---
title: "Iowa lawyer reprimanded for AI-drafted brief with fake citations"
slug: "iowa-lawyer-reprimanded-for-ai-drafted-brief-with-fake-citations"
published: ""
beat: "Policy"
tags: ["Policy"]
creator: "Agentry Newsroom"
editor: "Susanne Sperling, Editor — Human in the Loop"
tools: ["Claude (Anthropic)", "Perplexity Sonar"]
creativeWorkStatus: "verified"
dateReviewed: "2026-06-27"
aiActArticle50: "compliant"
humanView: "https://agentry.news/iowa-lawyer-reprimanded-for-ai-drafted-brief-with-fake-citations"
agentView: "https://agentry.news/agent/iowa-lawyer-reprimanded-for-ai-drafted-brief-with-fake-citations"
---# Iowa lawyer reprimanded for AI-drafted brief with fake citations

> James Kay Larsen, a central Iowa attorney, received a public reprimand from the Iowa Supreme Court on April 9, 2026, after filing an appeal brief in a parental rights termination case that contained t

*Drafted by an AI agent. Verified by Susanne Sperling, Editor — Human in the Loop. [AI policy](/ai-policy).*

## Disciplinary Order Highlights AI Verification Failures

James Kay Larsen, an attorney in central Iowa, was publicly reprimanded by the Iowa Supreme Court for submitting an appeal brief in a parental rights termination case that relied on AI-generated citations without independent verification. The Supreme Court of Iowa issued [Order No. 26-0525](https://alabnews.com/attorney-james-kay-larsen-publicly-reprimanded-by-iowa-supreme-court-for-using-ai-without-verifying-legal-citations/) on April 9, 2026, citing violations of Iowa Rules of Professional Conduct 32:1.1 (competence) and 32:8.4(d) (conduct prejudicial to the administration of justice).

The brief contained two entirely fabricated case citations and misstated the holdings or language of real cases, according to findings posted on [LinkedIn by legal ethics commentator Tyler Coe](https://www.linkedin.com/posts/tylercoe_legalethics-aiandlaw-legaltech-activity-7465898162734686209-z5Jt). Larsen did not independently verify the citations before filing, a critical failure of professional responsibility that the court emphasized was indefensible regardless of AI use.

## Court Establishes 100% Attorney Accountability

The Iowa Supreme Court's disciplinary board was explicit in its holding: **"lawyers may use AI tools, but they remain 100% responsible for every citation and assertion they put before a court."** The order further stated that **"competence now includes understanding the benefits and the risks of the technology you use"** and that **"the signing professional bears 100% accountability."**

Crucially, the board rejected any defense rooted in inadequate AI verification. [Alab News](https://alabnews.com/attorney-james-kay-larsen-publicly-reprimanded-by-iowa-supreme-court-for-using-ai-without-verifying-legal-citations/) reported that **"a lawyer cannot use AI as a defense for inadequate verification,"** underscoring that delegation to an autonomous tool does not absolve professional duty.

## Penalty and Broader Implications

The disciplinary action imposed only a public reprimand—no fines, jail time, or dollar penalties. The reprimand was published as [Order No. 26-0525](https://www.facebook.com/KYOUTV/posts/iowa-attorney-reprimanded-for-ai-fabricated-information-in-court-filing/1593265232805573/) and circulated through legal ethics channels on social platforms including [Instagram](https://www.instagram.com/p/DY5ldMZjD7L/) and [Facebook](https://www.facebook.com/ktvotv/posts/iowa-capital-dispatch-an-iowa-attorney-has-been-disciplined-for-having-incorpora/1471551974986843/).

This case reflects a critical tension in modern legal practice: while AI tools are increasingly integrated into law firm workflows, courts and disciplinary boards are crystallizing the non-delegable duty of verification. The Iowa Supreme Court's framing—that competence itself now encompasses understanding AI risks—signals that courts nationwide will hold attorneys accountable for tool-induced hallucinations with the same rigor as human error. Larsen's reprimand serves as a high-profile warning that autonomous drafting, without human verification, constitutes a breach of professional conduct regardless of the technology's capabilities or the attorney's intent.