IOWA SUPREME COURT ATTORNEY DISCIPLINARY BOARD 

COMES NOW Pro Se Michael J. Merritt for Complainant Cipher Hunter, in this matter before the Iowa Supreme Court Attorney Disciplinary Board. Respectfully requesting review of the below testimony and evidence in accordance with Iowa Rules of the Court Chapter 32 and 35.

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I. PARTIES

1. Petitioner, Cipher Hunter, is a civic transparency and records research initiative focused on the protection of civil liberties and governmental accountability registered in Marshall County, Iowa, and managed by Michael J. Merritt. Mr. Merritt is a retired U.S. Navy veteran, information warfare specialist, and public records researcher. He is also an advocate for domestic violence survivors, individuals living with mental health disabilities, and veterans affected by military sexual trauma (MST).
2. Respondent Erika Eckley is the Executive Director of the Iowa Public Information Board and, as of 14 MAY 2025, was selected as the Executive Director of the Iowa Ethics and Campaign Disclosure Board.

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II.  CAUSE OF ACTION

This complaint presents evidence of multiple violations of the Iowa Rules of Professional Conduct. The violations are attributed to Iowa Public Information Board Executive Director Erika Eckley.  However, this complaint is limited to evidence regarding Eckley’s conduct during IPIB Case 25FC:0014 and the subsequent actions that arose from that case.  A final formal complaint—incorporating alleged violations not specifically cited here but supported by evidence included in this submission—will be filed with the Iowa Supreme Court Attorney Disciplinary Board. This final complaint will be submitted upon conclusion of the Complainant’s statewide investigation into Erika Eckley’s conduct and a future Iowa Court case, as detailed in Attachment 31.

Multiple alleged violations of the Iowa Rules of Professional Conduct stem from a unified sequence of factual events. To maintain legal sufficiency for each rule cited, overlapping facts appear where necessary to establish each violation in isolation.

1. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — Iowa Public Information Board Executive Director allegedly failed to manifest her responsibilities pursuant to Iowa Code §§ 23.6(4) and 23.6(5).  The evidence indicates that Executive Director Eckley disregarded a request for a public record (See Attachment 14 and 17)—or failed to acknowledge its existence—pertaining to alleged historical misconduct by the Jasper County, IA, Attorney’s Office.  The requested record contained historical evidence that cast doubt on the integrity of Jasper County, IA, Attorney Scott Nicholson’s testimony related to IPIB case 25FC:0014.  Ultimately, the evidence shows Iowa Public Information Board Executive Director Eckley decided to withhold evidence showing her receipt of an electronic mail that called into question the historical conduct of the Jasper County, IA, Attorney’s Office.  At the same time, Attachment 19 shows the Executive Director proposed a quid pro quo scheme that suggested the Complainant withdraw all historical requests that were not completed by Jasper County, IA, (leading to historical complaints that evidence shows the Executive Director disregarded (See Attachment 7) becoming moot) in exchange for the public record that Jasper County, IA, was being asked to produce.
2. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — On 21 MAR 2025, a public records request was sent to Iowa Public Information Board Executive Director Eckley pursuant to Iowa Code § 22.4(2) requesting a public record (See Attachment 14).  Evidence shows this requested public record was sent to the Executive Director related to the Jasper County, IA, Attorney’s office’s alleged historical misconduct referenced in IPIB case 25FC:0014.  On 14 APR 2025, Iowa Public Information Board Executive Director Eckley was again requested to release the requested public record (See Attachment 17).  No evidence has been received indicating Iowa Public Information Board Executive Director Eckley adhered to her responsibilities pursuant to Iowa Code Chapter 22.
3. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — On 03 JUN 2025, a complaint against Jasper County, IA, was submitted to the Iowa Public Information Board (See Attachment 30).  This complaint was regarding evidence of Jasper County, IA, Attorney Scott Nicholson failing to provide a public record showing the alleged fee he claimed the Complainant failed to pay in IPIB case 25FC:0014 (See Attachment 13).  The public record Jasper County, IA, was requested to provide is the same public record that the Iowa Public Information Board Executive Director should have requested from Jasper County, IA, Attorney Scott Nicholson in case 25FC:0014 pursuant to Iowa Code §§ 23.6(4) and 23.6(5) to verify his testimony in case 25FC:0014 rather than the unethical quid pro quo scheme she proposed in Attachment 19 and Jasper County, IA, Attorney Scott Nicholson agreed to in Attachment 20.  An alleged scheme that would have made all historical record requests that evidence shows Jasper County, IA, Attorney Scott Nicholson disregarded and related IPIB complaints moot. Evidence indicates the Iowa Public Information Board Executive Director disregarded numerous complaints during 2023 and 2024 while failing to manifest her responsibilities pursuant to Iowa Code § 23.7.  Evidence provided in Attachment 3 indicates this posture executed by Iowa Public Information Board Executive Director and former Iowa Public Information Board Chair Julie Pottorff was directly related to evidence of discrimination against mental health-based service-connected disabilities.  Disabilities protected by Iowa Code Chapter 216 that Attachment 4 shows the Executive Director attempted to criminalize in correspondence with the Iowa Department of Public Safety.
4. 32:3.4(a) — “unlawfully obstruct another party’s access to evidence or unlawfully alter, destroy, or conceal a document or other material having potential evidentiary value. A lawyer shall not counsel or assist another person to do any such act;” On 21 MAR 2025, a public records request was sent to Iowa Public Information Board Executive Director Eckley pursuant to Iowa Code § 22.4(2) requesting a public record (See Attachment 14).  Evidence shows this requested public record was sent to the Executive Director related to the Jasper County, IA, Attorney’s office’s alleged historical misconduct referenced in IPIB case 25FC:0014.  On 14 APR 2025, Iowa Public Information Board Executive Director Eckley was again requested to release the requested public record (See Attachment 17).  No evidence has been received indicating Iowa Public Information Board Executive Director Eckley adhered to her responsibilities pursuant to Iowa Code Chapter 22.
5. 32:3.4(a) — “unlawfully obstruct another party’s access to evidence or unlawfully alter, destroy, or conceal a document or other material having potential evidentiary value. A lawyer shall not counsel or assist another person to do any such act;” On 16 JUN 2025 Iowa Public Information Board Executive Director Erika Eckley was requested to provide public records that evidence indicates to date both Taryn Frideres (See ISCADB Complaint — Taryn Frideres) and Katlin Smith (See ISCADB Complaint — Katlin Smith) have also failed to release after being requested to do so.  The public records requested included two public records requests from 2024 that the Office of Iowa Governor Kim Reynolds also chose to ignore.  Given the evidence within Iowa Code § 23.3(1) that indicates the Governor of the State of Iowa appoints the members of the Iowa Public Information Board.  Iowa Code § 23.3(6) also shows that those same members who were appointed by the Governor of the State of Iowa hired the Iowa Public Information Board Executive Director. Arriving at a possible motive why Executive Director Eckley would not want to release public records that might expose the Office of the Governor to civil liability, was not too difficult to arrive at.
6. 32:4.4(a.) — “In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.” — Iowa Public Information Board Executive Director allegedly failed to manifest her responsibilities pursuant to Iowa Code §§ 23.6(4) and 23.6(5).  The evidence indicates that Executive Director Eckley disregarded a request for a public record (See Attachment 14 and 17)—or failed to acknowledge its existence—pertaining to alleged historical misconduct by the Jasper County, IA, Attorney’s Office.  The requested record contained historical evidence that cast doubt on the integrity of Jasper County, IA, Attorney Scott Nicholson’s testimony related to IPIB case 25FC:0014.  Ultimately, the evidence shows Iowa Public Information Board Executive Director Eckley decided to withhold evidence showing her receipt of an electronic mail that called into question the historical conduct of the Jasper County, IA, Attorney’s Office.  At the same time, Attachment 19 shows the Executive Director proposed a quid pro quo scheme that suggested the Complainant withdraw all historical requests that were not completed by Jasper County, IA (leading to historical complaints that evidence shows the Executive Director disregarded (See Attachment 7) becoming moot) in exchange for the public record that Jasper County, IA, was being asked to produce.
7. 32:4.4(a.) — “In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.” — On 21 MAR 2025, a public records request was sent to Iowa Public Information Board Executive Director Eckley pursuant to Iowa Code § 22.4(2) requesting a public record (See Attachment 14).  Evidence shows this requested public record was sent to the Executive Director related to the Jasper County, IA, Attorney’s office’s alleged historical misconduct referenced in IPIB case 25FC:0014.  On 14 APR 2025, Iowa Public Information Board Executive Director Eckley was again requested to release the requested public record (See Attachment 17).  No evidence has been received indicating Iowa Public Information Board Executive Director Eckley adhered to her responsibilities pursuant to Iowa Code Chapter 22.
8. 32:4.4(a.) — “In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.” — On 16 JUN 2025 Iowa Public Information Board Executive Director Erika Eckley was requested to provide public records that evidence indicates to date both Taryn Frideres (See ISCADB Complaint — Taryn Frideres) and Katlin Smith (See ISCADB Complaint — Katlin Smith) have also failed to release after being requested to do so.  The public records requested included two public records requests from 2024 that the Office of Iowa Governor Kim Reynolds also chose to ignore.  Given the evidence within Iowa Code § 23.3(1) that indicates the Governor of the State of Iowa appoints the members of the Iowa Public Information Board.  Iowa Code § 23.3(6) also shows that those same members who were appointed by the Governor of the State of Iowa hired the Iowa Public Information Board Executive Director. Arriving at a possible motive why Executive Director Eckley would not want to release public records that might expose the Office of the Governor to civil liability, was not too difficult to arrive at.
9. 32:4.4(a.) — “In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.” — On 03 JUN 2025, a complaint against Jasper County, IA, was submitted to the Iowa Public Information Board (See Attachment 30).  This complaint was regarding evidence of Jasper County, IA, Attorney Scott Nicholson failing to provide a public record showing the alleged fee he claimed the Complainant failed to pay in IPIB case 25FC:0014 (See Attachment 13).  The public record Jasper County, IA, was requested to provide is the same public record that the Iowa Public Information Board Executive Director should have requested from Jasper County, IA, Attorney Scott Nicholson in case 25FC:0014 pursuant to Iowa Code §§ 23.6(4) and 23.6(5) to verify his testimony in case 25FC:0014 rather than the unethical quid pro quo scheme she proposed in Attachment 19 and Jasper County, IA, Attorney Scott Nicholson agreed to in Attachment 20.  An alleged scheme that would have made all historical record requests that evidence shows Jasper County, IA, Attorney Scott Nicholson disregarded and related IPIB complaints moot. Evidence indicates the Iowa Public Information Board Executive Director disregarded numerous complaints during 2023 and 2024 while failing to manifest her responsibilities pursuant to Iowa Code § 23.7.  Evidence provided in Attachment 3 indicates this posture executed by Iowa Public Information Board Executive Director and former Iowa Public Information Board Chair Julie Pottorff was directly related to evidence of discrimination against mental health-based service-connected disabilities.  Disabilities protected by Iowa Code Chapter 216 that Attachment 4 shows the Executive Director attempted to criminalize in correspondence with the Iowa Department of Public Safety.
10. 32:8.4(g) — “engage in sexual harassment or other unlawful discrimination in the practice of law or knowingly permit staff or agents subject to the lawyer’s direction and control to do so.” Iowa Public Information Board Executive Director Erika Eckley’s alleged conduct that evidence indicates violates the Iowa Rules of Professional Conduct, Iowa Code Chapter 22, Iowa Code Chapter 23, and Iowa Code Chapter 216 evidence supports is related to her historical posture of discrimination against service-connected mental health disabilities (See Attachments 3 and 4).  Attachment 4 shows that the Executive Director attempted to criminalize these service-connected mental health disabilities that are documented by the United States Department of Veterans Affairs.  This complaint documents nine individual unethical acts inconsistent with the Iowa Code and the Iowa Rules of Professional Conduct that are related to the evidence of the Executive Director’s alleged acts of discrimination shown in Attachments 3 and 4.
11. 32:8.4(a.) — “violate or attempt to violate the Iowa Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;” — This complaint alleges Iowa Public Information Board Executive Director Erika Eckley has produced evidence supporting ten individual violations of the Iowa Rules of Professional Conduct as supported by the testimony and evidence within this complaint.  A final complaint will be submitted upon the completion of the Complainant’s statewide investigation and the conclusion of a future Iowa Court case against the Iowa Public Information Board.

The following section provides a factual timeline and documentation supporting the violations outlined above.

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III. FACTS AND BACKGROUND

The timeline of evidence supports the conclusion that Iowa Public Information Board Executive Director Erika Eckley:  

1. Failed to release a requested public record pursuant to Iowa Code Chapter 22 that was requested on 21 MAR 2025 (See Attachment 14). 
2. Failed to release a requested public record pursuant to Iowa Code Chapter 22 that was requested on 16 JUN 2025 (See Attachments 32 and 33).
3. Failed to initiate a formal complaint pursuant to Iowa Code § 23.7 (See Attachment 30).
4. Failed to manifest a lawful investigation pursuant to Iowa Code §§ 23.6(4) and 23.6(5), during IPIB case 25FC:0014 while simultaneously proposing a quid pro quo scheme, which evidence indicates was designed to render historical record requests submitted to Jasper County, IA—and the related complaints disregarded by the Iowa Public Information Board—moot in exchange for the requested public record (See Attachment 19). 
5. Engaged in discriminatory conduct while denying a citizen of the State of Iowa access to public accommodations, in violation of Iowa Code Chapters 22, 23, and 216 (See Attachments 3, 4, 5, 6, and 7).

Timeline of Events

Each of the following events corresponds to a documented attachment and supports the foundation for the alleged Iowa Rules of Professional Conduct violations outlined in Section II.

1. 20 APR 2023 — Electronic mail block and communicated direction to the Jasper County, IA, Attorney’s office for no further contact from Jasper County, IA, CIO Ryan Eaton (See Attachment 1, Electronic Mail — Michael J Merritt — 20 APR 2023).
2. 21 APR 2023 — Correction to Attachment 1 (See Attachment 2, Electronic Mail — Michael J Merritt — 21 APR 2023).
3. 11-12 JUL 2023 — On 11 JUL 2023, Iowa Public Information Board Executive Director Erika Eckley communicated, “His emails are getting more and more prolific (maybe I just had a reprieve for a couple months) and quite frankly, I have some cyber security concerns with his links and attachments.  I especially worry about this database he is building which sounds like he is trying to be able to search all of the electronic records for all these entities or that it could create some security risks if he collects information about where and how records are stored online.  I don’t know if he is capable of collecting such information or if this is part of some of his mental health issues.”  On 12 JUL 2023, Iowa Public Information Board Chair Julie Pottorff communicated, “I think it’s probably related to mental health issues.  But you might call the Department of Public Safety and ask to talk to someone about your concerns.  Someone in that department should be able to give you advice about dealing with him and should know whether any investigation into his activities is warranted.  If investigation is warranted, the Department of Public Safety should handle it.”  (See Attachment 3, Electronic Mail – Iowa Public Information Board — Combined – 11-12 JUL 2023–1458).
4. 13-14 JUL 2023 — On 13 JUL 2023, Iowa Public Information Board Executive Director Erika Eckely communicated to the Iowa Department of Public Safety, “I am uncertain if this is the appropriate division or if there is a better place to reach out for some assistance, so please let me know if there is.  Michael Merritt communicates almost on a daily basis with IPIB in the fashion similar to below. (This is actually much shorter and lucid than most.) I have some cyber security concerns with his links and attachments. I especially worry about this database he says he is building which sounds like he is trying to be able to search all of the electronic records for all these entities or that it could create some security risks if he collects information about where and how records are stored online. I don’t know if he is capable of collecting such information or if this is part of some of his mental health issues. He has said that he had extensive computer and networking experience in the Navy. I do know that he makes prolific requests to cities and counties and many requests address emails and information related to their email systems, so it is possible he is gathering information that would be useful for such purposes. IPIB does not seem to have any authority or ability to address anything like this, so I am asking for any guidance or assistance you can provide on what limits we should put to ensure protection for government entities. It is possible that this is not anything that I need to worry about, if so, please let me know that as well. Thank you for any assistance or direction you can provide.”  On 14 JUL 2023, State of Iowa Criminal Intelligence Analyst Nicole Roberts communicated to Iowa Public Information Board Executive Director Erika Eckley, “Good Morning – The below email was received. We have shared this information with OCIO and the Iowa State Patrol for their awareness. Cyber related concerns can be directed to can be directed to OCIO also in the future: https://ocio.iowa.gov/ Thanks, Nikki” (See Attachment 4, Electronic Mail — Nicole Roberts — 14 JUL 2023–1103).
5. 20 JUL 2023 — Iowa Public Information Board 20 JUL 2023 Public Meeting (See Attachment 5, Chest Cam — Iowa Public Information Board Public Meeting — 20 JUL 2023).
6. 08 AUG 2023 — Iowa Public Information Board Executive Director Erika Eckley communicated to the State of Iowa Chief Information Officer, “I am not certain if this is anything that you all can address or need to address, but I have ongoing concerns regarding the activity from Mr. Merritt. I sent some information to public safety, but they suggested I contact OCIO. Mr. Merritt is making 1000s of records requests to government entities. He has a right to do that. The concern I have is that he has stated that he wants to develop a database of the government email systems etc. I know he is prolific in his postings online, and I am not sure how much information he has gathered or what he has posted that could potentially create risks and vulnerabilities to government entities. He continues to tout his military training in data security, so I am certain he is able to pull quite a bit of information from his requests. I have concerns about the scope of what is being collected and potential harm that could be done if there is a database that shares information that could be useful to others to harm these government systems if bad actors were able to use the information to insert malware or ransomware. If there is no concern, then please let me know. If there is concern, then any recommendations you have to assist in educating entities about how to respond to requests for emails and data information or what to retain for security would be much appreciated. Thank you for your time.”  (See Attachment 6, Electronic Mail — Iowa Public Information Board Executive Director Eckley — 08 AUG 2023–1551).
7. 22 AUG 2023 — Iowa Public Information Board Executive Director Eckley communicated, “The Iowa Public Information Board is not able to accept any of the 35 complaints filed at 3:48 a.m. on August 11, 2023.  In reviewing the seemingly auto-generated and batched complaints, there is no evidence that any government entity has refused to comply with the request as made.  There is also no evidence that the requests have even be received by the entities.  You have withdrawn your complaints against the Iowa Department of the Blind and the Iowa Secretary of State’s office, the remaining 33 complaints are dismissed as failing to allege a violation of Iowa Code Chapter 22.” (See Attachment 7, Memorandum — Iowa Public Information Board Executive Director Erika Eckley — 22 AUG 2023).
8. 15 SEP 2023 — “Erika Eckley, the board’s executive director, told the committee the proposed legislation is intended to address what she called “excessive and abusive” requests for information. ”, “We’ve had some issues with individuals filing hundreds of requests and engaging in abuse – what many would consider abusive and harassing conduct related to those,” Eckley told the committee. “And so looking at it there’s not a lot that individuals can do if they’re in that situation. There’s very little that they can do other than to continue to just take the harassment and continue to have to review the information from that individual to make sure they are complying with their (Open Records Law) requirements.”, “I’m not sure if it’s 100 for one specific agency, but there have been hundreds sent out by — across the state — quite extensive,” she said. She added that she has “become aware of an individual basically automating across all counties, all school boards, all cities, and such, seeking extensive records and then the communications after that can be quite abusive and harassing.”, “Eckley declined to identify the person who is making the “automated” requests and abusive comments, although she acknowledged the records requests are, themselves, considered to be public documents in Iowa”, “I don’t feel comfortable sharing the individual’s name,” she said. “This isn’t just one person, but this is — I mean, it was brought up because of that situation, but this is, I don’t believe this is a one-person issue.”, “She said the proposed legislation was composed at her own initiative and that no city, county or state officials had suggested she draft such a bill. “I brought up the potential issue to look at as something within our scope if there’s issues within the public records for our board to look at and consider if there’s anything we need to do or not,” she said.”, “When asked about that at Friday’s meeting, Eckley said the issue before the board has more to do with “the conduct” of the people requesting the records than with the requests themselves. “I guess that the purpose (of the draft legislation) is to look at if there are ways that we can prevent front-line employees from significant harassing behavior or other things that make it so that they’re not able to do the job, their main job for government,” she said. “It’s not to prevent individuals from filing requests. It’s to address those extreme cases.” (See Attachment 8, News Article — Iowa Capital Dispatch — 15 SEP 2023).
9. 22 SEP 2023 — “A Navy veteran who says he has PTSD is the man responsible for triggering proposed new restrictions on Iowans’ access to government documents.”, “The individual, Michael J. Merritt of Newton, calls himself “Cipher Hunter” and describes himself as a “creative writer/musician and information warfare specialist.”, “He wrote to one state official earlier this year and explained that he had “been diagnosed with post-traumatic stress disorder related to multiple false allegations of criminal conduct going back to January 2017.”, “Last month, he filed almost three dozen complaints with the Iowa Public Information Board, each alleging violations of Iowa’s Open Records Law. Merritt’s actions prompted IPIB’s executive director to urge the board to take action, calling it a “potential immediate crisis” that could quickly consume all of IPIB’s resources by forcing the board to investigate each of Merritt’s complaints.  Within days, IPIB quickly rejected all of Merritt’s complaints, but then began considering proposed legislation that would enable state agencies, as well as Iowa’s cities, counties and school districts, to ignore for up to one year any public-records requests generated by individuals deemed by the board to be the work of a “vexatious requester.” IPIB Executive Director Erika Eckley has said that while the proposed bill was prompted by the actions of one individual, she believes it’s not “a one-person issue” in Iowa. The Iowa Capital Dispatch was unable to reach Merritt for comment.”, “Some board members have already expressed reservations with the proposal, noting that government agencies can pursue harassment charges or seek injunctive relief through the civil courts.”, “In July, Merritt sent Eckley an email with the subject header “The Form of the Flying Dutchman,” announcing his plans to donate to the state a database he had created showing where all state and local government agencies electronically store and preserve public documents. In the email, which was copied to dozens of other public officials, Merritt said he had compiled the database while being treated for PTSD.”, “Pottorff responded by indicating Merritt’s actions were “probably related to his mental health issues” and suggested Eckley consult with the Iowa Department of Public Safety.”, “Days later, Eckley wrote to the state’s Office of Chief Information Officer to express “ongoing concerns regarding the activity from Mr. Merritt.” Eckley wrote that “Merritt is making 1000s of records requests to government entities. He has a right to do that. The concern I have is that he has stated he wants to develop a database of the government email systems, etc.” She wrote that she was concerned about the “potential harm that could be done if there is a database that shares information that could be useful to others to harm these government systems if bad actors were able to use the information to insert malware of ransomware.”, “At one point he told me he was going to develop a database of information to make request to government entities easier – particularly how they store emails,” Eckley told the board members. “I am not sure his actions are meant to be a cybersecurity threat, but he could be creating information that others could use for attacks.” She warned of a “potential immediate crisis” that would have a direct impact on her own office, which works to resolve disputes over public-records requests. “This has ballooned into something that could consume all of the IPIB resources … if we have to open a complaint for every allegation he makes in regards to his voluminous and indecipherable requests.” (See Attachment 9, News Article — Iowa Capital Dispatch — 22 SEP 2023).
10. 18 DEC 2024 — Statewide records request requesting Microsoft 365/Google Workspace billing records for investigation into Jasper County, IA’s alleged historical inflated public records fees.  A research product managed through the analysis of control and variable data and statewide comparison data regarding Jasper County, IA’s historical responses in contrast to other State of Iowa government bodies (See Attachment 10, Electronic Mail — Michael J Merritt — 18 DEC 2024).
11. 05 FEB 2025 — IPIB acceptance of complaint 25FC:0014 (See Attachment 11, Electronic Mail — Iowa Public Information Board — 05 FEB 2025).
12. 05 MAR 2025 — IPIB acceptance of complaint 25FC:0014 (See Attachment 12, Electronic Mail — Iowa Public Information Board Executive Director Eckley — 05 MAR 2025).
13. 19 MAR 2025 — IPIB’s relay of Respondent’s communications to Complainant in IPIB case 25FC:0014 (See Attachment 13, Electronic Mail — Iowa Public Information Board Executive Director Eckley — 19 MAR 2025).
14. 21 MAR 2025 — Complainant’s records request to the IPIB to provide their copy of Attachment 1 to authenticate statewide transmission of electronic mail block and direction to Jasper County, IA, to halt Jasper County, IA, CIO Ryan Eaton’s communications with the Complainant.  Evidence indicates the Iowa Public Information Board disregarded this records request (See Attachment 14, Electronic Mail — Michael J Merritt — 21 MAR 2025).
15. 01 APR 2025 — IPIB’s request for original record request in IPIB complaint 25FC:0014 (See Attachment 15, Electronic Mail — Michael J Merritt — 01 APR 2025).
16. 13 APR 2025 — Complainant’s original request that Jasper County, IA, provide historical invoice public records showing their alleged time and fees (Jasper County, IA, alleged in Attachment 13) for the Complainants historical public records requests (See Attachment 16, Electronic Mail — Michael J Merritt — 13 APR 2025).
17. 14 APR 2025 — Complainant’s second request for the IPIB’s copy of Attachment 1 and follow up to the request in Attachment 14 that evidence indicates the IPIB failed to respond or provide the requested public record (See Attachment 17, Electronic Mail — Michael J Merritt — 17 APR 2025).
18. 24 APR 2025 — Complainant’s situational analysis and status update (See Attachment 18, Electronic Mail — Michael J Merritt — 24 APR 2025).
19. 06 MAY 2025 — Evidence supporting Iowa Public Information Board Executive Director Eckley’s quid pro quo tactics within the IPIB’s informal resolution process (See Attachment 19, Electronic Mail — IPIB Executive Director Eckley — 06 MAY 2025).
20. 07 MAY 2025 — Jasper County, IA, Attorney Scott Nicholson’s agreement to Iowa Public Information Board Executive Director Eckley’s proposal in Attachment 19 (See Attachment 20, Electronic Mail — Jasper County, IA Attorney Scott Nicholson — 07 MAY 2025).
21. 07 MAY 2025 — Complainant’s ethical analysis and rebuttal regarding the evidence supporting the corrupt nature within Attachments 19 and 20 (See Attachment 21, Electronic Mail — Michael J Merritt — 07 MAY 2025).
22. 08 MAY 2025 — Complainant’s declaration to assume investigative responsibilities in light of the evidence supporting the IPIB’s inaction and failure to manifest Iowa Code §§ 23.6(4) and 23.6(5) (See Attachment 22, Electronic Mail — Michael J Merritt — 08 MAY 2025–1254).
23. 08 MAY 2025 — Iowa Public Information Board Executive Director Eckley communicates that she considers Attachment 22 a withdrawal of the complaint for IPIB case 25FC:0014 (See Attachment 23, Electronic Mail — Iowa Public Information Board Executive Director Eckley — 08 MAY 2025).
24. 08 MAY 2025 — Complainant’s analysis of the historical evidence showing Iowa Public Information Board Executive Director Eckley’s professional conduct (See Attachment 24, Electronic Mail — Michael J Merritt — 08 MAY 2025–1344).
25. 08 MAY 2025 — Complainant’s second request and follow up to Attachment 16 requesting Jasper County, IA, to provide public records regarding historical invoicing and billing of the alleged public records fees communicated by Jasper County, IA, Attorney Scott Nicholson in Attachment 13 (See Attachment 25, Electronic Mail — Michael J Merritt — 08 MAY 2025–2141).
26. 09 MAY 2025 — IPIB public meeting announcement for case 25FC:0014 (See Attachment 26, Electronic Mail — Iowa Public Information Board Executive Director Eckley — 09 MAY 2025).
27. 09 MAY 2025 25FC:0014 Investigative Report (See Attachment 27, 24FC_0014 Merritt Investigative Report).
28. 19 MAY 2025 IPIB Announcement of public meeting board findings in IPIB case 25FC:0014 (See Attachment 28, Electronic Mail — Iowa Public Information Board Executive Director Eckley — 19 MAY 2025).
29. 19 MAY 2025 — 25FC:0014 Investigative Report (See Attachment 29, 24FC_0014 Merritt PCO).
30. 03 JUN 2025 — Iowa Public Information Board Complaint submitted against Jasper County, IA, regarding evidence supporting the county’s failure to respond to multiple records requests for evidence supporting the fee Jasper County, IA, Attorney Scott Nicholson alleged the Complainant failed to pay during IPIB case 25FC:0014 (See Attachment 13).  To date, the evidence indicates that Nicholson has failed to provide evidence supporting his claims during IPIB case 25FC:0014.  Evidence indicates Iowa Public Information Board Executive Director Erika Eckley disregarded this complaint possibly because it seeks evidence that Eckley should have requested during case IPIB case 25FC:0014 pursuant to Iowa Code §§ 23.6(4) and 23.6(5) (See Attachment 30, Electronic Mail — Michael J Merritt — 03 JUN 2025).
31. 10 JUN 2025 — Right To Sue Letter released by the Iowa Civil Rights Commission related to the evidence supporting Iowa Public Information Board Executive Director Eckley and former Iowa Public Information Board Chair Julie Pottorff’s posture of alleged discrimination and criminalization of a protected class pursuant to Iowa Code Chapter 216 (See Attachment 31, MM RTS).
32.  16 JUN 2025 — A record request submitted to the State of Iowa requesting public records that evidence shows the Office of the Governor of the State of Iowa (See ISCADB Complaint — Taryn Frideres) and the Iowa Civil Rights Commission (See ISCADB Complaint  — Kaitlin Smith) failed to provide (See Attachment 32, Electronic Mail — Michael J Merritt — 16 JUN 2025).
33. 23 JUN 2025 — Iowa Public Information Board Executive Director Erika Eckley’s response to Attachment 32 providing evidence of a complete disregard of her responsibilities to adhere to and enforce Iowa Code Chapter 22 (See Attachment 33, Electronic Mail — Iowa Public Information Board Executive Director Erika Eckley — 23 JUN 2025).

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IV. ATTACHMENTS

1. Electronic Mail — Michael J Merritt — 20 APR 2023
2. Electronic Mail — Michael J Merritt — 21 APR 2023
3. Electronic Mail – Iowa Public Information Board — Combined – 11-12 JUL 2023–1458
4. Electronic Mail — Nicole Roberts — 14 JUL 2023–1103
5. Chest Cam — Iowa Public Information Board Public Meeting — 20 July 2023
6. Electronic Mail — Iowa Public Information Board Executive Director Eckley — 08 AUG 2023–1551
7. Memorandum — Iowa Public Information Board Executive Director Erika Eckley — 22 AUG 2023
8. News Article — Iowa Capital Dispatch — 15 SEP 2023
9. News Article — Iowa Capital Dispatch — 22 SEP 2023
10. Electronic Mail — Michael J Merritt — 18 DEC 2024
11. Electronic Mail — Iowa Public Information Board — 05 FEB 2025
12. Electronic Mail — Iowa Public Information Board Executive Director Eckley — 05 MAR 2025
13. Electronic Mail — Iowa Public Information Board Executive Director Eckley — 19 MAR 2025
14. Electronic Mail — Michael J Merritt — 21 MAR 2025
15. Electronic Mail — Michael J Merritt — 01 APR 2025
16. Electronic Mail — Michael J Merritt — 13 APR 2025
17. Electronic Mail — Michael J Merritt — 14 APR 2025
18. Electronic Mail — Michael J Merritt — 24 APR 2025
19. Electronic Mail — IPIB Executive Director Eckley — 06 MAY 2025
20. Electronic Mail — Jasper County, IA Attorney Scott Nicholson — 07 MAY 2025
21. Electronic Mail — Michael J Merritt — 07 MAY 2025
22. Electronic Mail — Michael J Merritt — 08 MAY 2025–1254
23. Electronic Mail — Iowa Public Information Board Executive Director Eckley — 08 MAY 2025
24. Electronic Mail — Michael J Merritt — 08 MAY 2025–1344
25. Electronic Mail — Michael J Merritt — 08 MAY 2025–2141
26. Electronic Mail — Iowa Public Information Board Executive Director Eckley — 09 MAY 2025
27. 24FC_0014 Merritt Investigative Report
28. Electronic Mail — Iowa Public Information Board Executive Director Eckley — 19 MAY 2025
29. 24FC_0014 Merritt PCO
30. Electronic Mail — Michael J Merritt — 03 JUN 2025
31. MM RTS
32. Electronic Mail — Michael J Merritt — 16 JUN 2025
33. Electronic Mail — Iowa Public Information Board Executive Director Erika Eckley — 23 JUN 2025

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V. ANALYSIS

The evidence presented in this complaint supports multiple violations of the Iowa Rules of Professional Conduct. These violations are not theoretical—they are rooted in public communications, official correspondence, and documented timelines. Iowa Public Information Board Executive Director Erika Eckley’s failure to release lawful public records pursuant to Iowa Code Chapter 22, refusal to properly respond to a complaint filed pursuant to Iowa Code § 23.7, historical acts of discrimination, and a quid pro quo proposal during IPIB complaint 25FC:0014 all contributed to procedural obstruction, emotional harm, denial of rights, and violations of protections guaranteed under Iowa Code Chapters 22, 23, and 216.

Taken together, this conduct reflects not a single lapse in judgment, but a pattern of obstruction and disregard for legal transparency. Such behavior, when committed by the Executive Director of the Iowa Public Information Board, endangers the public’s trust in the State of Iowa’s position toward government transparency and violates the ethical obligations to the Iowa Rules of Professional Conduct.

When considered alongside Governor Kim Reynolds’s historical lapses regarding public records access, the evidence of Director Eckley’s past conduct reveals evidence supporting a troubling statewide posture that is inconsistent with Iowa Code Chapter 22 that threatens the very integrity of transparency in the State of Iowa.

“A journalist is arrested and put on trial for doing her job. The governor’s office and state agencies defy the law without consequence by ignoring or refusing requests for public records. A veteran state employee claims she was fired for complying with the law and providing a public record to a reporter.”

“Just last week, Iowa Capital Dispatch Deputy Editor Clark Kauffman reported that the governor’s office ignored public records requests related to the firing of the head of the Iowa Veterans Home. Among documents obtained elsewhere by Iowa Capital Dispatch were a series of thank-you notes former Commandant Timon Oujiri had written to the governor and chief of staff for “raises.” Two years after the first note, he was fired for receiving overpayments.”

Pfannenstiel, Brianne. The Reynolds Administration Is the Least Transparent in 30 Years. Iowa Capital Dispatch, 9 Aug. 2021, https://iowacapitaldispatch.com/2021/08/09/the-reynolds-administration-is-the-least-transparent-in-30-years/. Accessed 22 June 2025.

“The state of Iowa agreed Wednesday to pay more than $174,000 in attorney fees to settle three lawsuits against Republican Gov. Kim Reynolds that accused her of failing to follow the state’s public records law.

The settlements follow an Iowa Supreme Court ruling from April in which the justices unanimously agreed the governor’s office can be sued for not providing public documents in a timely manner and allowed the lawsuits to continue. The parties have decided to settle the lawsuits instead of continuing the fight in court.

Reynolds’ office did not provide certain public records for more than a year after they were requested by journalists, and only provided the documents after lawsuits were filed. The settlement agreements state the governor and her staff are not admitting to violating any laws or policies.”

Sostaric, Katarina. Reynolds Settles Three Lawsuits Accusing Her of Violating Iowa’s Public Records Law. Iowa Public Radio, 21 June 2023, https://www.iowapublicradio.org/state-government-news/2023-06-21/reynolds-settles-three-lawsuits-accusing-her-of-violating-iowas-public-records-law. Accessed 22 June 2025.

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VI. VICTIM IMPACT STATEMENT

This Victim Impact Statement is not being submitted as a formality, but as a necessity—because the consequences of Iowa Public Information Board Executive Director Erika Eckley’s conduct extend far beyond policy violations or administrative negligence. Her alleged failure to carry out the duties of her office, her prejudice and discrimination, her disregard of lawful requests pursuant to Iowa Code Chapter 22, her disregard of complaints submitted pursuant to Iowa Code § 23.7, and her proposed quid pro quo scheme have had direct and devastating effects on my life, my mental health, and my pursuit of justice.

I am a veteran with service-connected disabilities, including Severe Depression, Generalized Anxiety, and Obsessive Compulsive Disorder (OCD).  I have also been diagnosed with Post-Traumatic Stress Disorder (PTSD) and Military Sexual Trauma, which are pending service connection. My record requests and complaints were not arbitrary—they were acts of survival, of seeking redress in a system that has too often refused to hear me. When Iowa Public Information Board Executive Director Eckley failed to initiate a formal investigation under Iowa Code § 23.7, when she obstructed the complaint process by pushing an informal resolution that would have required me to rescind prior public records requests, she did more than undermine transparency—she damaged the integrity of my rights and liberties protected by the Constitution of the State of Iowa and the Iowa Code.

Her actions communicated that a survivor’s rights can be bartered for administrative convenience. That my pain can be negotiated behind closed doors. That my documented efforts to expose misconduct are disposable if they create too much discomfort for those in power.

The emotional toll of this experience has been immense. I have spent countless hours drafting records requests, compiling evidence, and building cases—not to attack, but to hold public officials accountable for alleged violations that affect real lives. When those efforts are met with condescension, delay, or bad-faith negotiation, it sends a message that truth is not important unless it is politically convenient.

This complaint is not just about records. It is about eroding trust in institutions designed to protect government transparency and civil rights. It is about the psychological fatigue that comes from being treated not as a citizen with rights, but as an annoyance to be silenced.

I did not choose this war—but I will not retreat from it. I have lost sleep, dignity, and emotional stability in this fight. And I know I am not alone.

This Victim Impact Statement is for every citizen who has been ignored, gaslit, or pressured into silence by those who swore to uphold the law. I submit it not out of weakness, but out of sacred resolve and duty to protect and defend the rights of those who were unable to speak for themselves.

Let this stand as part of the permanent record: If it be God’s will, I will be victorious in my pursuit of exposing evidence of the unethical conduct and corruption within the State of Iowa that led to the destruction of my family and my life to protect the lives of others.

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VII. CONCLUSION

In conclusion, the conduct of Iowa Public Information Board Executive Director Erika Eckley presents a compelling case of professional misconduct under the Iowa Rules of Professional Conduct. The Board should give this matter full consideration, as it implicates the integrity of the Iowa Court, the professional standards of its licensed legal community, and the public’s right to due process when faced with communicated criminal allegations (See Attachments 4, 8, and 9).

The Iowa Supreme Court has communicated regarding Iowa Code Chapter 22 “The purpose of the statute is to open the doors of government to public scrutiny [and] to prevent government from secreting its decision-making activities from the public, on whose behalf it is its duty to act.” ’ ”Diercks, 806 N.W.2d at 652 (quoting Rathmann v. Bd. of Dirs., 580 N.W.2d 773, 777 (Iowa 1998)). “ ‘Accordingly, there is a presumption of openness and disclosure under this chapter.’ ” Id. (quoting Gabrilson v. Flynn, 554 N.W.2d 267, 271 (Iowa 1996)).  The historical evidence supports that Iowa Public Information Board Executive Director Erika Eckley’s actions are not only in violation of the Iowa Code and the Iowa Rules of Professional Conduct, but they are in complete contrast to the spirit of government transparency.

Moreover, Iowa Public Information Board Executive Director Erika Eckley’s failure to uphold ethical transparency as required by Iowa Code Chapter 22 and 23 reflects not only upon herself and the office she represents, but also upon the Iowa Court’s standards in granting licensure to practice law in this state. The public nature of this misconduct, if left unaddressed, threatens to erode public trust and confidence in the Iowa Judicial Branch and its ability to self-regulate.

The gravity of this matter demands more than dismissal—it requires discipline, reform, and the restoration of trust in the institutions charged with protecting our liberties.

The Form of the Iowa Judicial Branch Licensed Gaslit Reality Distortion Field

A form of unethical rhetoric practiced or enabled by licensed attorneys of the Iowa Judicial Branch, characterized by misrepresentation, intentional ambiguity, and strategic omissions (See Iowa Rules of the Court §§ 32:4.1(a), 32:8.4(c))—with the malicious or willfully negligent intent of distorting the recipient’s perception and understanding of reality.

Simultaneously, it functions to damage, obstruct, or delay (See Iowa Rules of the Court § 32:4.4(a)) the individual’s access to rights, liberties, and lawful remedies.

At the same time, unethical actors within the Iowa Judicial Branch’s licensed community serve to enable and manifest the state’s corruption, authoritarianism, and tyranny—all under the cloak of bureaucratic procedure.

I certify under penalty of perjury and pursuant to the laws of the state of Iowa that the preceding is true and correct.