Iowa Supreme Court Attorney Disciplinary Board v. Curt N. Daniels, 838 N.W.2d 672

Curt N. Daniels is a 75-year-old attorney and veterinarian who practiced law in Chariton after obtaining his law degree in 1973.
Daniels owned a hog confinement operation and a corporation that faced a replevin action by John Holtz’s company over property Daniels removed after a tax sale.
A 2004 district court judgment against Daniels and his corporation arose from wrongful detention of property; he appealed this judgment.
During the appeal process, Daniels filed an action against Holtz’s attorney and law firm alleging fraud and other misconduct, and sought to amend the petition with multiple professional-conduct claims.
In 2008 the Iowa Supreme Court affirmed the 2004 judgment on condition of remittitur; on remand, Daniels sought a new trial based on newly discovered evidence and perjury allegations, leading to further district court rulings and appellate filings.
The Attorney Disciplinary Board charged Daniels with frivolous filings and a false statement to the court; the Grievance Commission found a rule 32:3.1 violation (frivolous filings) and no rule 32:3.3 violation, and recommended a public reprimand; the supreme court imposed a public reprimand for one count sustained.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the petition for relief contained a false statement to the court under rule 32:3.3	Board argues the petition omitted background facts making it a false statement.	Daniels contends omission was not an affirmative misrepresentation and not essential to pleading.	No violation of rule 32:3.3.
Whether the petition for relief was frivolous under rule 32:3.1	Board claims the petition sought relief not available and thus was frivolous.	Daniels contends relief under rule 1.1012 was legally permissible and not frivolous.	No violation; petition for relief did not constitute frivolous proceedings.
Whether Daniels violated rule 32:3.1 by amending his petition to assert claims based solely on professional-conduct rules	Amended claims against Holtz’s attorney were baseless civil claims relying only on professional-conduct rules.	Claims lack basis in law and were not meritorious.	Yes, violated rule 32:3.1.

Rhinehart v. Bd. of Prof’l Ethics & Conduct, 827 N.W.2d 169 (Iowa 2013) (candor rules apply to self-represented lawyers as well as advocates)
Ramey v. Comm. on Prof’l Ethics & Conduct, 512 N.W.2d 569 (Iowa 1994) (administration of justice requires honesty by officers of the court)
Hays v. Hays, 612 N.W.2d 817 (Iowa Ct. App. 2000) (indirectly addressing relief under 1.1012 when 6.101(5) relief is unavailable)
Gottschalk v. Iowa Supreme Ct. Bd. of Prof’l Ethics & Conduct, 729 N.W.2d 812 (Iowa 2007) (discipline for frivolous claims; respect for court integrity)
Ronwin v. Iowa Bd. of Prof’l Ethics & Conduct, 557 N.W.2d 515 (Iowa 1997) (suspension for filing frivolous matters)