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, Molly Widen is the Chief of Staff for the Office of the Treasurer of State.

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II.  CAUSE OF ACTION

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;” — Evidence supports that Office of the Treasurer of State Chief of Staff Molly Widen—failed to release requested social media block lists (See Iowa Public Information Board Case No. 22FC:0091).  Evidence indicates these block lists are the property of the State of Iowa pursuant to § 22 of Article IV of The Constitution of the State of Iowa and are therefore subject to public access under Iowa Code Chapter 22 (See Attachment 4).
2. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — Evidence supports that Office of the Treasurer of State Chief of Staff Molly Widen—failed to provide requested contact information for the servicing of court documents, thereby burdening and delaying a third party’s exercise of legal rights (See Attachment 5).
3. 32:4.1(a) — “make a false statement of material fact or law to a third person; or” Evidence supports that Office of the Treasurer of State Chief of Staff Molly Widen—knowingly misrepresented the availability of public records, specifically social media block lists, despite publicly available evidence on the Iowa State Treasurer’s official website showing active social media profiles that belong to the State of Iowa pursuant to § 22 of Article IV of the Constitution of the State of Iowa. Molly Widen stated, “There are no records responsive to your request. Therefore, we consider this matter closed.” This response stands in direct conflict with observable state-operated accounts and raises serious concerns regarding the agency’s candor and commitment to lawful transparency under Iowa Code Chapter 22 (See Attachment 4).
4. 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.” — Evidence supports that Office of the Treasurer of State Chief of Staff Molly Widen—knowingly misrepresented the availability of public records, specifically social media block lists, despite publicly available evidence on the Iowa State Treasurer’s official website showing active social media profiles that belong to the State of Iowa pursuant to § 22 of Article IV of The Constitution of the State of Iowa. Molly Widen stated, “There are no records responsive to your request. Therefore, we consider this matter closed.” This response stands in direct conflict with observable state-operated accounts and raises serious concerns regarding the agency’s candor and commitment to lawful transparency under Iowa Code Chapter 22 (See Attachment 4).
5. 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.” — Evidence supports that Office of the Treasurer of State Chief of Staff Molly Widen—failed to provide requested contact information for the servicing of court documents, thereby burdening and delaying a third party’s exercise of legal rights (See Attachment 5).
6. 32:8.4(c) — “engage in conduct involving dishonesty, fraud, deceit, or misrepresentation;”  — Evidence supports that Office of the Treasurer of State Chief of Staff Molly Widen—knowingly misrepresented the availability of public records, specifically social media block lists, despite publicly available evidence on the Iowa State Treasurer’s official website showing active social media profiles that belong to the State of Iowa pursuant to § 22 of Article IV of The Constitution of the State of Iowa. Molly Widen stated, “There are no records responsive to your request. Therefore, we consider this matter closed.” This response stands in direct conflict with observable state-operated accounts and raises serious concerns regarding the agency’s candor and commitment to lawful transparency under Iowa Code Chapter 22 (See Attachment 4).
7. 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 Office of the Treasurer of State Chief of Staff Molly Widen has engaged in conduct supporting six distinct violations of the Iowa Rules of Professional Conduct as supported by the testimony and evidence within this complaint.

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 submitted supports that Molly Widen failed to properly respond to or release requested public records and provide the proper address for the service of court documents.

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. 11 OCT 2022 — Former Iowa Public Information Board Executive Director Margaret E. Johnson communicated in her initial dismissal of IPIB case 22FC:0091, “The Jasper County attorney contacted the IPIB on September 16, 2022, and filed a response on September 22, 2022. In response to the complaint, the County attorney stated that the County “has no such list. It does not exist anywhere. There is no ‘public record’ of such a list kept anywhere in Jasper County, including in its computer systems. Because such a list does not exist, it is impossible to comply with Mr. Merritt’s request.”  Public records are defined in Iowa Code section 22.1(3)(a) as records “stored or preserved in any medium, or of belonging to… any county….” If the government body does not store or preserve a specific record, then there is no record to be released to a record requester.  Iowa Code section 23.8 requires that a complaint be within the IPIB’s jurisdiction, appear legally sufficient, and could have merit before the IPIB accepts a complaint. This complaint does not meet the necessary requirements for acceptance.”  At the same time, the evidence indicates that former Iowa Public Information Board Executive Director Margaret E. Johnson’s original dismissal is legally insufficient because it completely disregards the “belonging” aspect of Iowa Code Section 22.1(3)(a).  Johnson’s interpretation of Iowa Code Section 22.1(3)(a) also misrepresents the very text the Executive Director was referencing while possibly assisting Jasper County, IA, with withholding their social media block lists during the 2022 election year.  Given available public domain name system (DNS) evidence showing the vast majority of State of Iowa government bodies contractually store and preserve their public records via commercial assets (i.e., Microsoft, Google, or Facebook) if Johnson’s interpretation were applied statewide, it would exempt nearly all electronic records hosted on Microsoft, Google, and Facebook’s infrastructure from Chapter 22—effectively rendering Iowa’s transparency statute obsolete in the digital age. (See Attachment 1, Memorandum — Iowa Public Information Board — Dismissal — 11 OCT 2022).
2. 09 NOV 2022 — Upon the Iowa Public Information Board tabling former Iowa Public Information Board Executive Director Johnson’s 11 OCT 2022 dismissal, it was determined that Facebook block lists “belonging to… any county….” are public records in the State of Iowa. (See Attachment 2, Memorandum — Iowa Public Information Board — Revised Dismissal — 09 NOV 2022).
3. 22 JAN 2025 — The Complainant communicated to the State of Iowa Office of the Treasurer, “I am respectfully requesting the Facebook Page Block List for the following social media asset documented as belonging to the State of Iowa in accordance with Iowa Code Chapter 22 and IPIB case 22FC:0091.  https://www.facebook.com/IowaTreasurer” (See Attachment 3, Electronic Mail — Michael J Merritt — 22 JAN 2025 — 1441).
4. 23 JAN 2025 — Molly Widen communicated, “Good Morning Mr. Merritt, There are no records responsive to your request. Therefore, we consider this matter closed.” (See Attachment 4, Electronic Mail — Molly Widen — 23 JAN 2025 — 1109).
5. 23 JAN 2025 — The Complainant communicated to Molly Widen, “Office of the Iowa Treasurer:  Thank you for your response. Whether the previously mentioned page actively blocks users or not, there is a block list responsive to this request.  I am respectfully requesting the address that the Office of the Iowa Treasurer desires the proper service of court documents.”  (See Attachment 5, Electronic Mail — Michael J Merritt — 23 JAN 2025 — 1317).
6. 13 JUN 2025 — Evidence supporting the official social media profiles for the Office of The Treasurer of the State of Iowa. (See Attachment 6, Screenshot — iowatreasurer-gov — 13-6-2025_224517).
7. 14 JUN 2025 — Evidence supporting that Facebook Page “State Treasurer of Iowa” (https://www.facebook.com/IowaTreasurer) is a “Government Official” Facebook Page belonging to the State of Iowa as the Facebook page intro states, “The Treasurer acts as the State’s banker and serves Iowans in many ways.” (See Attachment 7, Screenshot — facebook-com-iowatreasurer — 14-6-2025_22268).

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IV. ATTACHMENTS

1. Memorandum — Iowa Public Information Board — Dismissal — 11 OCT 2022
2. Memorandum — Iowa Public Information Board — Revised Dismissal — 09 NOV 2022
3. Electronic Mail — Michael J Merritt — 22 JAN 2025 — 1441
4. Electronic Mail — Molly Widen — 23 JAN 2025 — 1109
5. Electronic Mail — Michael J Merritt — 23 JAN 2025 — 1317
6. Screenshot — iowatreasurer-gov — 13-6-2025_224517
7. Screenshot — facebook-com-iowatreasurer — 14-6-2025_22268

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V. ANALYSIS

The historical evidence supports that Molly Widen received a request for records that IPIB case 22FC:0091 articulate are public records.  At the same time, the historical evidence supports that Widen failed to release the requested public records or provide the proper address for the service of court documents to lawfully combat this alleged unethical conduct before the Iowa Court.

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VI. CONCLUSION

The evidence presented in this complaint does not merely describe violations of the Iowa Rules of Professional Conduct—it exposes a broader failure of ethical leadership and systemic accountability at the highest levels of government. Chief of Staff for the Office of the Treasurer of State Molly Widen, deprived the public of lawful access to records and obstructed access to constitutional remedies.  This complaint respectfully requests that the Iowa Supreme Court Attorney Disciplinary Board not merely examine the cited violations, but confront a broader culture of impunity.

This matter implicates not only the operational integrity of the office of State of Iowa Treasurer Roby Smith, but the ethical standards by which this Court vests public trust in its licensees.  The conduct of Chief of Staff for the Office of the Treasurer of State Molly Widen constitutes a serious breach of professional responsibility, meriting immediate investigation by the Iowa Supreme Court Attorney Disciplinary Board. This matter implicates not only the credibility of a state agency but also the standards of integrity governing the Iowa Bar and the Court’s licensing authority.

Moreover, 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)). 

This is not merely a guiding principle—it is binding law. Molly Widen’s conduct, as detailed in this declaration, cannot be reconciled with that mandate. The record supports a finding that her actions violate both Iowa statutory law and the Iowa Rules of Professional Conduct, and directly contradict Iowa’s constitutional commitments to transparency and civil rights protection.

Molly Widen’s failure to uphold her duties under Iowa Code Chapters 22 reflects not only her personal conduct, but also the institutional posture of the Office of the Treasurer of State. If left unaddressed, this matter would cast serious doubt on the Court’s commitment to holding its licensees to meaningful standards of legal and ethical accountability.

Accordingly, the undersigned respectfully requests that the Iowa Supreme Court Attorney Disciplinary Board initiate a formal review of Molly Widen’s conduct. This is not merely a request for disciplinary review—it is an affirmation that legal licensure in Iowa demands fidelity to law, transparency, and justice.

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.

Fiat justitia ruat caelum

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