MEMORANDUM OF LAW IN SUPPORT OF PROPOSED AMENDMENTS TO SECTIONS 932.61, 932.66 and 38.23 FLORIDA STATUTES


      I.  The Florida Bar and the Supreme Court of Florida Create an Appearance of 
Impropriety in Investigating, Prosecuting and Adjudicating Unlicensed Practice of Law 
Allegedly Committed by Non- Members of The Florida Bar.
      The Court has relied on its interpretation of Article V, Section 15 of the Florida 
Constitution for its jurisdiction over and authority to punish those accused of the 
unlicensed practice of law.  State ex rel. Florida Bar v. Sperry, 140 So.2d 587 (Fla.
1962), judgment vacated on other grounds 373 U.S. 379, 83 S.Ct. 1322, 10 L.Ed.2d 
428 (1963); see also, The Florida Bar v. Flowers, 320 So.2d 809 (Fla. 1975).  Article 
V, Section 15 provides:
           The supreme court shall have exclusive jurisdiction to 
           regulate the admission of persons to the practice of law 
           and the discipline of persons admitted.
      The Court's interpretation of this provision should be examined.  A plain 
reading of the constitutional provision does not support the interpretation which the 
Supreme Court of Florida relies on for jurisdiction in unlicensed practice of law cases
involving persons not members of The Florida Bar.
      The Court has chosen to exercise jurisdiction over the unlicensed practice of 
law under the rationales that the public needs protection from those who would hold 
themselves out as attorneys.  See The Florida Bar v. Moses, 380 So.2d 412 (Fla.
1980).  This need to protect the public can be satisfied alternatively by the normal
method of prosecuting criminal behavior in the state through proceedings instituted 
by the State Attorney's Office.  By enacting Section 454.23, Florida Statutes, the
legislature has provided the means by which the State Attorney's Office can charge 
an individual with "unlicensed practice of law," a misdemeanor of the first degree.  
However, should the Court adhere to the interpretation of the constitutional provision
conferring exclusive jurisdiction to regulate and discipline the unlicensed practice of 
law in the supreme court, then the legislature was without authority to enact the 
misdemeanor offense proscribing this conduct.  Assuming that Section 454.23 F.S. 
is valid, the State Attorney's Office has the means to protect the public from those 
who engage in any other type of criminal behavior.  Therefore, it is not a public 
necessity for the Court to act as the court of first impression for unlicensed practice 
of law cases.  
      It would be better public policy to leave the prosecution of unlicensed practice 
of law to the various State Attorneys where the object of the prosecution is to protect 
the public from harm.  A problem of perception arises with the Court prosecuting 
unlicensed practice of law violators by civil injunction or contempt.  The problem is 
analogous to the problem, discussed in Young v. United States Ex rel. Vuitton Et Fils 
S.A., 481 U.S. 787, 107 S.Ct. 2124, 95 L.Ed.2d 740 (1987), that arises when one 
party to a civil action is allowed to prosecute the other party for criminal contempt. 
Here, the Court seems to be an interested party to the civil action as much as is The 
Florida Bar.  The Court has an interest in preserving its constitutional jurisdiction over 
those licensed to practice law.  The unlicensed practice of law is a direct affront to 
the Court's exclusive jurisdiction--the Court is in a sense "the victim" when a person 
not licensed to practice law does so.  The punishment of violators by the Court for 
a crime that so directly affects the Court's exclusive jurisdiction creates an 
appearance of impropriety in the same way that appointment of an interested
prosecutor 'creates an appearance of impropriety that diminishes faith in the fairness 
of the criminal justice system in general."  Young, 481 U.S. at 811, 107 S.Ct. at 
2139.
      Indirect criminal contempt proceedings (the next level of escalation after the 
civil injunction) "are not intended to punish conduct proscribed as harmful by the 
general criminal laws.  Rather, they are designed to serve the limited purpose of
vindicating the authority of the Court.  In punishing contempt, the Judiciary is 
sanctioning conduct that violates specific duties imposed by the court itself, arising 
directly from the parties' participation in judicial proceedings."  Young, supra at 2134.  
As stated in the above quoted passage from Young, contempt should not be used to 
remedy conduct proscribed as harmful by the general criminal laws.  Rather, such 
power of the court should be used to serve the limited purpose of vindicating the 
authority of the court.  In his dissent in Walker v. Bentley, 660 So.2d 313 (Fla. 2d
DCA 1995), Judge Altenbernd makes a case for the avoidance of the use of indirect 
criminal contempt when the legislature has provided an alternative criminal remedy:
           [T]he judicial concept of indirect criminal contempt overlaps 
           with legislative and executive functions.  Indirect criminal
           contempt allows a judge considerable flexibility in deciding 
           the elements of an offense against a victim for acts 
           occurring outside the presence of the judge.  The judge 
           also determines who should be prosecuted, and then tries, 
           convicts, and punishes.  I do not suggest that this 
           combination of legislative, executive, and judicial functions 
           is prohibited by article II, section 3, of the Florida 
           Constitution.  See Johnson, 345 So.2d 1069.  Never-
           the less, if separation of powers is intended to discourage 
           a concentration of power in one branch, this political 
           doctrine should discourage the avoidable use of indirect 
           criminal contempt when the legislature provides alternative 
           criminal and civil remedies.  See Edward M. Dangel,
           Contempt, Sec. 42A (1939).

      While the Florida State Bar Association (as the lawyers' trade association was 
named at that time) actively sought to motivate its brethren into action against 
activities of non-lawyers, it also sought to invoke the Court's rule-making powers to 
provide a formalized means of enforcing the prohibition on UPL.  In Petition of Florida 
State Bar Ass'n, 186 So. 280 (Fla. 1938), the Bar petitioned for adoption of a rule 
which would have provided a limited form of registration of "active" lawyers, i.e., 
those officially registered and licensed to practice.  The Court construed that portion 
of the petition as an effort to prevent the unauthorized practice of law. Id., at 284.  
The Court declined to adopt the proposed rule, noting that under the provisions of
Florida's Constitution, an ample remedy already existed to prevent such unauthorized 
practice.  Id., at 289-90.  The Court further noted that it did not have a concrete case 
before it, and thus, had insufficient facts to allow it to properly devise such a rule. 
Id., citing, Rhode Island Bar Association v. Automobile Service Association, 255 R.I. 
122, 179 Atl. 139 (1935).
      In Rhode Island, the Supreme Court of Rhode Island found that while it had the 
power to punish UPL as contempt, such a procedure would only be invoked where 
there is an evident need for summary action in order to protect the public.  Id.  As 
one commentator on the subject noted:
           Criminal contempt is a summary proceeding and,
           as such, dangerous.  Where a statute makes the
           unauthorized practice of law a crime ...
           summary action is merely an alternative
           method, the results of which might be unjust
           when compared with the ordinary protection
           afforded in the criminal process.  (Emphasis
           added)

Attorney and Client - Unauthorized Practice, 6 Miami L.Q. 607, 609 (1952).
      The principle that such power should be used sparingly must be considered for 
another reason.  When the Court exercises this power, whether by civil injunction or 
order of indirect criminal contempt, the defendant is deprived of his/her appellate 
rights.  Therefore, such power should not be exercised except in extreme or dire 
cases and to do otherwise constitutes abuse of power which also usurps the authority 
of the Executive and Legislative Branches.
      Given the procedural difficulties with the Supreme Court of Florida holding trial-
like proceedings, and given the perception that the Court maintains an interest in the 
outcome of these cases, the Court should abstain from its law enforcement activities and
disband its badge-carrying UPL police.
      One must realize that members of The Florida Bar willfully accepted the Court's 
jurisdiction when they were admitted to practice--but non-members obviously have not done
so.  It is unconscionable for the Supreme Court of Florida to allow the use of 
unsubstantiated allegations of unlicensed practice of law prosecuted by The Florida Bar 
as its fabricated conduit for jurisdiction over the alleged actions of a non-member of The
Florida Bar, which ultimately circumvents the rights of the accused including the right 
to a jury trial and the right to counsel.  The Court's scheme denies due process to the 
non-lawyer accused of UPL.
      The United States Supreme Court discussed the historic progression of due 
process in Griffin v. People of the State of Illinois, (1956), 351 U.S. 12, 16, 76 S.Ct. 
585, 590 wherein was stated:
           Providing equal justice for poor and rich,
           weak and powerful alike is an age-old problem. 
           People have never ceased to hope and strive to
           move closer to this goal.  This hope, at least
           in part, brought about in 1215 the royal
           concessions of Magna Charta: "To no one will
           we sell, to no one will we refuse, or delay,
           right of justice."

           Ye shall do no unrighteousness in judgment;
           thou shalt not respect the person of the poor,
           nor honour the person of the might; but in
           righteousness shalt thou judge thy neighbor. 
           Leviticus, c. 19, v. 15.

Persons accused of UPL are denied an impartial tribunal by the composition of any 
committee assembled by The Florida Bar to investigate and adjudicate non-members 
of The Florida Bar.  The U.S. Supreme Court in its opinion in Marshall v. Jerrico, 
(1980), 446 U.S. 238, 242, 64 L.Ed.2d 182, 100 S.Ct. 1610, 1613, stated:
           The due process clause entitles a person to an
           impartial and disinterested tribunal .... 
           This requirement of neutrality in adjudicative
           proceedings safeguards the two central
           concerns of procedural due process, the
           prevention of unjustified or mistaken
           deprivations and the promotion of
           participation in dialogue by affected
           individuals in the decision making process. 
           (citations omitted)  The neutrality
           requirement helps to guarantee that life,
           liberty, or property will not be taken on the
           basis of an erroneous or distorted conception
           of the fact or the law.  (citations omitted)
           ... it preserves both the appearance and
           reality of fairness (citations omitted) ...
           assurance that the arbiter is not predisposed
           to find against him.

Therefore, due to the biased composition of The Florida Bar's Standing Committee on 
UPL and the defective and prejudicial process used by The Florida Bar in selecting the 
members of said committee, non-lawyers are denied an impartial investigative process 
as well as an impartial adjudicative process violating their state and federal 
constitutional rights to due process of law and fundamental fairness.
      The question presented here is whether the Bar's efforts are reasonable given 
the facts presented, and equally, whether the Bar's investigative powers are being 
exercised without prejudice and with sufficient attention given to the protected rights 
of those non-Florida Bar members targeted by the Bar.  The circuit UPL committees 
appear to operate without sufficient public checks and balances or safeguards to 
prevent abuse and to protect the rights of non-lawyer citizens targeted by the Florida 
Bar.  As the Supreme Court of Florida has noted:
           Because of the natural tendency of all
           professions to act in their own self-interest
           ... this Court must closely scrutinize all
           regulations tending to limit competition in
           the delivery of legal services to the public,
           and determine whether or not such regulations
           are truly in the public interest.  (Emphasis
           added).

The Florida Bar v. Brumbaugh, 355 So.2d 1186, 1189 (Fla. 1978)
      In 1980 Barlow Christensen conducted a study of the unauthorized practice of 
law.  The findings of this study were published in the American Bar Foundation's 
Research Journal (spring 1980), which concluded:
           Suppression of the practice of law by non-
           lawyers has been proclaimed to be in the
           public interest, a necessary protection
           against incompetence, divided loyalties, and
           other evils.  But this interest of the public
           is one that has been defined, articulated,
           promulgated, and enforced not by the public
           but by the legal profession.  And nowhere, in
           all of the literature or in any of the court
           decisions, is there evidence of a public voice
           with respect to this supposed public interest. 
           (Emphasis added)

      The question above is answered in the negative sense in all respects as The 
Florida Bar is clearly and freely engaged in oppression relating to its persecution of 
competitors of members of The Florida Bar.
      The U.S. Supreme Court cited in Withrow v. Larkin, 421 U.S. 35, 95 S.Ct. 
1456, 43 L.Ed.2d 712 (1995) at 1436-1464 the following regarding prejudice in the 
adjudicatory process:
           Concededly, a "fair trial in a fair tribunal
           is a basic requirement of due process." In re
           Murchison, 349 U.S. 133, 136, 75 S.Ct. 623,
           625, 99 L.Ed. 942 (1955). This applies to
           administrative agencies which adjudicate as
           well as to courts. Gibson v. Berryhill, 411
           U.S. 564, 579, 93 S.Ct. 1689, 1698, 36 L.Ed.2d
           488 (1973). Not only is a biased decision maker
           constitutionally unacceptable but "our system
           of law has always endeavored to prevent even
           the probability of unfairness." In re
           Murchison, supra, at 136, 75 S.Ct. [623] at
           625, 99 L.Ed. 942; cf. Tumey v. Ohio, 273 U.S.
           510, 532, 47 S.Ct. 437, 444, 71 L.Ed. 749, 50
           A.L.R. 1243 (1927). In pursuit of this end,
           various situations have been identified in
           which experience teaches that the probability
           of actual bias on the part of the judge or
           decision maker is too high to be
           constitutionally tolerable.

      If the Court has any concern for the appearance that it and The Florida Bar 
are jointly involved in a so-called legal process devoid of impartiality and fairness 
which denies the very basics of due process, then the Court must divest itself of all 
involvement in it and run with great haste away from it, after dismissing all cases 
before the Court involving non-members of The Florida Bar accused of the unlicensed 
practice of law.  
      II.  Applying the Rules Regulating The Florida Bar to Non-Member Citizens 
Denies Due Process to Non-Lawyers and is Unconstitutional.
      The Florida Bar holds out its various Unlicensed Practice of Law committees 
(the Standing Committee and numerous circuit committees) to act as grand juries in 
matters of unlicensed practice of law investigations, cloaking their activities in
secrecy and denying the press access to their proceedings.  Committee members are 
far from being disinterested parties in matters before them because they are "hand 
picked" by The Florida Bar.
           "Intentional discrimination in the selection
           of grand jurors is a grave constitutional
           trespass, possible only under color of state
           authority and wholly within the state's power
           to prevent.  Even if the grand jury's
           determination of probable cause to believe
           that a defendant has committed a crime is
           confirmed in hindsight by a conviction on the
           indicted offense, that information does not
           suggest that discrimination did not
           impermissibly infect the framing of the
           indictment and, consequently, the nature or
           existence of proceedings to come."  Vasquez v.
           Hillery, 474 U.S. 254 (1986).

      Non-lawyers are denied a fair and impartial investigative and adjudicative 
process.  The U.S. Supreme Court stated  In the Matters of Leroy Murchison and 
John White, 349 U.S. 133, 75 S.Ct. 623, 99 L.Ed. 942 (1955) (cited in Bryant v. 
State, 1978 Fla. 1DCA 2777, 363 So.2d 1141):
           A fair trial in a fair tribunal is a basic
           requirement of due process.  Fairness of
           course requires an absence of actual bias in
           the trial of cases.  But our system of law has
           always endeavored to prevent even the 
           probability of unfairness.  To this end no man
           can be a judge in his own case and no man is
           permitted to try cases where he has an
           interest in the outcome.  That interest cannot
           be defined with precision.  Circumstances and
           relationships must be considered.  This Court
           has said, however, that 'every procedure which
           would offer a possible temptation to the
           average man as a judge ... not to hold the
           balance nice, clear and true between the State
           and the accused, denies the latter due process
           of law.'  Tumey v. Ohio, 273 U.S. 510, 532, 47
           S.Ct. 437, 71 L.Ed. 749.  Such a stringent
           rule may sometimes bar trial by judges who
           have no actual bias and who would do their
           very best to weigh the scales of justice
           equally between contending parties.  But to
           perform its high function in the best way
           'justice must satisfy the appearance of
           justice.'  Offutt v. United States, 348 U.S.
           11, 14, 75 S.Ct. 11, 99 L.Ed. 11.  (Cited in
           Bryant v. State, 1978 Fla. 1DCA 2777, 363
           So.2d 1141).

      The Florida Bar Standing Committee on Unlicensed Practice of Law is one of 
many instruments used by The Florida Bar and the Florida Supreme Court to deprive 
the profession's perceived enemies, such as non-lawyer legal technicians and 
independent paralegals, their constitutional rights as the profession attempts to 
prevent intrusion into its monopoly.  Even though the so-called "public members" of 
the 37-member Standing Committee have been increased to 18, these 18 public 
members are hand-picked by The Florida Bar insiders using the prospective 
candidates' loyalty to The Florida Bar and the legal profession as their primary
qualifying factor and then are appointed by the Court "on advice of the board of 
governors" and therefore do not truly represent the public interest.
      These non-lawyer committee members are exclusively persons who meet one 
or more of the following criteria:  a member of a regulated profession who can 
empathize with The Florida Bar's battle against competition with legal technicians; 
work in a profession that requires a good working relationship with Florida Bar 
members; a person whose income originates from members of The Florida Bar and/or 
a person whose income is high enough to afford the services of an attorney and 
therefore does not rely on legal technicians to gain access to the courts.  There are no 
legal technicians/independent paralegals on the Florida Bar Standing Committee on 
UPL which determines who will be forced out of business.
      The other 19 members have a far greater conflict of interest in investigating 
non-lawyers and in deciding whether or not they will be prosecuted, in that they are 
(a) members of The Florida Bar who must compete with the very low prices charged 
by legal technicians in or near the geographic locations of their law practices and (b) 
may have requested a position on The Florida Bar's Standing Committee on UPL for 
self-serving purposes, such as to target a nearby legal technician for prosecution.  An 
impartial fact-finding panel it is not.
      In The Florida Bar's own publication, The Florida Bar Journal, it disclosed the 
need for Bar members to be concerned with increased competition by legal 
technicians and paralegals.  In its May 1997 edition on pages 18-21 in an article titled 
"Key Trends in the Legal Profession," Mike J. Garcia, an employee of The Florida Bar, 
stated in his article's introduction, in part, "By identifying the key trends which will 
take place in the legal profession and assessing their impact, we can start to plan how 
to respond to them by generating and playing out scenarios of possible strategies." 
Of the seven key trends Mr. Garcia identifies in his article, one is subtitled "Increase 
of Legal Technicians/paralegals."  At the close of his article Mr. Garcia writes, "The 
21st Century will bring a proliferation of independent legal technicians--it is important 
The Florida Bar and its membership recognize this and plan accordingly."  I insist that 
the Supreme Court of Florida and The Florida Bar, in concert, have already done so.
      III.  The Restrictions Promulgated in Chapter 10 of The Rules Regulating The 
Florida Bar Concerning Which Forms May be Generated by a Non-Lawyer Unlawfully 
Restrict the Public's Right to Access to the Courts Under the State and Federal 
Constitutions.
      The United States Supreme Court has ruled that if prisoners are denied the right 
to legal help in preparing habeas corpus petitions, they must be afforded a reasonable 
alternative (i.e., non-lawyers who know how to help).  Johnson v. Avery, 393 U.S. 
483 (1969).  The implementation of the present-day "Supreme Court Approved 
Forms" addressed in Chapter 10 is a product of the case of The Florida Bar v. 
Rosemary Furman.  Whereas Ms. Furman was assisting poor women in divorce cases 
for a $50.00 fee, but The Florida Bar and its members wanted her stopped.  Limiting 
legal processes which are available to the public by limiting the availability of
 "Supreme Court Approved Forms" and then punishing non-lawyers for using the same 
forms and processes used by lawyers unreasonably restricts access to the court 
system to persons who cannot afford to hire an attorney.  The Court must remember 
who actually paid for that fine leather chair in which they are seated, who pays their 
salary and who paid for the courthouse facilities-- the citizens of this state who out-
number Florida Bar members by approximately 270 to 1!   Restricting access to the 
courts by the Supreme Court of Florida is violative of rights granted by the state and 
federal constitutions and such practice must be halted. 
      Today the poor and middle class face a legal access crisis precisely because 
information about how to approach and use our courts moves sluggishly if at all due 
to the greed of the "officers of the court".  It is dammed up by a class of 
professionals known as lawyers who charge such unaffordably high fees that, in 
Florida, The Florida Bar felt it necessary to establish a Fee Arbitration Program to help 
settle fee disputes between attorneys and their gorged clients.  How many other 
professions can you think of have such a special program complete with its own 
government committee.  In almost all states, lawyers have used their power to enact
statutes restricting to lawyers the right to provide legal information designed to solve 
an individual's legal needs.  And in all but a few states the laws go on to provide that 
a non-lawyer who gives legal advice has committed a crime punishable by 
imprisonment.  In Florida, it is a first degree misdemeanor pursuant to Florida Statute 
454.23, but few cases are tried under this law.  A more insidious process is applied 
in Florida, as described herein.
      Almost no other type of speech has ever been similarly forbidden in advance 
to the public.  The reason is clear. Prohibitions on disseminating information are 
almost always ruled to be unconstitutional violations of the First Amendment, which
forbids any law that abridges the freedom of speech.  This is especially true when it 
comes to speech about how to deal with public bodies such as Congress, state 
legislatures, and administrative agencies.  There is no good reason to treat the courts 
differently than any other organ of government. 
      Courts have allowed only a handful of narrow exceptions to this near-absolute 
rule prohibiting advance restrictions to free speech.  Obscenity, incitement to violence 
and false speech (libel, slander, fraud) are examples of the kinds of speech that the
government may legally abridge.  The government also may restrict commercial 
speech, such as advertising, if the restriction directly serves substantial state interests 
and the restriction is in reasonable proportion to the interests served.
      It is worthy of note that in other areas of American life, including the regulation 
of books claimed to be pornographic, where First Amendment rights were being 
restricted by quasi-official, but essentially private review boards, the U.S. Supreme 
Court has found a constitutional violation.  Bantam Books Inc. v. Sullivan, 372 U.S. 
58 (1963).
      If speech does not fall within these types of exceptions, it is fully protected 
under the First Amendment.  It may be restricted only if the government has a 
compelling interest for doing so and the restriction is as narrowly tailored as possible 
to satisfy the compelling interest.  Eliminating competition to lawyers is not a
compelling interest.
      The U.S. Supreme Court has ruled that legal advice is fully protected speech 
rather than commercial speech, even though the legal advice is given for a fee.  
Board of Trustees, State University of New York v. Fox, 492 U.S. 469 (1989).  That 
means that the government must have a compelling interest in stopping nonlawyers 
from giving legal advice.  It's a tough standard to meet for an honest court.
      Consumer protection is the reason usually advanced by the legal profession to 
justify handing it the exclusive right to give legal advice but it is a ruse.  According 
to this view, poor legal advice can cause such serious harm that a license should be
required of those who provide it.  Numerous studies of this issue, however, have 
shown that this fear is unwarranted.  No study has produced concrete evidence that 
legal advice from nonlawyers causes more harm than that sold it by licensed lawyers.  
Also see Conway-Bogue Realty Investment Co. v. Denver Bar Association, 312 P.2d 
998 (1957).
      When you think about it, denying consumers who can't afford a lawyer the 
right to purchase legal advice and completed forms from more affordable sources is 
a ridiculous way to protect them.  This only protects lawyers from low-cost 
competition.  The argument put forth by lawyers' groups seems to be that it is better 
for most consumers to have no legal advice than for some to receive advice that may 
be inaccurate or incomplete.  Interestingly, this argument is raised by lawyers, almost 
never by consumers, and lawyers persist in making it even though there have been 
very few complaints about existing non-lawyer legal form preparation businesses in 
comparison to the number of complaints lawyers generate from their clients.  It's as 
if accountants and tax lawyers could put H&R Block and other tax preparers out of 
business because they didn't approve of their training or level of advice (but they 
could be next as the legal profession expands into these areas and declare it "the 
unlicensed practice of law").
      Thus there seems to be no compelling reason to deny non-lawyers the right to 
offer the public information about our laws and courts as long as they do not 
misrepresent themselves to the public.  But even if there were a compelling interest, 
the method of regulation- barring everyone but lawyers from giving legal advice--is 
much broader than it needs to be.  For example, the term "legal advice" is never 
clearly defined in the laws that forbid nonlawyers from giving it.  This means that 
when a complaint against a non-lawyer is made, a judge (also a lawyer, of course) 
has no reasonable standard to use when deciding whether or not legal advice was
given.  As a result, unauthorized practice laws make criminals out of anyone who 
utters words that might, even after the fact, be interpreted as legal advice by a court.  
This sort of blanket censorship of all unlicensed legal advice is surely as blatant a
violation of the First Amendment as you'll ever find, as it chills free speech 
undeniably.
      In Wyche v. State, 619 So.2d 231 (1993 Fla. S.Ct. 1092) the Court stated:
                 When lawmakers attempt to restrict or
           burden fundamental and basic rights such as
           these, the laws must not only be directed
           toward a legitimate public purpose, but they
           must be drawn as narrowly as possible. See
           Firestone v. News-Press Publishing Co., 538
           So.2d 457 [14 FLW 54, 1989 Fla.SCt 318] (Fla.
           1989). As the United States Supreme Court has
           noted, "[b]ecause First Amendment freedoms
           need breathing space to survive, government
           may regulate in the area only with narrow
           specificity." NAACP v. Button, 371 U.S. 415,
           433, 83 S.Ct. 328, 9 L.Ed.2d 405 (1963). Put
           another way, statutes cannot be so broad that
           they prohibit constitutionally protected
           conduct as well as unprotected conduct.
           News-Press Publishing Co., 538 So.2d at 459.

                 When legislation is drafted(FN1) so that it
           may be applied to conduct that is protected by
           the First Amendment, it is said to be
           unconstitutionally overbroad. See Southeastern
           Fisheries Ass'n, Inc. v. Department of Natural
           Resources, 453 So.2d 1351 [1984 Fla.SCt 1497],
           1353 (Fla.1984).  This overbreadth
           doctrine permits an individual whose own
           speech or conduct may be prohibited to
           challenge an enactment facially "because it
           also threatens others not before the court -
           those who desire to engage in legally
           protected expression but who may refrain from
           doing so rather than risk prosecution or
           undertake to have the law declared partially
           invalid." Brockett v. Spokane Arcades, Inc.,
           472 U.S. 491, 503, 105 S.Ct. 2794, 86 L.Ed.2d
           394 (1985). The doctrine contemplates the
           pragmatic judicial assumption that an
           overbroad statute will have a chilling effect
           on protected expression. City of Daytona Beach
           v. Del Percio, 476 So.2d 197 [10 FLW 458, 1985
           Fla.SCt 3207], 202 (Fla.1985).

      IV.  The Florida Bar has a Corrupt Motive to Investigate and Prosecute Non-
Lawyers for the Unlicensed Practice of Law.
           Historically, efforts of the legal profession to prevent the unauthorized 
practice of law to perfect a monopoly of legal services have long played a role in 
American jurisprudence.  Throughout the years, the common justification of such 
efforts has been the legitimate interest of the state in protecting the public from the 
unskilled and dishonest(FN2) but this expressed concern for the public interest is not the 
true motivator.  Equally, those efforts have also been coupled with an emotional, if 
not outright, appeal that such is necessary to protect the profession.  As artfully put 
by a former chairman of the State Committee on Unauthorized Practice:
              The unauthorized practice of the law as it
           flourishes today presents a ringing challenge
           to the members of our profession; and if it is
           not stamped out, root and branch, every
           ethical and self-respecting lawyer, sooner or
           later, will have to close his office and
           abandon the hopeless task of making a living
           in the practice.  (Emphasis added)

Yates, Milton.  A Challenge - The Unauthorized Practice of the Law; 9 Fla.L.R. 560 
(1935).
      In his article, Yates sought to re-emphasize the role played by local attorneys 
in assisting the profession to prevent UPL.  This was an important endeavor because, 
at that time, UPL was addressed by petition in chancery at the circuit court level, with
a local attorney as petitioner.  Yates, supra (discussing the impact of a Tampa 
newspaper article critical of the efforts of the attorney organization in Tampa, which 
had sought an injunction to prohibit the practice of law by certain non-lawyers.)
                                Conclusion
      The Florida Bar and the Supreme Court of Florida have a corrupt motive for 
their unlicensed practice of law prosecutions and adjudication of non-lawyer citizens 
not members of The Florida Bar.  Our Judicial Branch has surrendered the power and 
prestige of the State to a powerful professional trade union (The Florida Bar, formerly 
known as the Florida State Bar Association) so it may repress its competitors and 
promote its own business interests which are contrary to the public interest.  See 40 
So.2d 902 (1949) which records the surrender of our Judicial Branch of State
Government to the Florida State Bar Association on June 7, 1949.
      The appearance and suggestion that justice is for sale at 500 South Duval 
Street, Tallahassee, Florida, in matters that challenge the legal profession's monopoly 
is overwhelming and damning.  The current scheme used by the Judiciary to 
prosecute non-lawyers for UPL under a court rule usurps the authority of the other 
co-equal branches and is unconstitutional.  The scheme is implemented with the 
intent to deny due process and fundamental fairness to non-bar-member citizens 
accused of UPL, to allow the Judiciary to manipulate the outcome of the case.  It is 
clear that Florida citizens are being denied honest government services by their
Judicial Branch.(FN3)
      Unlicensed persons alleged to have engaged in UPL are only afforded 
constitutional protections under Florida's UPL statute, 454.23 F.S., not under the 
Bar's Rules.  The overriding state interest in the matter is protected under the UPL 
statute.  
      The state interest in regulation of persons licensed to practice before the 
courts relates to the integrity of the judicial system, and is separate and distinct 
from protection of the public against unlicensed persons, which is satisfied by the 
UPL statute.
      In addition to the absence of provisions in the Rules Regulating The Florida Bar 
for consideration of state and federal constitutional issues on behalf of non-lawyers, 
the persons charged with undertaking the prosecution of non-lawyers, as well as 
those to whom responsibility is delegated for fact-finding, are all individuals with an 
identifiable personal interest in the outcome. No right to jury trial or right to counsel 
is provided.  Additionally, under Rule 4-5.5(b) of the Rules Regulating The Florida Bar, 
the person charged is also denied the right to counsel in UPL cases through the 
intimidation of prospective counsel by this rule.
      While the discipline of "licensed" attorneys may proceed without such funda-
mental constitutional protections as to the right to jury trial because of such licensees' 
consent to regulation as part of the state's grant of the license privilege,  no such
consent, or waiver of rights, has been given by those persons classified as non-
lawyers/non-attorneys under Rule 10-2.1(b) of the Rules Regulating The Florida Bar.
      The legislation the undersigned hereby proposes should resolve most of the 
issues raised herein to the benefit of the non-lawyer citizens of this state.  The 
proposed legislation is attached.

                                        
                                       
                   
                                        Ron Eubanks
                                        Able Legal Document Service
                                        3 Maples St. NW
                                        Fort Walton Beach, FL  32548
                                        (850) 244-2230
                                        Date:  January 20, 1999

 


Footnote 1 - In the instant case the offending item is not legislation but a court rule having the effect of legislation promulgated by self serving Florida Bar members and the Supreme Court of Florida absent significent input from the public or their elected representatives-- Chapter 10 of the Rules Regulating The Florida Bar.

Footnote 2 - As noted by Stanford Professor Deborah Rhode, " [T]hat no comperehensive history of the bar's role in unauthorized practice enforcement has ever been published is somewhat surprising, given public skepticism concerning the profession's objectives. " Policing the professional Monopoly: A Constitutional and Empirical Analysis of Unautorized Practice Prohibitions,34 Stanford L.R. 1, at 6 (November 1981). Professor Rhodes does however cite to several sources which offer a glimpse of such regulation efforts. See Also, Rhode, Deborah. The Delivery of Legal Services by Non-Lawyers,4 Geo. J. Legal Eth. 209-10 (1980).

Footnote 3 - The Florida Bar, as it stands today without public checks and balances, is a public menace which threatens the rights of all state citizens. Therefore, the Florida Legislature should also consider requiring attorneys to pay their annual license fees ($190.00 plus per lawyer) into the state general fund instead of into the coffers of The Florida Bar. These fees add up to many millions of dollars annually. The Florida Bar expends millions of these dollars to fund the salaries and expenses of its private UPL police department, headed by Mary Ellen Bateman, Esquire and to fund other questionable special interest programs such as manipulating the Constitution Revision Commision, state legislation, etc. This would certainly have the effect of putting The Florida Bar on a leash, which is the least that should be done with any "rabid beast" running wild and roughshod across the state abusing and pillaging the citizenry. Additionally, The Florida legislature should consider conducting a formal inquiry into the improper conduct of The Florida Bar management and staff, as well as the Supreme Court's willful complicity.

 

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