PLEASANT HILL, Iowa (IOWA CAPITAL DISPATCH- A legal professional from central Iowa has faced disciplinary action after including incorrect case references in a court document that was assisted by artificial intelligence.
It is at least the second instance where an Iowa lawyer has been accused of utilizing artificial intelligence, or AI, to draft legal documents containing inaccurate details, commonly known as "hallucinations" because the data is generated by AI through patterns rather than actual, confirmed facts.
The latest incident pertains to a public reprimand issued by the Iowa Attorney Disciplinary Board to attorney Cathleen Jane Siebrecht from Pleasant Hill.
As stated in the board's letter notifying Siebrecht of the reprimand, her argument in the 2025 appeal regarding the termination of parental rights was prepared with the assistance of artificial intelligence.
The Iowa Court of Appeals found that two cases you referenced were completely made up, and at other times the brief incorrectly described the language or decision from the sources cited," the board stated to Siebrecht. "You did not personally check the accuracy of those references before submitting the brief.
The board concluded that the offense warranted a public warning. "Presenting fabricated authorities, even if unintentional, disrupts the court's operations and undermines trust in the legal field," the board mentioned in its letter to Siebrecht.
Numerous cases have been reported involving the improper use of artificial intelligence.
The Court of Appeals’ October 2025 decisionIn the parental rights case, it was acknowledged that "issues related to artificial intelligence have permeated nearly every aspect of American life, and our courtroom is no different. In August of this year, the court emphasized that both pro se litigants and attorneys must independently confirm the accuracy and truthfulness of all sources and claims when using artificial intelligence tools for preparing trial or appellate court documents."
The court mentioned that it had examined a database containing 355 various cases from different parts of the world that have dealt with "hallucinated" AI-created material.
The court issued a fine of $150 to Siebrecht and mentioned that instead of paying, she could participate in two hours of educational training about legal ethics related to artificial intelligence.
Siebrecht did not respond Thursday to calls and text messages from the Iowa Capital Dispatch seeking her comments on the issue, but records from the Court of Appeals show she took full responsibility for failing to identify the false case citations in her brief. She also mentioned that she will conduct a thorough, line-by-line review of all her future court filings.
As per the court, Siebrecht expressed that she felt "humbled and haunted" by the mistake.
AI referenced in 2025 disciplinary proceeding
Last year, the Iowa Attorney Disciplinary Board claimed that a former Iowa attorney was trying to regain his license by referencing an "imaginary" case created through artificial intelligence.
In December 2016, the Iowa Supreme Court placed a hold on the legal license ofAttorney Royce David Turner from Des Moines, who received their initial license from the state in 2013. The court restored Turner's license in May 2017.
In 2018, the Iowa Supreme Court Attorney Disciplinary Board brought 13 disciplinary charges against Turner, leading to a one-year suspension of his law license. From 2022 onward, the disciplinary board has consistently rejected Turner's applications to regain his license, stating that he has not provided the necessary expert evaluation from a mental health specialist confirming his ability to practice law.
In July 2025, the board requested the Iowa Supreme Court to remove "several recent submissions" from Turner, which the board claimed included "at least one citation generated by AI that refers to a case that either doesn't exist or doesn't support the claims made in the documents."
The board claimed that "the imaginary case" was referenced by Turner in three different documents concerning his attempts to regain his license.
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