The Iowa State Bar Association issued Ethics Opinion 24-01 in May 2024, providing formal guidance on attorney use of generative AI. Iowa's opinion is notable for its direct stance on billing: time saved through AI should be reflected in fees, and attorneys cannot charge human rates for AI-generated work.
Iowa's opinion addresses the three core concerns — billing, confidentiality, and disclosure — with enough specificity to give practitioners actionable direction. For Midwest firms, Iowa's guidance joins Illinois's ISBA Advisory Opinion 24-01 as a key regional reference point for AI ethics compliance.
What the Bar Says
Ethics Opinion 24-01 (May 2024) takes a clear position across multiple areas. On competence, the opinion requires attorneys to understand the AI tools they use, including limitations like hallucination and bias. Attorneys must verify all AI-generated output before submitting it as work product.
The opinion holds that AI is a tool, not a substitute for professional judgment. Attorneys bear full responsibility for AI-assisted work product, and the duty of supervision extends to managing AI workflows. The opinion treats AI output as a starting point requiring attorney review — not a finished product.
Billing Implications
Iowa's opinion takes one of the strongest positions on AI billing among state bars. The key holding: time saved through AI should be reflected in billing, and attorneys cannot charge human rates for AI work.
This means if AI helps draft a motion in 30 minutes that would have taken 4 hours manually, billing 4 hours is not permissible. Attorneys can bill for time spent reviewing, editing, and verifying AI output. AI tool costs may be passed to clients as an expense with transparency. This aligns with Colorado's Formal Ethics Opinion 145 and represents the emerging national standard.
Confidentiality Rules
Ethics Opinion 24-01 states that AI prompts containing client information must be treated as confidential communications. This is a significant holding — it means the same protections that apply to emails, letters, and phone calls with clients apply to AI inputs.
Practically, this prohibits using consumer AI tools that retain or train on user inputs for any work involving client data. Iowa attorneys must evaluate AI vendors' data handling practices, use tools with adequate security protections, and potentially obtain client consent before inputting confidential information into AI platforms.
What's Still Unclear
Iowa's opinion recommends disclosure to clients when AI significantly contributed to work product but does not mandate it. The threshold for "significant contribution" is undefined — does AI-assisted legal research count? What about document review or contract drafting?
The opinion also does not address court disclosure requirements, leaving that to individual judges and local rules. Other gaps include: no specific vendor vetting framework, no guidance on using AI for marketing or client communications, and no safe harbor for firms that follow the opinion. The opinion is advisory and the Iowa Supreme Court has not adopted binding AI rules.
The Bottom Line: Iowa's Ethics Opinion 24-01 (May 2024) is one of the strongest on billing — AI efficiency must benefit clients, and human rates cannot apply to AI work.
AI-Assisted Research. This piece was researched and written with AI assistance, reviewed and edited by Manu Ayala. For deeper takes and the perspective behind the research, follow me on LinkedIn or email me directly.