Iowa Supreme Court Attorney Disciplinary Board v. Clovis Bowles, 794 N.W.2d 1

Board filed a complaint against Bowles alleging violations of Iowa Rules 32:1.8(j), 32:1.14(a), 32:8.4(d), and 32:8.4(a).
Grievance Commission found multiple ethical violations and recommended a three-year suspension.
Bowles engaged in sexual acts with the client in his office and later at her home, and again in the courthouse library after the complaint was filed.
The client, previously treated for mental health issues, faced child custody problems and later married Bowles; Bowles aided in a false affidavit to defend the misconduct.
The court reviews de novo and imposes a sanction; Bowles is ultimately suspended for eighteen months with no reinstatement for at least that period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Bowles’s sexual relationship with the client a violation of 32:1.8(j)?	Board: yes, sexual relations with a client breached 32:1.8(j).	Bowles: argues no violation under the rule.	Yes; violated 32:1.8(j).
Did Bowles’ handling of a client with diminished capacity violate 32:1.14(a)?	Board: client’s diminished capacity justified protective actions.	Bowles: insufficient proof of substantially impaired decision-making.	No violation proven by a convincing preponderance.
Did Bowles’ conduct constitute conduct prejudicial to the administration of justice under 32:8.4(d)?	Board: misconduct interfered with court operations, including reliance on false affidavit.	Bowles: argues isolated acts within discretion of court proceedings.	Yes for violating 32:8.4(d) due to obstructive conduct before the commission.
Should Bowles be sanctioned, and if so, the appropriate sanction?	Board: suspension warranted to protect public and deter others.	Bowles: mitigation due to mental health issues; seeks lesser sanction.	Eighteen-month suspension with no reinstatement for at least 18 months.

Att’y Disciplinary Bd. v. Monroe, 784 N.W.2d 784 (Iowa 2010) (sexual misconduct with a client not per se violation; broader discipline considerations)
Att’y Disciplinary Bd. v. McGrath, 713 N.W.2d 682 (Iowa 2006) (sanctions for sexual misconduct by attorneys considered in determining discipline)
In re Marzen, 779 N.W.2d 757 (Iowa 2010) (aggravating factor: client recently discharged from mental health facility; impact on sanction)
Comm. on Prof’l Ethics & Conduct v. Templeton, 784 N.W.2d 761 (Iowa 2010) (limits on certain charges following Templeton decision)
Att’y Disciplinary Bd. v. Marks, 759 N.W.2d 328 (Iowa 2009) (sanction considerations in attorney discipline)
Att’y Disciplinary Bd. v. Kallsen, 670 N.W.2d 161 (Iowa 2003) (factors guiding sanction decisions in ethics cases)
Att’y Disciplinary Bd. v. Morrison, 727 N.W.2d 115 (Iowa 2007) (range of sanctions for sexual misconduct with clients)
Att’y Disciplinary Bd. v. Grotewold, 642 N.W.2d 288 (Iowa 2002) (mitigating effects of mental health on sanction)