## Facts

- William Ray Monroe, an Iowa attorney, entered an appearance for Jane Doe in a dissolution-of-marriage action in 2007.
- During the attorney–client relationship, Monroe and Doe had a sexual relationship while he continued representing her in the dissolution case and later in misdemeanor criminal matters, including a public intoxication charge.
- Monroe admitted the sexual relationship and admitted it violated Iowa Rule of Professional Conduct 32:1.8(j), with the qualification that the relationship predated the public intoxication case.
- Doe testified the relationship was consensual, Monroe did not exert undue influence, and they remained on good terms after it ended.
- After Doe’s estranged husband learned of the relationship, his divorce attorney reported it to the disciplinary authorities and informed the prosecutor handling Doe’s criminal cases.
- The prosecutor suggested Monroe withdraw; Monroe withdrew from the dissolution case but continued in the misdemeanor matters until they concluded.
- The grievance commission found misconduct and recommended a 30-day license suspension.

## Issues

1. Whether Monroe’s sexual relationship with a current client violated Iowa Rule of Professional Conduct 32:1.8(j).
2. Whether that misconduct constituted conduct prejudicial to the administration of justice under Iowa Rule of Professional Conduct 32:8.4(d).
3. What sanction was appropriate.

## Decision

- The court found Monroe violated rule 32:1.8(j) by engaging in sexual relations with a current client where no exception applied.
- The court declined to find a violation of rule 32:8.4(d), rejecting a per se approach and holding the record did not show actual prejudice to the administration of justice.
- The court suspended Monroe’s license to practice law for 30 days.

## Legal Principles

- Rule 32:1.8(j) prohibits sexual relations with a client unless the client is the lawyer’s spouse or the relationship predates the client-lawyer relationship; client consent does not excuse the violation.
- A violation of rule 32:1.8(j) does not automatically establish “conduct prejudicial to the administration of justice” under rule 32:8.4(d).
- For rule 32:8.4(d), the disciplinary authority must prove the conduct actually hampered the proper functioning of the court system, not merely that it breached another ethics rule.
- Sanctions for client-sexual-relationship violations may include actual suspension even absent coercion or demonstrated harm to the client’s legal outcomes.

## Conclusion

The court imposed a 30-day suspension for Monroe’s admitted violation of the categorical ban on sexual relations with a current client, but required separate proof of actual interference with the court system before finding conduct prejudicial to the administration of justice.


Iowa Supreme Court Attorney Disciplinary Board v. Monroe, 784 N.W.2d 784 (Iowa 2010)