule 32:1.3 when h

2016We have found a violation of this rule for a wide range of behavior; however, in all cases where a violation of this rule is alleged, we “require a reasonable level of scienter to find an attorney violated rule 32:8.4(c).” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Qualley, 828 N.W.2d 282, 292 (Iowa 2013).

2016When a violation of this rule is alleged, we “require a reasonable level of scienter to find an attorney violated rule 32:8.4(c).” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stoller, 879 N.W.2d 199, 212 (Iowa 2016) (quoting Iowa Supreme Ct. Att’y Disciplinary Bd. v. Qualley, 828 N.W.2d 282, 292 (Iowa 2013)).

2015See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kieffer-Garrison, 847 N.W.2d 489, 492 (Iowa 2014) (finding an attorney violated rule 32:1.3 when she failed “to comply with deadlines . . . in nine separate criminal cases” and also failed to pay court-imposed penalties in a prompt manner); Conroy, 845 N.W.2d at 65 (finding an attorney violated rule 32:1.3 when he “failed to timely file documents to pursue [six] appeals to which he was appointed”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kennedy, 837 N.W.2d 659, 668 (Iowa 2013) (finding an attorney violated rule 32:1.3 when her handling

2015See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kieffer-Garrison, 847 N.W.2d 489, 492 (Iowa 2014) (finding an attorney violated rule 32:1.3 when she failed “to comply with deadlines ... in nine separate criminal cases” and also failed to pay court-imposed penalties in a prompt manner); *Conroy, 845 N.W.2d at 65 (finding an attorney violated rule 32:1.3 when he “failed to timely file documents to pursue [six] appeals to which he was appointed”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kennedy, 837 N.W.2d 659, 668 (Iowa 2013) (finding an attorney violated rule 32:1.3 when her handling o

2016We have concluded an attorney violated rule 32:3.4(d) when “the court granted several motions to compel and motions for sanctions filed by opposing counsel” because the attorney “repeatedly failed to provide timely discovery responses to opposing counsel’s proper requests.” Id.

2016See Hedgecoth, 862 N.W.2d at 363 (concluding on our de novo review that an attorney violated a rule of professional conduct the Board alleged he violated even though the grievance commission did not specifically address the allegation in its conclusions of law). 2 We then address whether Taylor’s 2We acknowledge the constitutional guarantee of procedural due process requires an attorney charged with an ethical violation in an attorney disciplinary proceeding be given notice of the violation with which he or she is charged sufficient to afford a meaningful opportunity to respond.

2021The allegations were false, and we concluded the attorney violated the rule because she had no “ ‘objectively reasonable basis’ for her false attacks on the integrity of public officers.” Id. at 671 (quoting Weaver, 750 N.W.2d at 90 ).

2021The allegations were false, and we concluded the attorney violated the rule because she had no “ ‘objectively reasonable basis’ for her false attacks on the integrity of public officers.” Id. at 671 (quoting Weaver, 750 N.W.2d at 90 ).

2024See Iowa Sup. Ct. Att’y Disciplinary Bd. v. Van Ginkel, 809 N.W.2d 96, 103 (Iowa 2012) (concluding that the attorney violated rule 32:8.4(d) because the attorney’s multi-year procrastination caused the district court to expend valuable judicial resources to issue orders, extend deadlines, and clean up the ongoing probate proceedings).

2013Under rule 32:1.3, “an ethical violation does not typically occur from one missed deadline, but arises when a lawyer ‘repeatedly fail[s] to perform required functions as attorney....’” Iowa Supreme Ct. Att’y Disciplinaiy Bd. v. Van Ginkel, 809 N.W.2d 96, 102 (Iowa 2012) (quoting Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Grotewold, 642 N.W.2d 288, 293 (Iowa 2002)).

2021In addition, the lawyer’s letter impeded the administration of justice because it “spurred a lengthy and costly investigation into the allegations of misconduct and coercion.” Att’y Doe No. 792, 878 N.W.2d at 199 (discussing Kennedy, 837 N.W.2d at 663–64). 21 In Iowa Supreme Court Attorney Disciplinary Board v. Weaver, the district court sentenced a former district associate judge to a two-year term of incarceration following his conviction for operating while intoxicated, second offense.

2021In addition, the lawyer’s letter impeded the administration of justice because it “spurred a lengthy and costly investigation into the allegations of misconduct and coercion.” Att’y Doe No. 792, 878 N.W.2d at 199 (discussing Kennedy, 837 N.W.2d at 663–64). 21 In Iowa Supreme Court Attorney Disciplinary Board v. Weaver, the district court sentenced a former district associate judge to a two-year term of incarceration following his conviction for operating while intoxicated, second offense.

2020See Stansberry, 922 N.W.2d at 597 (holding an attorney violated the rule of professional misconduct against sexual harassment in part by victimizing attorneys who had lower seniority than him in the county attorney’s office).

2020See Stansberry, 922 N.W.2d at 597 (holding an attorney violated the rule of professional misconduct against sexual harassment in part by victimizing attorneys who had lower seniority than him in the county attorney’s office).

2019See Dolezal , 841 N.W.2d 114 , 124 (Iowa 2013).

2019See Dolezal, 841 N.W.2d 114, 124 (Iowa 2013).