Full Opinion

In the Iowa Supreme Court No. 26–1167 Submitted October 12, 2026—Filed November 13, 2026 Iowa Supreme Court Attorney Disciplinary Board, Complainant, vs. Sandra E. Suarez, Respondent. On review of the report of the Iowa Supreme Court Grievance Commission. The grievance commission recommends a thirty-day suspension for disciplinary violations. Attorney’s license suspended. Waterman, J., delivered the opinion of the court, in which all participating justices joined. Mansfield, J., took no part in the consideration or decision of the case. Tara van Brederode, Allison A. Schmidt, and Sarah C. Tupper, Des Moines, for complainant. Michael J. Streit, West Des Moines, for respondent. 2 Waterman, Justice. Sandra E. Suarez is presently a solo practitioner with a law office in Windsor Heights. She is one of only four Iowa attorneys to be reinstated by our court after we revoked their license to practice law. See Iowa Ct. R. 34.27 (allowing readmission five years after revocation under specified conditions). The misconduct that led to her revocation occurred while she was in the throes of alcoholism. She quit drinking in 2017, and we gave her a fresh start in 2023, six years after she attained sobriety. To her credit, she volunteers a considerable amount of time helping others who struggle with substance-use disorders. But now Suarez is the first and only Iowa lawyer to face new disciplinary charges following her reinstatement after revocation. A panel of the Iowa Supreme Court Grievance Commission concluded that if viewed in isolation, her new disciplinary violations “might simply warrant a public reprimand.” But the commission saw her prior disciplinary history as an aggravating factor and recommended that we impose a thirty-day suspension, which is the sanction urged by the Iowa Supreme Court Attorney Disciplinary Board (Board). On our de novo review, for the reasons explained below, we agree with the commission’s findings and recommendation and suspend her license to practice for thirty days. I. Background Facts and Proceedings. Suarez was admitted to the Iowa bar in 2000 and spent much of her early career in health-care law, government relations, and lobbying. In 2008, she began working as a multiclient lobbyist. As her lobbying career flourished, her social drinking morphed into problem drinking. She was convicted of operating a motor vehicle while intoxicated (OWI), first offense, in 2009. In 2011, she underwent a bitter divorce and child-custody battle. In 2012, she opened a solo practice handling immigration, family, and minor criminal matters. Her second 3 OWI conviction came in 2013. In 2015, she was twice charged with OWI, third offense, a class “D” felony; she pleaded guilty to both and was sentenced to five years in prison. Suarez was incarcerated at the Iowa Correctional Institution for Women in Mitchellville. In 2014, the Board charged her with multiple violations of the Iowa Rules of Professional Conduct, and it amended its complaint several times through 2017. The commission found various violations, including that she deposited $630 of client funds into her law firm’s operating account and misappropriated them for personal use without a colorable future claim to those funds. Iowa Sup. Ct. Att’y Disciplinary Bd. v. Suarez-Quilty, 912 N.W.2d 150, 155, 157, 159 (Iowa 2018). The Board and commission recommended revocation. Id. at 157. On our de novo review, we found that she converted the $630 of client funds, and “[b]ecause of [that] finding,” on May 18, 2018, we revoked her license to practice without considering “mitigating and aggravating factors that may be present here.” Id. at 160 (second quotation quoting Iowa Sup. Ct. Att’y Disciplinary Bd. v. Guthrie, 901 N.W.2d 493, 500 (Iowa 2017)). We noted that she could apply for reinstatement under our rules after a period of at least five years. Id. On October 16, 2018, Suarez was disbarred from practicing federal immigration law before the Board of Immigration Appeals (BIA), the immigration courts, and the Department of Homeland Security (DHS). That disbarment order provided that Suarez could petition for reinstatement to practice immigration law in those forums. Five years later, Suarez applied for reinstatement of her Iowa license. Her application and supporting materials documented her path to sobriety. She had the requisite letters of support from Iowa practitioners. The Board and other divisions of the Office of Professional Regulation stated that “Suarez had satisfied 4 all requirements for readmission under applicable Iowa Court Rules.” The Iowa Board of Law Examiners conducted its investigation and submitted its reports and recommendations to the court. After a public hearing and our review of the filings and her testimony, we found that “Suarez has demonstrated that she is of good moral character and worthy of readmission to the practice of law in Iowa.” We readmitted her by order filed August 16, 2023. With this fresh start, Suarez resumed practicing law in Iowa state courts. That October, Jorge Villeda retained Suarez to represent him on an immigration matter. Although she had begun the process to obtain a new Executive Office for Immigration Review filing number, she remained disbarred from practice before the BIA, DHS, and the immigration courts. She jumped the gun by filing a motion on Villeda’s behalf before she was reinstated to practice in the federal tribunals. Her motion for Villeda failed to disclose that she was not authorized to practice before the BIA. And her subsequent motion for reinstatement with the BIA did not disclose that she had already engaged in the practice of immigration law without authorization. After federal disciplinary counsel called that omission to her attention, she explained in an amendment to her motion that “[m]istakenly, it was [her] understanding that upon reinstatement to the State of Iowa her reinsta[te]ment to practice immigration law . . . was automatic.” On January 3, 2024, the BIA denied her motion for reinstatement based on that omission and required her to wait at least a year before reapplying. She filed another motion for reinstatement the following January, and on February 11, 2025, she was reinstated to practice before the BIA, DHS, and the immigration courts. On October 15, the Board filed a two-count complaint against Suarez. Count I alleged that she violated Iowa Rule of Professional Conduct 32:5.5(a) and 5 8 C.F.R. § 1003.102(n) (2025) by engaging in the unauthorized practice of law in the immigration forum. Following its evidentiary hearing, the commission found that Suarez violated rule 32:5.5(a), prohibiting the unauthorized practice of law.1 The commission concluded that a public reprimand was warranted for her violation of rule 32:5.5(a) alone. Count II of the Board’s complaint, as later summarized in the Board’s Statement in Support of Sanction, alleged that Suarez violated multiple rules in her representation of “a dissolution client, Joseph Burgett, by failing to prepare for his temporary matters hearing, failing to inform Joseph of the date of the hearing, failing to attend the hearing, and failing to promptly inform Joseph of what occurred at the hearing.” A record was developed at the commission’s evidentiary hearing, which included testimony from Joseph and Suarez and exhibits showing their communications and court filings. On May 29, 2024, Joseph filed a petition for relief from domestic abuse against his wife, Kylie, in Polk County. Suarez, then a sole practitioner, represented him in that matter. On June 10, Suarez filed a petition for dissolution of marriage on Joseph’s behalf. The next day, the court entered a protective order by consent. The order granted Joseph physical custody of his and Kylie’s children and provided Kylie with supervised visitation. Suarez joined the Noble Law Firm while representing Joseph. On July 16, Kylie filed a motion 1The commission also determined that Suarez violated rule 32:8.4(d) (conduct prejudicial to the administration justice) under Count I. The Board did not charge Suarez with violating that rule in Count I, and for that reason, we do not address it. See Iowa Sup. Ct. Att’y Disciplinary Bd. v. Rickabaugh, 728 N.W.2d 375, 379 n.3 (Iowa 2007) (declining to consider misrepresentations shown in the record because the Board did not charge them in its complaint). The Board did allege that Suarez violated the federal rule prohibiting conduct prejudicial to the administration of justice, 8 C.F.R. § 1003.102(n), but the commission did not find a violation of that rule. The Board requests that we find the federal rule was violated by relying on the similarity of the rules and transposing the commission’s finding that Suarez violated rule 32:8.4(d). We decline to do so. 6 for a hearing on temporary matters (custody and visitation). Suarez filed a partial resistance that day, noting that the protective order already addressed those matters. Suarez asked Joseph to write an affidavit supporting his position. He provided Suarez with a draft affidavit on July 23. She promised to review it. Three days later, he texted her again, asking if she’d reviewed it and whether he should “put all the dates [Kylie] was drunk in there and sign and notarize and be done with it?” Suarez responded, “Not yet but I will.” On July 29, the district court issued an order setting a hearing on temporary matters for August 26. Joseph was not informed of the hearing date. On August 1, staff at the Noble Law Firm emailed Joseph requesting his narrative about factors the court would consider in awarding primary physical care. Joseph provided that narrative the same day. Suarez responded, “We will rework and get back to you for signature/notary.” On August 2, staff revised the affidavit, saved it, and informed Suarez where to find it. Identical texts from the Noble Law Firm staff on August 5 and 12 told Joseph that “[o]ur team is actively and diligently working on [his case], we simply do not have any updates.” Joseph’s affidavit was never finalized or executed. In August, Kylie was only three months into recovery after years of heavy drinking, and Joseph doubted she was yet a safe or reliable caregiver for the children. On August 23, Kylie’s attorney filed exhibits on her behalf. Suarez filed no exhibits for Joseph. The court conducted the hearing as scheduled on August 26. Neither Suarez nor Joseph attended. Court staff contacted the Noble Law Firm, and Lisa Noble (who had not filed an appearance in the case) came to the hearing late and submitted no evidence on Joseph’s behalf. Suarez failed to update Joseph about what transpired at the hearing. Instead, on September 13, she texted him, “FYI - update. No order yet.” When Joseph asked what that meant, she replied, “No order on temporary matters yet.” The next day, after Joseph 7 mentioned a case-status message about temporary matters, Suarez responded, “I don’t see anything? Nothing since 8.23 was issued in the case. So still waiting.” Nor did she take any steps to fix what happened through a motion to reopen the record and offer Joseph’s affidavit into evidence during the ensuing four weeks before the court filed its ruling. On September 27, the district court issued its ruling adverse to Joseph. The court modified the prior protective order to allow Kylie joint physical care of their three minor children. The court noted that “Joseph did not submit any evidence in the Temporary Matters proceedings.” The court further noted, “Joseph requested temporary child support from Kylie, but he did not submit a Child Support Guideline Worksheet or other evidence that would allow the court to determine an appropriate child support obligation.” And the court faulted Joseph for not providing “a financial affidavit or any other information.” Joseph received the order late that afternoon. The next day, he urged Suarez to “file a motion to reopen the hearing or set aside the modification of the protective order ASAP.” He added, “I was not made aware of the hearing and didn’t have an opportunity to participate and the judge wasn’t given my affidavit.” Suarez responded that it was a temporary order and that “Temporary Matters aren’t testimonial.” Joseph sent this text to Suarez on September 29: I just heard a very different story about what happened with this temporary matters issue. Sounds like there was a hearing on 8/26. And everybody including the judge was shocked that we weren’t there and I submitted no evidence. Also, they waited and waited and finally Lisa [N]oble showed up because you were in trial. (Alteration in original.) Suarez responded by confirming that Noble was present at the hearing and that the “hearing was the very reason our staff was working with you . . . on your affidavit.” 8 The next day, Joseph discharged Suarez. He hired new counsel, who promptly filed a motion to vacate the temporary order based on Suarez’s failure to inform Joseph of the hearing or submit evidence on his behalf. On October 16, the court denied the request to vacate but reopened the record to permit additional evidence. The order noted that “the absence of any information” from Joseph meant his “perspective was not considered” in the September 27 order and that his “evidence . . . could have impacted the temporary ruling on custody and visitation.” Both parties submitted additional documentation that included new allegations against each other. But by this time, Kylie had been sober for about five months and had resumed meaningful involvement in parenting the children. On October 31, the court concluded that Kylie’s new evidence was sufficient to support its prior order on temporary matters and declined to modify it. The commission concluded that Suarez violated the following Rules of Professional Conduct as alleged by the Board: rule 32:1.3 (requiring reasonable diligence), rule 32:1.4(a)(3) (duty to keep client reasonably informed), and rule 32:8.4(d) (conduct prejudicial to the administration of justice). The commission elaborated as to her violation of rule 32:1.3: [T]he evidence demonstrates more than a singular oversight. [Suarez] failed to properly calendar a scheduled hearing, failed to timely obtain and submit a required affidavit, and failed to take appropriate, honest, and complete follow-up action after the hearing. Considered collectively, these omissions reflect a pattern of neglect rather than an isolated error. The commission explained why it found she violated rule 32:1.4(a)(3): The evidence established that [Suarez] did more than fail to communicate. She provided information that was misleading and created a false impression regarding the status of the matter and the actions that had been taken on the client’s behalf. . . . 9 . . . [Suarez] intentionally misled her client regarding the status of the representation. Such conduct deprived the client of the ability to make informed decisions and undermined the trust that is fundamental to the attorney-client relationship. The commission determined her conduct violated rule 32:8.4(d) by undermining “confidence in the legal profession and the proper functioning of the legal system.” The commission determined that “[t]aking count II alone, . . . a public reprimand is the appropriate sanction.” The commission then reviewed aggravating factors—most notably that Suarez intentionally misled her client, did not fully accept responsibility, and had a prior disciplinary history, as well as her approximately eighteen years of licensure—and mitigating factors, including that Suarez “has devoted significant time and effort to assisting members of the legal profession who struggle with substance-use issues” and that her volunteer service “reflects a commitment to the wellbeing of fellow attorneys and the profession as a whole.” The commission recommended a thirty-day suspension. Suarez did not appeal from the commission’s report. See Iowa Ct. R. 36.22(1). Nor did she exercise her right to file a statement regarding sanctions. See id. r. 36.21(1). The Board filed an unrebutted statement in support of the commission’s recommended thirty-day suspension. Id. II. Standard of Review. Although Suarez “did not appeal, it is our practice to review the record de novo and verify that the Board proved the violations charged.” Iowa Sup. Ct. Att’y Disciplinary Bd. v. Allison, 33 N.W.3d 192, 198 (Iowa 2026). “If we conclude the Board has proven violations, we then consider the appropriate sanction.” Id. 10 “In all of this, we give respectful consideration to the commission’s findings and recommendations, but we are not bound by them.” Id. III. Analysis. We find the facts as set forth above on our de novo review. First, we determine that Suarez violated Iowa Rule of Professional Conduct 32:5.5(a) by representing Villeda in a federal tribunal before her license to practice in that forum was reinstated. “Rule 32:5.5(a) prohibits a lawyer from ‘practic[ing] law in a jurisdiction in violation of the regulation of the legal profession in that jurisdiction.’ ” Iowa Sup. Ct. Att’y Disciplinary Bd. v. Hearity, 812 N.W.2d 614, 620 (Iowa 2012) (alteration in original) (quoting Iowa R. of Prof’l Conduct 32:5.5(a)). Suarez testified that she mistakenly believed our reinstatement of her Iowa license automatically allowed her to resume practicing in the federal immigration tribunals. The federal tribunals in fact required her to apply for and obtain an order reinstating her to practice in that forum. Her professed ignorance of the federal practice requirements is no defense here. That is because rule 32:5.5(a) “contains no express scienter requirement.” Id. The Board was not required to prove Suarez intentionally or knowingly violated the rule. See id. Second, we agree with the commission that Suarez violated Iowa Rule of Professional Conduct 32:1.3 in her representation of Joseph. Rule 32:1.3 provides that “[a] lawyer shall act with reasonable diligence and promptness in representing a client.” One missed hearing need not violate rule 32:1.3. “This is because ‘[a] violation of this rule arises not from inadvertent acts or omissions from missing a single deadline, but from consistently failing to perform functions required of an attorney or from repeatedly missing deadlines.’ ” Iowa Sup. Ct. Att’y Disciplinary Bd. v. Weiland, 885 N.W.2d 198, 208 (Iowa 2016) (alteration in original) (quoting Iowa Sup. Ct. Att’y Disciplinary Bd. v. Weiland, 862 N.W.2d 11 627, 635 (Iowa 2015)). Rather, a lawyer violates rule 32:1.3 when the lawyer “fails to appear at scheduled court proceedings, does not make the proper filings, or is slow to act on matters.” Id. (quoting Iowa Sup. Ct. Att’y Disciplinary Bd. v. Kingery, 871 N.W.2d 109, 117 (Iowa 2015)). Suarez failed to file Joseph’s crucial affidavit despite his persistent inquiries. She missed the court hearing that had been scheduled a month earlier. She then flunked damage control by failing to promptly move to reopen and supplement the record with Joseph’s affidavit well before the court issued its adverse ruling another month later. Third, we agree with the commission that Suarez violated Iowa Rule of Professional Conduct 32:1.4(a)(3). This rule “provides that a lawyer shall keep his or her client ‘reasonably informed’ about the status of the client’s legal matter.” Weiland, 885 N.W.2d at 209 (quoting Iowa R. of Prof’l Conduct 32:1.4(a)(3)). Suarez failed to timely communicate with Joseph to finalize and file his affidavit before the August 26 hearing. Then after missing the hearing, Suarez told Joseph nothing about it during the month before the first adverse ruling. When she did communicate, she told him there was “[n]o order on temporary matters yet” and that she was “still waiting,” without mentioning that the hearing had already occurred without them. By the time new counsel succeeded in reopening the record, Kylie had about two more months of sobriety behind her, which undercut the safety concerns Joseph’s evidence would have raised. What should have happened? Suarez should have reached out to Joseph the same day or the next day after missing the hearing and offered him an apology, followed by prompt action to reopen and supplement the record. Instead, she delayed and prevaricated. She misleadingly minimized the consequences of missing the hearing and the significance of the temporary order. She never acknowledged to Joseph that temporary orders on custody, support, 12 and visitation can and often do set the stage for similar determinations in the final decree. The commission found Suarez was intentionally misleading. Given her experience, we agree. Finally, we agree with the commission that Suarez violated Iowa Rule of Professional Conduct 32:8.4(d), which prohibits “conduct that is prejudicial to the administration of justice.” We reiterate that “an attorney violates rule 32:8.4(d) ‘when [her] misconduct results in additional court proceedings or causes court proceedings to be delayed or dismissed.’ ” Weiland, 885 N.W.2d at 212 (quoting Iowa Sup. Ct. Att’y Disciplinary Bd. v. Dolezal, 841 N.W.2d 114, 124 (Iowa 2013)). Because Suarez missed the August 26 hearing and its required filings, new counsel had to move to vacate the order and reopen the record, requiring additional filings and further delay. IV. Sanction. “The purposes of lawyer discipline include protection of the public, the need for deterring other lawyers from similar misconduct, upholding the integrity of the legal system, and assuring the fair administration of justice.” Iowa Sup. Ct. Att’y Disciplinary Bd. v. Lipski, 14 N.W.3d 751, 759 (Iowa 2024). “To determine the appropriate sanction, we consider the nature of the ethical duties that the lawyer violated, the lawyer’s mental state, the extent of the actual or potential injury caused by the lawyer’s misconduct, and any aggravating and mitigating circumstances.” Id. at 759–60. The commission recommends a thirty-day suspension. The Board asks us to impose a thirty-day suspension. Suarez did not file a statement regarding sanctions. The Board characterizes Suarez’s violation of rule 32:5.5(a) in Villeda’s immigration case as “an isolated instance of unauthorized practice.” We agree, 13 although the commission in her earlier proceeding found a prior violation of rule 32:5.5(a). See Suarez-Quilty, 912 N.W.2d at 153, 157. If that were her only violation, no more than a public reprimand would be warranted. See, e.g., Bd. of Prof’l Resp. v. Brimley, 344 P.3d 259, 260–62 (Wyo. 2015) (ordering public censure of an attorney licensed in Utah but not Wyoming who filed appearances in Wyoming on behalf of four defendants charged with motor vehicle violations). We find that a thirty-day suspension for her misconduct in the Burgett case aligns with our precedent given Suarez’s disciplinary history. See, e.g., Lipski, 14 N.W.3d at 757–58, 761–62 (imposing a thirty-day suspension for violating rules 32:1.3 and 32:1.4(a)(3), among others, when neglect of an appeal resulted in dismissal and Lipski misled the client about what happened); Iowa Sup. Ct. Att’y Disciplinary Bd. v. Sobel, 997 N.W.2d 421, 433–35 (Iowa 2023) (imposing a thirty-day suspension for violating rules 32:1.3, 32:1.4(a)(3), and 32:8.4(d), among other violations, in two separate matters); Weiland, 885 N.W.2d at 214–16 (imposing a sixty-day suspension when the lawyer mishandled a divorce petition and misled the client as to the status of the case, among other violations). We next consider aggravating and mitigating circumstances. We agree with the Board that Suarez’s disciplinary history—two public reprimands and a revocation—is “significantly aggravating.” See Iowa Sup. Ct. Att’y Disciplinary Bd. v. O’Brien, 971 N.W.2d 584, 593 (Iowa 2022) (concluding that a disciplinary history including two prior Iowa suspensions and a Nebraska disbarment “weighs heavy” in determining the sanction). We acknowledge that the misconduct that led to Suarez’s revocation was attributable to her alcoholism and that she has achieved and maintained sobriety since 2017. To her credit, Suarez volunteers for the Iowa Lawyers Assistance Program, and, as the 14 commission recognized, she “has devoted significant time and effort to assisting members of the legal profession who struggle with substance-use issues.” We consider her efforts to assist others in overcoming their addictions to be a significant mitigating factor. See Iowa Sup. Ct. Att’y Disciplinary Bd. v. Anderson, 21 N.W.3d 145, 150 (Iowa 2025) (finding an attorney’s participation in an expungement clinic and volunteer service as a moot court judge mitigating). But we also consider the timing of her ethical violations that so quickly followed her reinstatement after revocation. Suarez fumbled the fresh start we gave her. Suarez’s eighteen years of licensure is an aggravating factor. See id. at 149 (finding fifteen years of experience aggravating). Her violation of multiple rules is another aggravating factor. Sobel, 997 N.W.2d at 433. Yet another aggravating factor is that she intentionally misled her client. See Iowa Sup. Ct. Att’y Disciplinary Bd. v. Aeilts, 974 N.W.2d 119, 132 (Iowa 2022) (finding the dishonest nature of the misconduct aggravating). And we see client harm in the Burgett case, which also is an aggravating factor. Lipski, 14 N.W.3d at 761 (“Client harm is an aggravating factor.”). We agree with the Board and commission that a thirty-day suspension is appropriate under these circumstances. V. Disposition. We suspend Suarez’s license to practice law for thirty days, effective ten days from the date of this opinion. The suspension applies to all facets of the practice of law under Iowa Court Rule 34.23(4). She must comply with the notification requirements to her clients in Iowa Court Rule 34.23(2). We tax the costs of this action to Suarez under Iowa Court Rule 36.24(1). Attorney’s license suspended. All justices join this opinion except Mansfield, J., who takes no part.