Jane Doe, by John Doe and Mary Doe, Her Father and Mother and Next Friends, and John Doe and Mary Doe, Individually v. Perry Community School District, Arthur Pixler, and Russell Gronewold

Summary

The Supreme Court of Iowa held that a law firm must be disqualified from representing a school district and principal when an attorney who previously represented the plaintiffs in the same litigation joined the firm. The court concluded that the representations were substantially related and that screening procedures, or a Chinese Wall, could not overcome the resulting imputed disqualification and strong appearance of impropriety. The court reversed and remanded.

Holdings

1. When a former client establishes a substantial relationship between the former representation and the current adverse representation, the attorney is presumed disqualified, and the former attorney's knowledge is imputed to the attorney's new law firm.
2. A Chinese Wall cannot avoid imputed disqualification when the former and current representations are substantially related and the attorney had substantial involvement in the former representation.
3. The district court abused its discretion by denying the Does' motion to disqualify the Bradshaw firm.

Questions Presented

1. Whether a law firm must be disqualified when an attorney who substantially represented the plaintiffs in a lawsuit joins the firm representing defendants in that same lawsuit.
2. Whether a Chinese Wall or other screening mechanism can prevent imputed disqualification under these circumstances.

Disposition

reversed_and_remanded