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Iowa Supreme Court Attorney Disciplinary Board v. Ronald L. Ricklefs
2014 Iowa Sup. LEXIS 32
| Iowa | 2014
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Background

  • Ronald L. Ricklefs, Iowa attorney since 1978, faced a grievance from the Board based on trust-account mismanagement and misrepresentation.
  • An audit in 2012 revealed significant trust-account deficiencies, including commingling client and personal funds and poor recordkeeping.
  • A prior 2008 audit had flagged similar issues, which Ricklefs failed to rectify.
  • The Grievance Commission found most violations occurred and recommended a 30-day suspension.
  • The Iowa Supreme Court suspended Ricklefs indefinitely with no reinstatement for three months, due to ongoing trust-account violations and misrepresentations, after weighing aggravating and mitigating factors.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Ricklefs violated trust-account rules Board: violations established by defective records and commingling Ricklefs: efforts to correct; no client harm shown Yes, trust-account violations established
Whether Ricklefs committed dishonesty Board: false questionnaire and auditor statements showing deceit Ricklefs: acknowledged issues and attempted corrections Yes, dishonesty established
Appropriate sanction for misconduct Board: suspension warranted given pattern and aggravating factors Ricklefs: reform efforts and mitigating factors Indefinite suspension with no reinstatement for three months

Key Cases Cited

  • Kersenbrock v. Iowa Bd. of Professional Ethics & Conduct, 821 N.W.2d 415 (Iowa 2012) (mitigating factors; incomplete trust records in audit context)
  • Sunleaf v. Iowa Bd. of Prof'l Ethics & Conduct, 588 N.W.2d 126 (Iowa 1999) (trust account used to hide funds; reprimand inclination)
  • Boles v. Iowa Bd. of Prof'l Disciplinary, 808 N.W.2d 431 (Iowa 2012) (pattern of trust-account violations; suspended for 30 days)
  • Clarity v. Iowa Bd. of Prof'l Disciplinary, 838 N.W.2d 648 (Iowa 2013) (extensive misconduct; one-year suspension with no reinstatement)
Read the full case

Case Details

Case Name: Iowa Supreme Court Attorney Disciplinary Board v. Ronald L. Ricklefs
Court Name: Supreme Court of Iowa
Date Published: Mar 28, 2014
Citation: 2014 Iowa Sup. LEXIS 32
Docket Number: 13–1965
Court Abbreviation: Iowa