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 Chapters 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 Attorney General Brenna Bird is the Attorney General for the State of Iowa and Iowa’s chief legal officer.

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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;” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request (See Attachment 4).
2. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachment 5).
3. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence supporting Iowa Governor Kim Reynolds’ office and Jasper County, IA’s disregard of a public records request submitted during 2024 pursuant to Iowa Code § 22.4(2) (See Attachment 6).
4. 32:8.4(d) — “engage in conduct that is prejudicial to the administration of justice;” —  Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachment 8).
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;” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachment 5).
6. 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;”  —  Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence supporting Iowa Governor Kim Reynolds’ office and Jasper County, IA’s disregard of a public records request submitted during 2024 pursuant to Iowa Code § 22.4(2) (See Attachment 6).
7. 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;” —  Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachment 8).
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.” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request (See Attachment 4).
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.” —  Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachment 5).
10. 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.” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence supporting Iowa Governor Kim Reynolds’ office and Jasper County, IA’s disregard of a public records request submitted during 2024 pursuant to Iowa Code § 22.4(2) (See Attachment 6).
11. 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.” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded a public records request related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachment 8).
12. 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.” — Under the leadership of Attorney General Brenna Bird, the evidence supports that the Iowa Attorney General’s Office disregarded several public records requests related to evidence of the State of Iowa’s inter-agency acts of service-connected mental health disability discrimination (See Attachments 4, 5, 6, 7, and 8).
13. 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 Attorney General Brenna Bird has produced evidence supporting twelve 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 following timeline of evidence supports the conclusion that Attorney General Brenna Bird violated sections of the Iowa Rules of Professional Conduct outlined in Section II of this complaint.

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. 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 1, Memorandum — Iowa Public Information Board — Revised Dismissal — 09 NOV 2022).
2. 11 AUG 2023 — Kristi Harshbarger of the Iowa State Association of Counties communicated to the Iowa Attorney General’s office, “Good afternoon:  I talked to Erika Eckley with IPIB this afternoon. She received 35 complaints from Michael Merritt last night and so she is reaching out to us, the League, and IASB, as she would like to discuss this issue with her board next Thursday the 17th and is encouraging local governments that have concerns/ideas on how to handle Mr. Merritt’s requests to come speak at the public comment portion at the beginning of the meeting (meeting is at 1:00).  I think she would like to try to get some guidance for local governments and is trying to strike a balance between Chapter 22 and the needs of local governments (resources, IT security, etc). I know both ICIT and ICAA have had some informal conversations among their members about these requests — if either of you are aware of counties that might like to comment at this meeting, could you please contact them or let me know who to contact?  Thank you!  Kristi” (See Electronic Mail — Iowa State Association of Counties — Kristi Harshbarger — 11 AUG 2023).
3. 14 AUG 2023 — Cindy Glick of the Iowa Attorney General’s Office forwarded an email from Kristi Harshbarger to a Legislative Committee regarding an intercounty teleconference regarding public records requests submitted by the Complainant, “Hi—Here is the call-in info—Dial-in number:  877-304-9269 Conference Code: 664760#  Thanks! Kristi” (See Electronic Mail — Iowa Attorney General’s Office — Cindy Glick — 14 AUG 2023).
4. 22 JAN 2025 — Public records requests submitted pursuant to Iowa Code § 22.4(2) related to the Iowa Attorney General’s Facebook Page Block List (See Electronic Mail — Michael J Merritt — 22 JAN 2025).
5. 31 JAN 2025 — Public records request submitted pursuant to Iowa Code § 22.4(2) requesting evidence of the Iowa Attorney General’s involvement in alleged discriminatory acts by IPIB Executive Director Erika Eckley’s alleged statewide discrimination against service-connected mental health-based disabilities (See Electronic Mail — Michael J Merritt — 31 JAN 2025; see also ISCADB Complaint — Erika Eckley — 25 JUN 2025).
6. 05 JUN 2025 —  Public records request submitted pursuant to Iowa Code § 22.4(2) requesting evidence of a statewide transmitted public records request that evidence indicates Iowa Governor Kim Reynolds and Jasper County, IA, disregarded during 2024 (See Electronic Mail — Michael J Merritt — 05 JUN 2025).
7. 10 JUN 2025 — Iowa Office of Civil Rights issued a Right to Sue memorandum for Michael J. Merritt v. Iowa Public Information Board (See MM RTS).
8. 12 JUN 2025 — Public records request sent to Daniel Barnes — Deputy Attorney General, Jeffrey Peterzalek — Deputy Attorney General, Edward Bull— Deputy Attorney General, Susan Krisko — Deputy Attorney General, Eric Wessan — Deputy Attorney General, Leif Olson — Deputy Attorney General, and Dan Breitbarth — Assistant Attorney General 3/Former Board, Commission, Council pursuant to Iowa Code § 22.4(2) requesting evidence of the Iowa Attorney General’s involvement in alleged discriminatory acts by IPIB Executive Director Erika Eckley’s alleged statewide discrimination against service-connected mental health-based disabilities (See Electronic Mail — Michael J Merritt — 12 JUN 2025).
9. 13 JUN 2025 — Iowa Attorney General’s response to Attachment 8 (See Electronic Mail — Iowa Attorney General — 13 JUN 2025).
10. 16 JUN 2025 — Complainant’s response to Attachment 9 (See Electronic Mail — Michael J Merritt — 16 JUN 2025).
11. 06 JUL 2025 — Evidence supporting that Facebook Page “Office of the Attorney General of Iowa (Attorney General Brenna Bird)” (https://www.facebook.com/AGIowa/) is a Facebook Page belonging to the State of Iowa (See Screenshot — facebook-com-agiowa — 6-7-2025_15114).
12. 06 JUL 2025 — Evidence supporting the official social media profiles for the Office of the Attorney General’s Office of the State of Iowa (See Screenshot — iowaattorneygeneral-gov — 6-7-2025_1508).  

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IV. ATTACHMENTS

1. Memorandum — Iowa Public Information Board — Revised Dismissal — 09 NOV 2022
2. Electronic Mail — Iowa State Association of Counties — Kristi Harshbarger — 11 AUG 2023
3. Electronic Mail — Iowa Attorney General’s Office — Cindy Glick — 14 AUG 2023
4. Electronic Mail — Michael J Merritt — 22 JAN 2025
5. Electronic Mail — Michael J Merritt — 31 JAN 2025
6. Electronic Mail — Michael J Merritt — 05 JUN 2025
7. MM RTS — 10 JUN 2025
8. Electronic Mail — Michael J Merritt — 12 JUN 2025
9. Electronic Mail — Iowa Attorney General — 13 JUN 2025
10. Electronic Mail — Michael J Merritt — 16 JUN 2025
11. Screenshot — facebook-com-agiowa — 6-7-2025_15114
12. Screenshot — iowaattorneygeneral-gov — 6-7-2025_1508

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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 hypothetical—they are grounded in public communications, official correspondence, and a clearly documented timeline. Attorney General Brenna Bird’s failure to release lawful public records pursuant to Iowa Code Chapter 22, combined with the evidence supporting the Attorney General’s Office’s role in inter-agency acts of disability-based discrimination, contributed to procedural obstruction, emotional harm, denial of rights, and violations of statutory protections under Iowa Code Chapters 22 and 216.

Taken together, this conduct reflects not a singular lapse in judgment, but a pattern of obstruction and disregard for legal transparency. Such behavior—when committed by the Iowa Attorney General’s Office—endangers public trust in the State of Iowa’s commitment to law enforcement integrity and open government. It also violates this agency’s leadership’s ethical obligations under the Iowa Rules of Professional Conduct.

The actions and omissions by the Iowa Attorney General’s Office—particularly in the correspondence from Cindy Glick (Attachment 3)—constitute a failure to uphold the ethical and legal responsibilities outlined in Chapter 32. Specifically, the refusal to meaningfully acknowledge or investigate credible evidence of discriminatory behavior by Erika Eckley, Executive Director of the Iowa Public Information Board, raises serious concerns under Rules 32:8.3(a), 32:8.4(a), and 32:8.4(g).

The Attorney General’s Office holds a heightened duty—not only to prosecute crimes and defend the state—but to ensure its attorneys maintain the standards of justice and professional ethics they are sworn to uphold. The failure to act upon well-documented evidence of discriminatory rhetoric contributes to a broader pattern of legal minimization, reputational protectionism, and institutional evasion.

This is not a matter of differing legal interpretation. It is a matter of civil rights accountability, professional responsibility, and the foundational promise of equal protection under the law.

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VI. CONCLUSION

In conclusion, the conduct of Attorney General Brenna Bird presents a compelling case of professional misconduct under the Iowa Rules of Professional Conduct. The Board should give this matter full consideration. It implicates the integrity of the Iowa Court, the professional standards of its licensed legal community, and the Iowa Court’s commitment to protecting the public’s right to basic civil and constitutional rights protections.

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 Attorney General Brenna Bird’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, Attorney General Brenna Bird’s failure to uphold ethical transparency as required by Iowa Code Chapter 22 reflects not only upon themselves and the office they represent, 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 not only in the Iowa Judicial Branch’s ability to self-regulate, but also the Iowa Attorney General’s commitment to proper law enforcement.

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.