A central Iowa attorney has been disciplined for having incorporated false case citations in a court brief authored with the help of artificial intelligence.
It’s at least the second time an Iowa attorney has faced allegations of using artificial intelligence, or AI, to author briefs that include false information, often referred to as “hallucinations” since the information is created by AI based on data patterns rather than on verified facts.
The most recent case involves the Iowa Attorney Disciplinary Board’s letter of public reprimand to attorney Cathleen Jane Siebrecht of Pleasant Hill.
According to the board’s letter informing Siebrecht of the reprimand, her brief in the 2025 appeal of a termination-of-parent-rights case was written with the help of artificial intelligence.
“The Iowa Court of Appeals discovered that two cases you cited were entirely hallucinated and at other points the brief incorrectly characterized the language or holding of the source cited,” the board told Siebrecht. “You did not independently verify the accuracy of those citations before filing the brief.”
The offense, the board decided, was deserving of a public reprimand. “Submitting hallucinated authorities, even unintentionally, interferes with the court’s work and erodes confidence in the legal profession,” the board stated in its letter to Siebrecht.
Hundreds of cases involve misuse of AI
The Court of Appeals’ October 2025 decision in the parental-rights case made note of the fact that “issues with artificial intelligence have reached most areas of American life, and our courtroom is no exception. In August of this year, this court stressed that self-represented litigants and attorneys alike have a duty to independently verify the authenticity and veracity of all sources and assertions when relying on artificial intelligence tools to prepare trial or appellate court filings.”
The court indicated it had reviewed a database of 355 different cases from around the world that have involved “hallucinated” AI-generated content.
The court imposed a financial penalty of $150 against Siebrecht and stated that in lieu of payment, she could instead attend two hours of instructional training on legal ethics involving artificial intelligence.
Siebrecht did not respond Thursday to calls and text messages from the Iowa Capital Dispatch seeking comment on the matter, but Court of Appeals records indicate she accepted full responsibility for not catching the false case citations in her brief and stated that in the future, she would conduct a rigorous, line by-line review of all her court filings.
According to the court, Siebrecht stated she was “humbled and haunted” by the error.
AI use cited in 2025 disciplinary case
Last year, Iowa’s Attorney Disciplinary Board alleged a former Iowa lawyer was attempting to win back his license by citing an “imaginary” case generated by artificial intelligence.
In December 2016, the Iowa Supreme Court suspended the law license of Des Moines attorney Royce David Turner, who was first licensed by the state in 2013. The court reinstated Turner’s license in May 2017.
In 2018, the Iowa Supreme Court Attorney Disciplinary Board filed a set of 13 disciplinary charges against Turner, and the court ultimately suspended Turner’s law license for one year. Since 2022, the disciplinary board has opposed Turner’s requests for reinstatement of the license, arguing he has yet to produce the required expert opinion from a mental health professional regarding his fitness to practice.
In July 2025, the board asked the Iowa Supreme Court to strike “multiple recent filings” by Turner that the board said contained “what appears to be at least one AI-generated citation to a case that does not exist or does not stand for the proposition asserted in the filings.”
The board alleged “the imaginary case” was cited by Turner in three separate filings related his efforts to have his license reinstated.
