colorable future claim in Iowa

2022Normally, “[m]isappropriation of funds held in trust ‘results in revocation, except in instances in which the attorney had a colorable future claim to the funds or did not take the funds for personal use.’ ” Kozlik, 943 N.W.2d at 598 (quoting Iowa Sup. Ct. Att’y Disciplinary Bd. v. Carter, 847 N.W.2d 228, 232 (Iowa 2014)).

2022“When an attorney converts funds without a colorable future claim, ‘we need not consider mitigating and aggravating factors that may be present.’ ” Id. at 600 15 (quoting Guthrie, 901 N.W.2d at 500 ).

2020We found Kelsen violated all of the rules alleged and “among those violations, Kelsen converted $7500 of client funds to personal use without a colorable future claim to the funds.” Id.

2015Finally, “an attorney crosses an important line when he or she misappropriates or converts client funds without a colorable future claim to those funds.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kelsen, 855 N.W.2d 175, 182 (Iowa 2014) (internal quotation marks omitted).

2015See Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCann, 712 N.W.2d 89, 97 (Iowa 2006) (suspending an attorney who misappropriated funds with a colorable future claim to the money).

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Boles, 808 N.W.2d 431 , 441–43 (Iowa 2012) (suspending the license of a criminal defense attorney for thirty days who among other things “withdrew unearned fees”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Parrish, 801 N.W.2d 580 , 586–87, 590 (Iowa 2011) (suspending a criminal defense attorney’s license for sixty days for several instances of failing to timely refund unearned fees to a client and withdrawing fees from a trust account before they were earned); Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCann, 712 N.W.2d 89, 97 (Iowa 2006) (impos

2019Guthrie , 901 N.W.2d at 500 -01 *171 ("[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney's license to practice law."); Iowa Supreme Ct. Att'y Disciplinary Bd. v. Thomas , 844 N.W.2d 111 , 117 (Iowa 2014) ("The amount of money an attorney converts does not lessen the sanction."); Comm. on Prof'l Ethics & Conduct v. Ottesen , 525 N.W.2d 865 , 866 (Iowa 1994) ("There is no place in our profession for lawyers who convert funds entrusted to them.

2019Guthrie, 901 N.W.2d at 500–01 (“[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney’s license to practice law.”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Thomas, 844 N.W.2d 111, 117 (Iowa 2014) (“The amount of money an attorney converts does not lessen the sanction.”); Comm. on Prof’l Ethics & Conduct v. Ottesen, 525 N.W.2d 865, 866 (Iowa 1994) (“There is no place in our profession for lawyers who convert funds entrusted to them.

2020See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kowalke, 918 N.W.2d 158, 163 (Iowa 2018) (“[W]e have found revocation appropriate ‘in nearly every case where an attorney converts client funds without a colorable claim.’ ” (quoting Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017))); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Suarez- Quilty, 912 N.W.2d 150 , 159–60 (Iowa 2018) (revoking the license of an attorney who converted $630 without a colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Adams, 809 N.W.2d 543, 546 (Iowa 2012); Iowa Supreme C

2018"Misappropriation or conversion of client funds results in revocation, except in instances in which the attorney had a colorable future claim to the funds or did not take the funds for personal use." Id.

2019Cepican , 861 N.W.2d at 844 .

2019Cepican, 861 N.W.2d at 844 .

2019See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017) (“[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney’s license to practice law.”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742 (Iowa 2013) (“It is almost axiomatic that we revoke the licenses of attorneys who convert funds when the attorney did not have a colorable future claim to the funds.” (Emphasis added.)); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almos

2017See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 787 , 742 (Iowa 2013) (quoting numerous cases wherein we held revocation was the appropriate sanction when attorneys converted client funds); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almost axiomatic that we will revoke the license of an attorney who converts a client’s funds to his or her own use.”); Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Williams, 675 N.W.2d 530, 533 (Iowa 2004) (revoking attorney’s license for fictitious billing); Iowa Supreme Ct. Bd. of Prof

2016See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Lubinus, 869 N.W.2d 546, 552 (Iowa 2015).

2016Id.

2019We revoked the attorney's license because he converted funds to which he did not have a colorable future claim. 2 Id. at 742-43 .

2019We revoked the attorney’s license because he converted funds to which he did not have a colorable future claim. 2 Id. at 742–43.

2020See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kowalke, 918 N.W.2d 158, 163 (Iowa 2018) (“[W]e have found revocation appropriate ‘in nearly every case where an attorney converts client funds without a colorable claim.’ ” (quoting Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017))); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Suarez- Quilty, 912 N.W.2d 150 , 159–60 (Iowa 2018) (revoking the license of an attorney who converted $630 without a colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Adams, 809 N.W.2d 543, 546 (Iowa 2012); Iowa Supreme C

2019See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017) (“[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney’s license to practice law.”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742 (Iowa 2013) (“It is almost axiomatic that we revoke the licenses of attorneys who convert funds when the attorney did not have a colorable future claim to the funds.” (Emphasis added.)); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almos

2015Cf. Kelsen, 855 N.W.2d at 185–86 (holding revocation was appropriate sanction when record showed attorney converted $7500 of client funds to personal use without a colorable future claim to the funds); Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Leon, 602 N.W.2d 336 , 338–39 (Iowa 1999) (holding repeated misappropriation of trust funds to cover-up neglect in several clients’ cases warranted revocation); Comm. on Prof’l Ethics & Conduct v. Ottesen, 525 N.W.2d 865, 866 (Iowa 1994) (imposing revocation when routine audit revealed attorney’s conversion of at least $7334 in client funds to h

2015Cf. Kelsen, 855 N.W.2d at 185-86 (holding revocation was appropriate sanction when record showed attorney converted $7500 of client funds to personal use without a colorable future claim to the funds); Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Leon, 602 N.W.2d 336, 338-39 (Iowa 1999) (holding repeated misappropriation of trust funds to cover-up neglect in several clients’ cases warranted revocation); Co mm. on Profl Ethics & Conduct v. Ottesen, 525 N.W.2d 865, 866 (Iowa 1994) (imposing revocation when routine audit revealed attorney’s conversion of at least $7334 in client funds to hi

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Boles, 808 N.W.2d 431 , 441–43 (Iowa 2012) (suspending the license of a criminal defense attorney for thirty days who among other things “withdrew unearned fees”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Parrish, 801 N.W.2d 580 , 586–87, 590 (Iowa 2011) (suspending a criminal defense attorney’s license for sixty days for several instances of failing to timely refund unearned fees to a client and withdrawing fees from a trust account before they were earned); Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCann, 712 N.W.2d 89, 97 (Iowa 2006) (impos

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Boles, 808 N.W.2d 431, 441-43 (Iowa 2012) (suspending the license of a criminal defense attorney for thirty days who among other things “withdrew unearned fees”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Parrish, 801 N.W.2d 580, 586-87, 590 (Iowa 2011) (suspending a criminal defense attorney’s license for sixty days for several instances of failing to timely refund unearned fees to a client and withdrawing fees from a trust account before they were earned); Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCann, 712 N.W.2d 89, 97 (Iowa 2006) (imposin

2020See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kowalke, 918 N.W.2d 158, 163 (Iowa 2018) (“[W]e have found revocation appropriate ‘in nearly every case where an attorney converts client funds without a colorable claim.’ ” (quoting Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017))); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Suarez- Quilty, 912 N.W.2d 150 , 159–60 (Iowa 2018) (revoking the license of an attorney who converted $630 without a colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Adams, 809 N.W.2d 543, 546 (Iowa 2012); Iowa Supreme C

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742-43 (Iowa 2013) (revoking the license of an attorney who was convicted of a felony and converted client funds to which he had no colorable future claim); Adams, 809 N.W.2d at 546 (revoking the license of an attorney who took clients funds to which he had no colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Earley, 774 N.W.2d 301, 309 (Iowa 2009) (“Unless the attorney ‘had a colorable future claim to the funds or did not take the funds for [the lawyer’s] own use,’ revocation will be ordered.” (quoting Iow

2019See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017) (“[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney’s license to practice law.”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742 (Iowa 2013) (“It is almost axiomatic that we revoke the licenses of attorneys who convert funds when the attorney did not have a colorable future claim to the funds.” (Emphasis added.)); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almos

2017See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 787 , 742 (Iowa 2013) (quoting numerous cases wherein we held revocation was the appropriate sanction when attorneys converted client funds); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almost axiomatic that we will revoke the license of an attorney who converts a client’s funds to his or her own use.”); Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Williams, 675 N.W.2d 530, 533 (Iowa 2004) (revoking attorney’s license for fictitious billing); Iowa Supreme Ct. Bd. of Prof

2019See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017) (“[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney’s license to practice law.”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742 (Iowa 2013) (“It is almost axiomatic that we revoke the licenses of attorneys who convert funds when the attorney did not have a colorable future claim to the funds.” (Emphasis added.)); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almos

2017See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 787 , 742 (Iowa 2013) (quoting numerous cases wherein we held revocation was the appropriate sanction when attorneys converted client funds); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almost axiomatic that we will revoke the license of an attorney who converts a client’s funds to his or her own use.”); Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Williams, 675 N.W.2d 530, 533 (Iowa 2004) (revoking attorney’s license for fictitious billing); Iowa Supreme Ct. Bd. of Prof

2014The phrase first surfaced in Anderson, see 687 N.W.2d at 590 , but it was a concept we have recognized for a much longer period of time, see Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Allen, 586 N.W.2d 383, 385, 390 (Iowa 1998) (suspending the law license of a lawyer who took fees from a conservatorship without first obtaining court approval); Comm. on Prof'l Ethics & Conduct v. Jackson, 492 N.W.2d 430, 433, 435 (Iowa 1992) (suspending the law license of a lawyer who took fees before obtaining court approval required by probate rule); Comm, on Prof'l Ethics & Conduct v. Rauch, 486 N.W.

2009See, e.g., Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Allen, 586 N.W.2d 383, 391 (Iowa 1998); Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Hansel, 558 N.W.2d 186, 192 (Iowa 1997).

2022“When an attorney converts funds without a colorable future claim, ‘we need not consider mitigating and aggravating factors that may be present.’ ” Id. at 600 15 (quoting Guthrie, 901 N.W.2d at 500 ).

2022Under the colorable future claim defense,1 “[a]n attorney in a disciplinary proceeding bears the burden of coming forward with evidence of a colorable future claim, but the burden to prove conversion remains with the Board.” Id. at 598 (quoting Carter, 847 N.W.2d at 232–33).

2019Guthrie , 901 N.W.2d at 500 -01 *171 ("[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney's license to practice law."); Iowa Supreme Ct. Att'y Disciplinary Bd. v. Thomas , 844 N.W.2d 111 , 117 (Iowa 2014) ("The amount of money an attorney converts does not lessen the sanction."); Comm. on Prof'l Ethics & Conduct v. Ottesen , 525 N.W.2d 865 , 866 (Iowa 1994) ("There is no place in our profession for lawyers who convert funds entrusted to them.

2019Guthrie, 901 N.W.2d at 500–01 (“[I]n nearly every case where an attorney converts client funds without a colorable future claim, we revoke the attorney’s license to practice law.”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Thomas, 844 N.W.2d 111, 117 (Iowa 2014) (“The amount of money an attorney converts does not lessen the sanction.”); Comm. on Prof’l Ethics & Conduct v. Ottesen, 525 N.W.2d 865, 866 (Iowa 1994) (“There is no place in our profession for lawyers who convert funds entrusted to them.

2020See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kowalke, 918 N.W.2d 158, 163 (Iowa 2018) (“[W]e have found revocation appropriate ‘in nearly every case where an attorney converts client funds without a colorable claim.’ ” (quoting Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017))); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Suarez- Quilty, 912 N.W.2d 150 , 159–60 (Iowa 2018) (revoking the license of an attorney who converted $630 without a colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Adams, 809 N.W.2d 543, 546 (Iowa 2012); Iowa Supreme C

2014See Powell, 830 N.W.2d at 358-59 (addressing the broad distinction recognized by a colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Reilly, 708 N.W.2d 82, 84-85 (Iowa 2006) (same).

2016Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stoller, 879 N.W.2d 199, 222 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Att’y Doe No. 792, 878 N.W.2d 189, 201 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cepican, 861 N.W.2d 841, 844 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cross, 861 N.W.2d 211 , 219 n.3 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kelsen, 855 N.W.2d 175 , 183 n.3 (Iowa 2014); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528 , 536 n.2 (Iowa 2013); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Rickabaugh, 728 N.W.2d 375

2016Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stoller, 879 N.W.2d 199, 222 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Att’y Doe No. 792, 878 N.W.2d 189, 201 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cepican, 861 N.W.2d 841, 844 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cross, 861 N.W.2d 211 , 219 n.3 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kelsen, 855 N.W.2d 175 , 183 n.3 (Iowa 2014); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528 , 536 n.2 (Iowa 2013); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Rickabaugh, 728 N.W.2d 375

2016Iowa Supreme Ct. Att’y Disciplinary Bd. v. Reilly, 884 N.W.2d 761, 762 (Iowa 2016) (per curiam). 7 These changes make it easier for me to revoke the license of an attorney who misappropriates funds from a client with a colorable future claim to those funds.

2016Iowa Supreme Ct. Att’y Disciplinary Bd. v. Reilly, 884 N.W.2d 761, 762 (Iowa 2016) (per curiam). 7 These changes make it easier for me to revoke the license of an attorney who misappropriates funds from a client with a colorable future claim to those funds.

2016Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stoller, 879 N.W.2d 199, 222 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Att’y Doe No. 792, 878 N.W.2d 189, 201 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cepican, 861 N.W.2d 841, 844 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cross, 861 N.W.2d 211 , 219 n.3 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kelsen, 855 N.W.2d 175 , 183 n.3 (Iowa 2014); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528 , 536 n.2 (Iowa 2013); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Rickabaugh, 728 N.W.2d 375

2016Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stoller, 879 N.W.2d 199, 222 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Att’y Doe No. 792, 878 N.W.2d 189, 201 (Iowa 2016); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cepican, 861 N.W.2d 841, 844 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cross, 861 N.W.2d 211 , 219 n.3 (Iowa 2015); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kelsen, 855 N.W.2d 175 , 183 n.3 (Iowa 2014); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelson, 838 N.W.2d 528 , 536 n.2 (Iowa 2013); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Rickabaugh, 728 N.W.2d 375

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Boles, 808 N.W.2d 431 , 441–43 (Iowa 2012) (suspending the license of a criminal defense attorney for thirty days who among other things “withdrew unearned fees”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Parrish, 801 N.W.2d 580 , 586–87, 590 (Iowa 2011) (suspending a criminal defense attorney’s license for sixty days for several instances of failing to timely refund unearned fees to a client and withdrawing fees from a trust account before they were earned); Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCann, 712 N.W.2d 89, 97 (Iowa 2006) (impos

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Boles, 808 N.W.2d 431, 441-43 (Iowa 2012) (suspending the license of a criminal defense attorney for thirty days who among other things “withdrew unearned fees”); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Parrish, 801 N.W.2d 580, 586-87, 590 (Iowa 2011) (suspending a criminal defense attorney’s license for sixty days for several instances of failing to timely refund unearned fees to a client and withdrawing fees from a trust account before they were earned); Iowa Supreme Ct. Att’y Disciplinary Bd. v. McCann, 712 N.W.2d 89, 97 (Iowa 2006) (imposin

2014The phrase first surfaced in Anderson, see 687 N.W.2d at 590 , but it was a concept we have recognized for a much longer period of time, see Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Allen, 586 N.W.2d 383, 385, 390 (Iowa 1998) (suspending the law license of a lawyer who took fees from a conservatorship without first obtaining court approval); Comm. on Prof'l Ethics & Conduct v. Jackson, 492 N.W.2d 430, 433, 435 (Iowa 1992) (suspending the law license of a lawyer who took fees before obtaining court approval required by probate rule); Comm, on Prof'l Ethics & Conduct v. Rauch, 486 N.W.

2006See, e.g., Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Allen, 586 N.W.2d 383, 391 (Iowa 1998); Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Hansel, 558 N.W.2d 186, 192 (Iowa 1997); Comm. on Prof’l Ethics & Conduct v. Rauch, 486 N.W.2d 39, 40 (Iowa 1992).

2020See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Kowalke, 918 N.W.2d 158, 163 (Iowa 2018) (“[W]e have found revocation appropriate ‘in nearly every case where an attorney converts client funds without a colorable claim.’ ” (quoting Iowa Supreme Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017))); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Suarez- Quilty, 912 N.W.2d 150 , 159–60 (Iowa 2018) (revoking the license of an attorney who converted $630 without a colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Adams, 809 N.W.2d 543, 546 (Iowa 2012); Iowa Supreme C

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742-43 (Iowa 2013) (revoking the license of an attorney who was convicted of a felony and converted client funds to which he had no colorable future claim); Adams, 809 N.W.2d at 546 (revoking the license of an attorney who took clients funds to which he had no colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Earley, 774 N.W.2d 301, 309 (Iowa 2009) (“Unless the attorney ‘had a colorable future claim to the funds or did not take the funds for [the lawyer’s] own use,’ revocation will be ordered.” (quoting Iow

2019See Iowa Supreme Ct. Att'y Disciplinary Bd. v. Guthrie , 901 N.W.2d 493 , 500 (Iowa 2017) (revoking attorney's license for converting client's funds without a colorable future claim); Iowa Supreme Ct. Att'y Disciplinary Bd. v. Green , 888 N.W.2d 398 , 405 (Iowa 2016) (concluding revocation of attorney's license to practice was the proper sanction for his misappropriation and theft of client funds); Iowa Supreme Ct. Att'y Disciplinary Bd. v. Fields , 790 N.W.2d 791 , 797, 799-801 (Iowa 2010) (finding attorney's misconduct resulting in two counts of second-degree fraudulent practice warranted ei

2014See Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742-43 (Iowa 2013) (revoking the license of an attorney who was convicted of a felony and converted client funds to which he had no colorable future claim); Adams, 809 N.W.2d at 546 (revoking the license of an attorney who took clients funds to which he had no colorable future claim); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Earley, 774 N.W.2d 301, 309 (Iowa 2009) (“Unless the attorney ‘had a colorable future claim to the funds or did not take the funds for [the lawyer’s] own use,’ revocation will be ordered.” (quoting Iow

2017See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 737, 742 (Iowa 2013) (quoting numerous cases wherein we held revocation was the appropriate sanction when attorneys converted client funds); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almost axiomatic that we will revoke the license of an attorney who converts a client’s funds to his or her own use.”); Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Williams, 675 N.W.2d 530, 533 (Iowa 2004) (revoking attorney’s license for fictitious billing); Iowa Supreme Ct. Bd. of Prof’

2017See, e.g., Iowa Supreme Ct. Att’y Disciplinary Bd. v. Stowe, 830 N.W.2d 787 , 742 (Iowa 2013) (quoting numerous cases wherein we held revocation was the appropriate sanction when attorneys converted client funds); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Nelsen, 807 N.W.2d 259, 266 (Iowa 2011) (“It is almost axiomatic that we will revoke the license of an attorney who converts a client’s funds to his or her own use.”); Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Williams, 675 N.W.2d 530, 533 (Iowa 2004) (revoking attorney’s license for fictitious billing); Iowa Supreme Ct. Bd. of Prof