In the Interest of R.A.

In the Interest of R.A., Minor Child, No. 24-1629, Iowa Court of Appeals, opinion filed October 1, 2025 (2025 Iowa App. LEXIS 860), by Judge Buller, with oral argument before Chief Judge Tabor and Judges Greer and Buller. Copy of primary document: `files/sources/D-90-in-the-interest-of-ra.pdf`.

Counsel for the mother, attorney Cathleen J. Siebrecht of the Siebrecht Law Firm, filed a reply brief containing citations to cases and statutes that do not exist and inaccurate quotations from real authorities. After the court ordered her to explain or produce the authorities, she acknowledged that, due to login problems with her Westlaw subscription, she had relied on her prior research notes plus "secondary AI-driven research tools," and that the AI program was the source of the fabricated citations and inaccurate quotations, which she never verified.

Exercising its discretion under its inherent power and Iowa Rule of Civil Procedure 1.413, the court imposed three sanctions: the mother's reply brief was stricken; a $150 monetary penalty payable to the clerk of appellate courts within 60 days, which counsel may satisfy instead by attending two hours of legal ethics training specific to AI within 60 days and certifying attendance under oath; and the clerk was directed to transmit the opinion and counsel's written explanation to the Attorney Discipline Board when the opinion is filed.

Never file without access to a verified research database; if subscriptions lapse, request additional filing time to complete a line-by-line cite check. Verify every citation and quotation against official sources, especially when using secondary or AI-driven tools. Treat any brief assembled from prior notes and AI tools as unverified until each authority is confirmed genuine.