We imposed a supervision requirement in some older cases. See, e.g., Iowa Supreme Ct. Bd. of Prof'l Ethics & Conduct v. Scheetz, 549 N.W.2d 828, 833 (Iowa 1996) (acknowledging Scheetz had voluntarily ceased private practice, but stating if he ever returned he would be required to align himself with an experienced mentor before undertaking probate or estate matters); Comm. on Prof'l Ethics & Conduct v. Conzett, 476 N.W.2d 43, 46 (Iowa 1991) (prohibiting an attorney from accepting certain types of cases after reinstatement “unless he ... associates with a lawyer experienced in that type of practice”). However, we have declined to impose this condition since 2007, and we continue to follow that path today.
Like illness, voluntary remedial efforts to limit a respondent's practice of law to areas of competence do not excuse misconduct. Nevertheless, we consider such remedial efforts as a mitigating circumstance. Iowa Supreme Ct. Bd. of Prof'l Ethics Conduct v. Scheetz, 549 N.W.2d 828, 833 (Iowa 1996) (imposing discipline notwithstanding respondent's voluntary remedial efforts to limit practice to areas of competence, but considering such efforts in deciding to impose discipline of public reprimand). G. Discipline. After considering the number and nature of Lickiss's ethical infractions as well as the aggravating and mitigating factors present in this case, we agree with the commission that a three-month suspension is appropriate.
Generally, discipline imposed in cases based on client neglect coupled with failure to respond range from reprimand to suspension. See Iowa Supreme Ct. Bd. of Prof'l Ethics Conduct v. Scheetz, 549 N.W.2d 828, 832 (Iowa 1996) (summarizing cases imposing sanctions ranging from public reprimand to six-month suspension). Yet, the seriousness of this case is compounded by the violation of the order we imposed to prevent the very neglect and incompetence documented in this case.
Gottschalk has appealed the matters before us pursuant to Iowa Supreme Court Rule 118.11. Our review is therefore de novo. Iowa Sup. Ct. R. 118.11. We give respectful consideration to commission recommendations, but we ultimately decide what discipline is appropriate under the unique facts of each case. Iowa Supreme Ct. Bd. of Professional Ethics Conduct v. Scheetz, 549 N.W.2d 828, 832 (Iowa 1996). In each case, we are guided by the following standards in determining whether discipline is warranted: "the nature of the alleged violation, the need for deterrence, protection of the public, maintenance of the reputation of the bar as a whole and the respondent's fitness to continue in the practice of law."