IN THE SUPREME COURT OF IOWA

No. 12–0228

Filed May 18, 2012

IOWA SUPREME COURT ATTORNEY

DISCIPLINARY BOARD,

Complainant,

vs.

KAREN A. TAYLOR,

Respondent.

On review of the report of the Grievance Commission of the 

Supreme Court of Iowa.

Grievance commission reports respondent committed ethical 

misconduct and recommends a public reprimand. ATTORNEY 

REPRIMANDED.

Charles L. Harrington and N. Tré Critelli, Des Moines, for 

complainant.

Karen A. Taylor, Des Moines, pro se.
2

APPEL, Justice.

This matter comes before us on the report of a division of the 

Grievance Commission of the Supreme Court of Iowa (commission). See

Iowa Ct. R. 35.10. The Iowa Supreme Court Attorney Disciplinary Board 

(Board) alleges the respondent, attorney Karen Taylor, engaged in 

multiple instances of misconduct in violation of several rules of 

professional conduct. The commission recommends a public reprimand. 

Upon our de novo review, we agree with the recommendation of the 

commission.

I. Procedural and Factual Background.

A. Introduction. In September 2011, the Board filed a complaint 

against Taylor. The Board alleges that Taylor violated several rules of 

professional conduct in her representation of Sharilyn Norin and Derrick 

Coleman in appeals of family law matters.1

In Count I, the Board alleges Taylor represented Norin in a child in 

need of assistance (CINA) proceeding. In that proceeding, Norin sought 

to challenge the placement of Norin’s nephew outside the family. The 

Board alleges that Taylor failed to file a timely appeal to an adverse 

ruling, causing dismissal of the appeal. The Board further asserts that 

Taylor failed to advise her client of the dismissal in a timely fashion and 

misled the client regarding the reason for the dismissal. The Board 

alleges that Taylor’s conduct violated rule 32:1.3 (neglect), rule 

32:1.4(a)(3) (failing to keep a client reasonably informed about the status 

of a matter), rule 32:1.4(a)(4) (failing to promptly comply with reasonable

requests for information), rule 32:8.4(c) (engaging in conduct involving 

misrepresentation), and rule 32:8.4(d) (engaging in conduct prejudicial to 

the administration of justice).

 1The Board voluntarily dismissed a third count against Taylor involving another 

client.
3

In Count II, the Board alleges that Taylor represented Coleman in a 

modification proceeding where Coleman sought to alter a child custody 

arrangement. The Board alleges that Taylor failed to properly prosecute 

the appeal after an adverse ruling, causing dismissal of the appeal. The 

Board further asserts that Taylor failed to inform the client of the true 

basis of the dismissal. Based on these allegations, the Board asserts 

that Taylor violated rule 32:1.3, rule 32:8.4(c), and rule 32:8.4(d).

The commission held a brief hearing. The Board offered into 

evidence exhibits and called Taylor to testify. The facts were largely 

undisputed. Following the hearing, the commission concluded that 

Taylor had violated rules of professional conduct during her 

representation of Norin and Coleman and recommended that Taylor 

receive a public reprimand.

B. Facts Established at the Hearing. 

1. Norin matter. Norin retained Taylor in August 2008 for the 

purpose of filing a motion to intervene in a CINA matter. Norin sought to 

contest the placement of her nephew with a nonfamily member. The 

district court denied Norin’s request for a change of placement on 

November 10. Because the matter related to CINA issues, Taylor had 

fifteen days after the entry of the ruling to file a notice of appeal. See 

Iowa R. App. P. 6.101.

Taylor filed a notice of appeal on December 10, thirty days after the 

entry of the ruling. Taylor stated the belated filing was due to her 

mistaken belief that she had thirty days to file the notice of appeal. 

Taylor stated that she was aware that the fifteen-day deadline applied to 

appeals involving the termination of parental rights. Taylor explained, 

however, that she did not realize matters involving child placement were 
4

also subject to the fifteen-day deadline, instead of the thirty-day 

deadline.

On December 24, the guardian ad litem of Norin’s nephew filed a 

motion to dismiss based upon Taylor’s failure to file a timely notice of 

appeal. Taylor did not resist the motion, and on January 29, 2009, this 

court dismissed the appeal.

The Board further asserts that Taylor engaged in neglect by not 

seeking an extension of time to file her brief under Iowa Rule of Appellate

Procedure 6.101(5), which allows a motion for an extension of time to be 

filed within sixty days of the original deadline when the clerk of the 

district court has failed to notify a prospective appellant of the filing of 

the order or judgment. According to the Board’s calculation, Taylor 

could have filed such a motion by January 24, 2009. In her answer to 

the Board’s charges, Taylor denied that she was aware that such an 

extension could be obtained. At the hearing, Taylor testified she “could 

have still filed a Notice of Appeal on time” because she received the order 

on November 25, within fifteen days of the filing of the order. Taylor 

stated she did not file the notice of appeal on the 25th because she 

believed she had until December 10 to do so. Thus, according to Taylor, 

“the delay for getting a Notice of Appeal filed was irrespective of whether 

or not I got the order on time, but because of my mistake.”

Taylor did not immediately inform Norin of the dismissal. On 

February 10, 2009, Norin sent an e-mail to Taylor requesting a copy of 

the appellate brief. On March 19, Norin sent another e-mail expressing 

her dissatisfaction with Taylor’s efforts to communicate the status of the 

matter. Taylor responded to the March 19 e-mail on the same day. 

Taylor’s reply, however, did not tell Norin of the dismissal or of Taylor’s 

error. Instead, Taylor said she would send to Norin the appellate brief, 
5

as requested. Norin responded the next day and stated she received the 

appellate brief, but wished to know when the brief was filed.

Taylor testified that she first informed Norin of the dismissal in a 

letter dated March 23. The letter was offered into evidence at the 

hearing. The March 23 letter told Norin the appeal had been dismissed 

and that Taylor incorrectly calculated the time for filing the appeal. 

Taylor acknowledged the “error,” though she stated that “by the time that 

we received a copy of the Order we were already outside of the time frame 

for the filing of the appeal.”

Norin sent Taylor another e-mail on March 26, which suggested 

Norin had not received Taylor’s March 23 letter. Norin’s e-mail requested 

the date Taylor filed the brief and information regarding whether the 

other side had submitted its response to Taylor’s brief. Norin again emailed Taylor on June 9, stating, “We have been trying to patiently wait 

for news regarding our appeal on behalf of our nephew . . . . The appeal 

was filed around Thanksgiving. Has a decision been made? Has any 

information come to you?” On June 11, Joan Ryan, a family member of 

Norin, sent Taylor another e-mail. The e-mail expressed Ryan’s 

disappointment in Taylor’s “lack of professionalism and communication.” 

Ryan further noted her family’s frustration over Taylor’s consistent 

failure to respond to their phone calls and e-mails. Ryan requested 

Taylor provide information relating to the status of the appeal. Taylor did 

not respond to the March 26, June 9, or June 11 e-mails.

Taylor testified she did not at first inform Norin of the dismissal 

because she “wasn’t quite sure how to handle” the situation. Taylor 

acknowledged her failure to inform Norin of the dismissal “compounded 

the problem.” When asked whether her failure to disclose was 

intentional, Taylor responded:
6

The Motion to Dismiss came after I had already initially 

worked on the brief and stuff, so initially I . . . wasn’t 

completely forthright . . . about the dismissal, and I believe 

there was probably a two-month period of time after I knew 

about it where we kind of led her to believe that it hadn’t—I 

hadn’t been forthright about the dismissal, and . . . I kind of 

led her to believe that it was still pending. 

In hindsight, Taylor realizes she should have immediately informed 

Norin of her error and that it resulted in dismissal of the appeal. Taylor 

reports she has since implemented measures to ensure her clients are 

better informed and deadlines are met. 

2. Coleman matter. In June 2008, Taylor began representation of 

Coleman in a matter involving a modification of a dissolution decree. 

The district court denied Coleman’s request to modify the decree on 

September 29, 2009. Because the matter involved child custody issues, 

the expedited deadlines of rule 6.902(1)(a) applied.

Although Taylor filed a timely notice of appeal, the combined 

certificate did not state whether the expedited deadline applied, as 

required by rule 6.804(4) of the rules of appellate procedure. Taylor 

subsequently filed two applications to extend the filing date of the proof 

brief and designation of appendix. Neither application stated whether 

the expedited deadlines applied in violation of rule 6.1003(2).

The appellee in the matter filed a motion to dismiss, which noted 

the appeal involved child custody issues. The motion to dismiss was not 

resisted. The court order granting the motion to dismiss noted that it 

was not resisted and further stated that “[t]he motion to dismiss 

indicates that this appeal involves child custody issues, though this was 

not noted by the appellant in the combined certificate or in his two 

extension requests, as is required by the rules.”

Taylor stated she did not indicate in her court filings that the 

expedited deadlines controlled the Coleman appeal because she believed 
7

they were inapplicable. Taylor explained that she thought the expedited 

deadlines did not apply because the Coleman appeal involved child 

visitation issues, not matters involving child custody. Thus, based on 

her erroneous interpretation of the rules of appellate procedure, Taylor 

requested extensions to extend the filing dates. Taylor further testified 

she had been experiencing problems in her personal life, which 

ultimately culminated in a divorce.

Within ten days of the dismissal, Taylor sent a letter to Coleman 

advising of the dismissal. The letter stated that the dismissal was due to 

Taylor’s “fail[ure] to file the original proof brief as required as the 

docketing date missed my calendar.”

II. Standard of Review. 

We review the findings of the commission de novo. Iowa Supreme 

Ct. Att’y Disciplinary Bd. v. Johnson, 792 N.W.2d 674, 677 (Iowa 2010). 

The Board must prove misconduct by a “convincing preponderance of the 

evidence.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Earley, 774 N.W.2d 

301, 304 (Iowa 2009). This burden is less demanding than proof beyond 

a reasonable doubt, but requires a greater showing than the 

preponderance of the evidence standard. Iowa Supreme Ct. Bd. of Prof’l 

Ethics & Conduct v. Lett, 674 N.W.2d 139, 142 (Iowa 2004). Once 

misconduct is proven, we may impose a “lesser or greater sanction than 

the discipline recommended by the grievance commission.” Earley, 774 

N.W.2d at 304 (citations and internal quotation marks omitted).

III. Ethical Violations.

A. Neglect. Iowa Rule of Professional Conduct 32:1.3 states, “A 

lawyer shall act with reasonable diligence and promptness in 

representing a client.” Iowa R. Prof’l Conduct 32:1.3. Despite the 

linguistic differences of its predecessor, DR 6–101(A)(3), we have cited 
8

neglect cases under DR 6–101(A)(3) as precedent in interpreting rule 

32:1.3. Iowa Supreme Ct. Att’y Disciplinary Bd. v. Van Ginkel, 809 

N.W.2d 96, 102 (Iowa 2012); Iowa Supreme Ct. Att’y Disciplinary Bd. v. 

Dolezal, 796 N.W.2d 910, 915 (Iowa 2011). In this case, neither party 

has argued that rule 32:1.3 should be interpreted or applied differently 

than DR 6–101(A)(3).

Generally, a violation of rule 32:1.3 cannot be found if “the acts or 

omissions complained of were inadvertent or the result of an error of 

judgment made in good faith.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. 

Joy, 728 N.W.2d 806, 812 (Iowa 2007). An attorney does not typically 

commit neglect by missing a single deadline. Van Ginkel, 809 N.W.2d at

102. Instead, neglect involves a consistent failure to perform obligations 

the lawyer has assumed or a “conscious disregard for the responsibilities 

a lawyer owes to a client,” and may arise when an attorney repeatedly 

fails to meet deadlines. Iowa Supreme Ct. Att’y Disciplinary Bd. v.

Lickiss, 786 N.W.2d 860, 867 (Iowa 2010) (citation and internal quotation 

marks omitted); Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. 

Grotewold, 642 N.W.2d 288, 293 (Iowa 2002). Further, ordinary 

negligence does not constitute neglect. Iowa Supreme Ct. Att’y 

Disciplinary Bd. v. Gottschalk, 729 N.W.2d 812, 817 (Iowa 2007); Iowa 

Supreme Ct. Bd. of Prof’l Ethics & Conduct v. Moorman, 683 N.W.2d 549, 

551–52 (Iowa 2004).

We conclude the Board failed to establish by a convincing

preponderance of the evidence that Taylor violated rule 32:1.3 in both 

the Norin and Coleman matters. This is not a case in which the 

attorney’s repeated failure to comply with appellate deadlines resulted in 

administrative dismissal. See Dolezal, 796 N.W.2d at 915; Iowa Supreme 

Ct. Bd. of Prof’l Ethics & Conduct v. Daggett, 653 N.W.2d 377, 380 (Iowa 
9

2002). Nor is this a case in which the attorney used the clerk’s office as 

a private tickler system. See Iowa Supreme Ct. Att’y Disciplinary Bd. v. 

Curtis, 749 N.W.2d 694, 699 (Iowa 2008). While Taylor’s actions in each 

matter resulted in the dismissal of each appeal, the record indicates 

Taylor’s actions were the result of negligence rather than neglect. See 

Iowa Supreme Ct. Att’y Disciplinary Bd. v. Wintroub, 745 N.W.2d 469, 475 

(Iowa 2008) (holding attorney’s failure to timely designate expert, 

resulting in dismissal of action, did not constitute neglect).

B. Communication. Rule 32:1.4(a)(3) states a lawyer shall “keep 

the client reasonably informed about the status of the matter.” Iowa R. 

Prof’l Conduct 32:1.4(a)(3). The comments to rule 32:1.4 state that 

paragraph (a)(3) requires a lawyer to keep the client reasonably informed 

about “significant developments affecting . . . the substance of the 

representation.” Id. cmt. 3. The Board alleges Taylor violated this rule 

by failing to inform Norin of the dismissal. We agree. The Norin appeal 

was dismissed on January 29, 2009. Taylor, however, failed to notify 

Norin of the dismissal for nearly two months. We are therefore satisfied 

the Board established Taylor failed to keep her client reasonably 

informed about the status of the Norin matter.

The Board has also proven Taylor violated rule 32:1.4(a)(4). Rule 

32:1.4(a)(4) provides that a lawyer shall “promptly comply with 

reasonable requests for information.” Id. r. 32:1.4(a)(4). Following 

dismissal of the Norin appeal, Norin wrote Taylor several e-mails 

inquiring generally into the status of the matter. Norin also requested a 

copy of the appellate brief on multiple occasions. Taylor responded to 

these inquiries by sending the March 23 letter informing her clients of 

the dismissal. Yet three additional letters were sent to Taylor following 

March 23. The letters again requested information regarding the status 
10

of the matter, the date on which Taylor filed the appeal, and a copy of the 

appellate brief. Taylor did not respond to any of these requests. 

Therefore, the Board has proven by a convincing preponderance of the 

evidence Taylor failed to promptly comply with reasonable requests for 

information.

C. Misrepresentation. Iowa Rule of Professional Conduct 

32:8.4(c) states it is professional misconduct for a lawyer to “engage in 

conduct involving dishonesty, fraud, deceit, or misrepresentation.” Id. r.

32:8.4(c). Misrepresentation generally requires proof of intent to deceive. 

Iowa Supreme Ct. Att’y Disciplinary Bd. v. Thomas, 794 N.W.2d 290, 294 

(Iowa 2011); see also Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct v. 

Smith, 569 N.W.2d 499, 501 (Iowa 1997) (interpreting DR 1–102(A)(4) 

and stating “[t]he key question is whether the effect of the lawyer’s 

conduct is to mislead rather than to inform.” (citation and internal 

quotation marks omitted)). The Board must prove the attorney acted 

with some level of scienter greater than negligence. Iowa Supreme Ct. 

Att’y Disciplinary Bd. v. Netti, 797 N.W.2d 591, 605 (Iowa 2011).

We conclude Taylor violated rule 32:8.4(c) in the Norin matter but 

not the Coleman matter. Norin sent Taylor an e-mail on February 10

and March 19 requesting information relating to the appeal and 

expressing dissatisfaction with Taylor’s efforts to keep her informed 

about the status of the matter. Taylor’s first response on March 19 did 

not inform Norin of the dismissal. Instead, Taylor explained she would 

send a copy of the appellate brief as requested even though she knew the 

appeal had been dismissed. Taylor testified that she had not been 

“forthright about the dismissal,” and that there was a period of time in 

which she “kind of led [Norin] to believe that [the appeal] was still 

pending.”
11

Taylor then sent a letter dated March 23, 2009, clearly explaining 

the reason for the dismissal. We credit Taylor’s testimony that the letter 

was sent. Nonetheless, the communication of March 19 amounts to a 

misrepresentation, and Taylor does not argue to the contrary.

Under these circumstances, we are satisfied Taylor’s 

communication and conduct following the dismissal of the Norin appeal 

constitutes conduct involving misrepresentation in violation of rule 

32:8.4(c). See Thomas, 794 N.W.2d at 294 (concluding attorney deceived 

client in a letter stating he would “get to the bottom of the matter” when 

the attorney knew the case had been dismissed).

In the Coleman matter, however, on this record we are unable to 

determine whether Taylor acted with a level of scienter greater than 

negligence. The Board alleges Taylor’s letter to Coleman stating the 

appeal had been dismissed due to her failure to timely file a proof brief 

amounts to a misrepresentation because the true reason for the 

dismissal was her failure to include a notice of the expedited deadlines in 

the court filings. Taylor reasonably testified that she believed the appeal 

had been dismissed due to her dilatory conduct and not her failure to 

include the notice in the appeal documents. Further, Taylor took 

responsibility for the dismissal in the letter to Coleman, stating the court 

granted the dismissal due to her “failure” to file the necessary brief. The 

letter also indicates Taylor attached the order granting dismissal. On 

these facts, the Board has not established by a convincing

preponderance of the evidence Taylor had a level of scienter greater than 

negligence in her correspondence with Coleman. We therefore hold the 

Board failed to prove Taylor violated rule 32:8.4(c) in the Coleman 

matter.
12

D. Conduct Prejudicial to the Administration of Justice. Rule 

32:8.4(d) prohibits a lawyer from engaging in “conduct that is prejudicial 

to the administration of justice.” Iowa R. Prof’l Conduct 32:8.4(d). Rule 

32:8.4(d) is nearly identical to its predecessor, DR 1–102(A)(5). See Iowa 

Code of Prof’l Responsibility DR 1–102(A)(5); Van Ginkel, 809 N.W.2d at

102. Conduct is prejudicial to the administration of justice when it 

impedes “the efficient and proper operation of the courts or of ancillary 

systems upon which the courts rely by violating well-understood norms 

and conventions of the practice of law.” Van Ginkel, 809 N.W.2d at 103

(citation and internal quotation marks omitted). Examples of conduct 

prejudicial to the administration of justice include “paying an adverse 

expert witness for information regarding an opponent’s case preparation, 

demanding a release in a civil action as a condition of dismissing 

criminal charges, and knowingly making false or reckless charges 

against a judicial officer.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. 

Templeton, 784 N.W.2d 761, 768 (Iowa 2010). The Board alleges Taylor 

violated this rule in both the Norin and Coleman matters by filing an 

appeal that was ultimately dismissed.

This court has held that a neglectful failure to prosecute an appeal, 

which results in an administrative dismissal, constitutes conduct 

prejudicial to the administration of justice. See, e.g., Dolezal, 796 

N.W.2d at 914; Iowa Supreme Ct. Att’y Disciplinary Bd. v. Knopf, 793 

N.W.2d 525, 530 (Iowa 2011); Iowa Supreme Ct. Att’y Disciplinary Bd. v. 

Wengert, 790 N.W.2d 94, 101 (Iowa 2010); Daggett, 653 N.W.2d at 380. 

We have also held an attorney can be in violation of rule 32:8.4(d) when 

an appeal is administratively dismissed even though the attorney did not 

commit neglect in the handling of the appeal. See Iowa Supreme Ct. Att’y 

Disciplinary Bd. v. Wright, 758 N.W.2d 227, 230–31 (Iowa 2008). Yet, in 
13

each of these cases, the administrative dismissal came after the 

attorneys abandoned prosecution of the appeal and failed to dismiss the 

appeal before administrative dismissal. Also, in those cases the clerk 

filed an order accomplishing the dismissal or filed a default notice to 

dismiss. The case before us, however, is distinguishable. 

In this case, Taylor did not allow the appeals to be administratively 

dismissed following the clerk’s default notice. See Knopf, 793 N.W.2d at 

530 (stating ignoring deadlines, which results in default notices from 

clerk, constitutes conduct prejudicial to the administration of justice). 

The record does not indicate whether the clerk filed any default notice 

related to either appeal. See Wengert, 790 N.W.2d at 101 (holding 

attorney’s failure to timely file proof brief, followed by default notice from 

clerk, constituted neglect and conduct prejudicial to the administration 

of justice when attorney ignored default notice); Iowa Supreme Ct. Att’y 

Disciplinary Bd. v. Tompkins, 733 N.W.2d 661, 669 (Iowa 2007) (holding 

disregard of notice of default constitutes neglect and conduct prejudicial 

to the administration of justice). Instead, the record shows the 

dismissals resulted from motions to dismiss filed by the opponents of 

Norin and Coleman in light of Taylor’s negligent failure to appreciate the 

applicability of the expedited deadlines. Under these circumstances, the 

Board has failed to establish by a convincing preponderance of the

evidence Taylor’s conduct was prejudicial to the administration of justice 

under rule 32:8.4(d).

IV. Sanction.

The appropriate sanction is determined by the particular 

circumstances of each case. Iowa Supreme Ct. Att’y Disciplinary Bd. v. 

Ackerman, 786 N.W.2d 491, 497 (Iowa 2010). We do, however, seek a 

degree of consistency in our disciplinary cases with respect to sanctions. 
14

Iowa Supreme Ct. Att’y Disciplinary Bd. v. Clauss, 711 N.W.2d 1, 4 (Iowa 

2006). While we give respectful consideration to recommendations of the 

commission, “the matter of sanction is solely within the authority of this 

court.” Iowa Supreme Ct. Att’y Disciplinary Bd. v. Morrison, 727 N.W.2d 

115, 119 (Iowa 2007) (citation and internal quotation marks omitted). In 

determining the appropriate sanction, the court weighs the aggravating 

and mitigating circumstances and considers “ ‘the nature of the 

violations, the need for deterrence, protection of the public, maintenance 

of the reputation of the bar as a whole, and the [attorney’s] fitness to 

continue in the practice of law.’ ” Iowa Supreme Ct. Att’y Disciplinary Bd. 

v. Liles, 808 N.W.2d 203, 206 (Iowa 2012) (quoting Comm. on Prof’l Ethics 

& Conduct v. Blomker, 379 N.W.2d 19, 21 (Iowa 1985)).

We first consider the mitigating factors. We note Taylor has taken 

responsibility for her actions. We have held that such forthrightness is a 

mitigating factor to be considered in calibrating the appropriate sanction. 

See Thomas, 794 N.W.2d at 295 (noting attorney’s admission of 

responsibility is a mitigating factor).

Taylor has also limited her appellate practice following the Norin 

and Coleman matters. For what remains of her appellate practice, Taylor 

has implemented new policies and procedures in her office to ensure 

deadlines are met. See id. (noting implementation of new office 

procedures to ensure missed deadlines do not recur is a mitigating 

factor).

We also note that Taylor maintains a law practice that allows 

persons with modest means to obtain representation in family law 

matters. She charges a modest hourly rate which provides her clients

with access to the courts for an affordable fee. Providing legal 

representation to an underserved part of the community is a significant 
15

mitigating factor. See Comm. on Prof’l Ethics & Conduct v. Borchart, 392 

N.W.2d 491, 492 (Iowa 1986) (agreeing with commission’s observation 

that attorney’s service on behalf of the disadvantaged was a mitigating 

factor).

Finally, Taylor cites stress related to personal issues involving the 

dissolution of her marriage and subsequent child custody dispute. 

Although such personal issues do not excuse ethical violations, they may 

be a mitigating factor in determining sanctions. See Van Ginkel, 809 

N.W.2d at 110.

Turning to the aggravating factors, we note Taylor received a public 

reprimand in 2005 for neglect of a client matter and failure to provide 

upon request an accounting of a client’s retainer. The details of this 

matter are not provided in the record of this proceeding. Taylor also 

received a temporary suspension in 2010, but the temporary suspension 

was lifted a day later and appears to have been the result of a mail or 

administrative error, was cured within hours of the suspension, and is of 

little consequence for purposes of this proceeding.

The most troublesome feature in this case is the misrepresentation 

to Norin regarding the dismissal. As we stated in Hohenadel, “[t]he court 

system and the public we serve are damaged when our officers play fast 

and loose with the truth.” Iowa Supreme Ct. Bd. of Prof’l Ethics & 

Conduct v. Hohenadel, 634 N.W.2d 652, 656 (Iowa 2001) (citation and 

internal quotation marks omitted). Yet the conduct in this case is less 

egregious than that found in other cases imposing a greater sanction. 

See Daggett, 653 N.W.2d at 381–82 (imposing sixty-day suspension for 

conduct involving neglect, misrepresentation, and failure to respond to 

the Board’s inquiries when client was harmed); Hohenadel, 634 N.W.2d 

at 657 (imposing four-month suspension for attorney with history of 
16

unethical conduct who engaged in conduct involving misrepresentation 

and neglect resulting in harm to the attorney’s clients); Comm. on Prof’l 

Ethics & Conduct v. Horn, 379 N.W.2d 6, 8–10 (Iowa 1985) (holding 

failure to cooperate with committee, neglect in one matter, and 

misrepresentations to decedent’s daughter warranted three-month 

suspension). Taylor’s conduct is closer, though not identical, to 

misrepresentation cases in which we imposed a public reprimand. See 

Iowa Supreme Ct. Att’y Disciplinary Bd. v. Cannon, 789 N.W.2d 756, 760

(Iowa 2010) (holding misrepresentation involving plagiarism warranted 

public reprimand); Iowa Supreme Ct. Att’y Disciplinary Bd. v. Newman, 

748 N.W.2d 786, 788–89 (Iowa 2008) (holding misrepresentation in form 

of forging judge’s signature warranted public reprimand in absence of 

prior disciplinary history).

We agree with the commission’s conclusion that, under all the 

facts and circumstances of this case, a public reprimand is the 

appropriate sanction. We further agree with the commission’s 

observation that future violations may well produce a different result.

V. Conclusion.

For the reasons expressed above, Karen Taylor is publically 

reprimanded for the ethical violations cited in this opinion.

ATTORNEY REPRIMANDED.