FTC Staff Comment Before the Supreme Court of Kentucky Concerning Proposed Guidelines for Certification of Specialists in Kentucky

us-ftc-advocacy-filings-79c2a2d893370fa94584ea91e024f73cFTC Staff Comment Before the Supreme Court of Kentucky Concerning Proposed Guidelines for Certification of Specialists in KentuckyAdvocacy Filing

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June 	8, 	1987
Honorable 	Robert 	F. 	Stephens
Chief 	Justice
Supreme 	Court 	of 	Kentucky
Ne~ Capitol 	Building, 	Room 	231
Frank~ort, Kentucky 	40601
Dear 	Chief 	Justice 	Stephens:
The 	Federal 	Trade 	Commission 	staff 	is 	pleased 	to 	submit
these 	comments 	respecti~g the 	proposed 	Kentucky 	Rules 	of
Professional 	Conduct, 	Supreme 	Court 	Rule 	3.135, 	and 	the 	proposed
Guidelines 	for 	Certification 	of 	Specialists 	in 	Kentucky
("Guide1ines").1 	It 	is 	our understanding 	that 	the"Court 	~ill
hold 	a 	pUblic 	hearing 	on 	the 	proposed 	rules 	and 	guidelines 	on
June 	11 	and 	that 	the 	Court 	is 	interested 	in 	receiving 	our 	vie~s
before 	that 	date.
!n 	this 	letter, 	we 	focus 	~n the 	proposed 	rules 	regarding
fees, 	practice 	with 	non1awyers'~' advertis ing, 	and 	solicitation.
In 	addition, 	we 	address 	existing 	Rule 	3.135,2 	~hich deals 	with
attorney 	advertising, 	and 	some 	of 	the 	proposed 	Guidelines
relating 	to 	advertising 	of 	specialty. 	We 	are 	concerned 	that 	some
of 	the 	proposed 	rules 	and 	the 	existing 	rule 	may 	harm 	consumers 	by
restraining 	price 	competition, 	discouragi~g referrals 	and
associations 	between 	attorneys, 	restricting 	the 	develo?men~ of
innovative 	and 	efficient 	forms 	of 	legal 	practice, 	and
un~ecessarily limiting 	the 	information 	available 	to 	consumers.
We 	also 	believe 	that 	the 	proposed 	Guidelines 	may 	restrain
advertising 	more 	than 	is 	necessary 	to 	protect 	consumers.
As 	is 	discussed 	in 	more 	detail 	below, 	we 	urge 	the 	Court 	to:
(1) 	clarify 	in 	the 	commentary 	to 	proposed 	Rule 	1.5(a) 	that 	only
fees 	that 	are 	so 	high 	as 	to 	suggest 	a 	br~ach 	of 	fiduciary 	duty 	to'
! the 	~lient would 	be 	unreasonable; 	(2) 	dele~e proposed Rule 	1.5(e)
1 	These 	comments 	re~resent the 	views 	of 	the 	Federal 	Trade
Commission's 	Bureaus 	of 	Competition, 	Consumer 	Prote=tion, 	and
Economics, 	and 	not 	necessarily 	those 	of 	the 	Commission 	itself.
The 	Commission 	has, 	however, 	voted 	to 	authorize 	us 	to 	sub~it
these 	comments 	for 	your 	consideration.
2 	We 	conment 	on 	the 	existing 	Supreme 	Court 	rule 	in 	t~e
event 	that 	the 	Court 	does 	not 	adopt 	the 	proposed 	Kentucky 	Rules·
of 	Professional 	Conduct 	a~d because, 	even 	if 	the 	Court 	adc~ts the
proposed 	Rules, 	portio~s of 	the 	existing 	rule 	may 	re~ai~ i;
effect.
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Honorable 	rtc~e~~ F. 	S~ephe~s--Page 2
so 	as 	no~ to 	discou~age referrals 	and 	associations 	of 	at~orneys
in 	different 	law 	firms 	for 	particular 	cases; 	(3) 	eliminate 	the
restrictions 	in 	proposed 	Rule 	5.~ 	on 	prac~ice with 	nonlawye~s,
and 	on 	lawyers 	influencing 	the 	p~ofessional jUdgment 	of 	othe~
lawyers; 	(4) 	amend 	proposed 	Rule 	7.1 	to 	clarify 	that 	t~uthful,
nondeceptive 	endorsements 	and 	experience, 	success, 	and 	comparison
claims 	are 	permitted; 	(5) 	delete 	proposed 	Rule 	7.2(a) 	to 	permit
advertising 	in 	any 	media; 	(6) 	delete 	Rule 	3.135(6) (a) (i) 	to 	allow
attorneys 	to 	advertise 	all 	truthful, 	nondeceptive 	in~ormation;
(7) 	amend 	Rule 	3.135(4) 	to 	eliminate 	the 	restrictions 	on 	the 	use
of 	self-laudatory 	statements 	and 	the 	requirement 	that 	statements
in 	advertisements 	be 	"informative," 	and 	to 	clarify 	what 	the 	Cou~t
interprets 	as 	"unfair"; 	(8) 	modify 	proposed 	Rule 	7.2(b) 	to 	allow
the 	payment 	of 	refer~al fees 	to 	attorneys 	and 	the 	use 	of 	for-
profit 	referral 	services; 	(9) 	modify 	proposed 	Rule 	7.3 	to 	remove
the 	broad 	ban 	on 	solicitation; 	(10) 	modify 	proposed 	Rule 	7.4 	to
allow 	express 	and 	implied 	claims 	of 	specialty, 	and 	delete 	Rule
3.135(5) (b) (2) 	and 	proposed 	Guideline 	VII.A.2 	and 	B so 	as not 	to
discourage 	specialty 	adve~~ising; and 	(11) 	delete 	proposed
Guideline 	IV.E 	to 	promote 	competition 	between 	Board 	certified
specialists 	and 	referring 	attorneys.
Interest 	and 	Exoerience 	of 	the 	Fede~al T~ade Commission
For 	more 	than 	a 	decade, 	the 	Commission 	has 	investigated 	the
effects 	of 	restrictions 	on 	the 	~usiness practices 	of 	state-
licensed 	professionals, 	inclUding 	lawyers, 	accountants, 	dentis~s,
physicians, 	non-physician 	health-care 	providers, 	and 	others. 	The
goal 	of 	the 	Commission 	has 	~een to 	identify 	and 	seek 	the 	removal
of 	restrictions 	that 	prevent 	professionals'from 	advertising 	or
providing 	services 	~hat consume~s want 	without 	providing
. countervailing 	benefits. 	We 	believe 	that 	Supreme 	Cour~ rtule
3.135, 	and 	certain 	of 	the 	proposed 	Guidelines 	and 	proposed
Kentucky 	Rules 	of 	Professional 	Conduct, 	may 	result 	in 	such
adverse 	effects. 	'
!
Prooosed 	Rule 	1.5: 	Fees
?rooosed 	Rule 	1.5(a): 	rteasonableness 	of 	Tee
Proposed 	Rule 	1.5(a) 	states 	that 	a 	"lawyer's 	fee 	shall 	~e
reasonable," 	and 	SUbparagraph 	(3) 	provides 	that 	"the 	fee
customa~ily charged 	in 	the 	locality 	fo~ similar 	legal 	services"
is 	~o 	be 	considered 	in 	dete~ining ~easonableness. 	We 	suppc~t
"h 	B 	' 	1 	. f . 	.. . 	. 	""h 	... 	d'	~ e 	ar 	s 	c 	a~~ 	~ca~~on 	~n 	~.e 	co~entary 	~o 	p~opose 	Ru_e 	1.5(a)
enti~led "Disputes 	ove~ Fees" 	that 	subparag~aph (3) 	is 	inte~ded
"to 	prohi'bit 	unreasona~ly high 	fees 	and 	does 	not 	p::event 	a 	la;.;ye~
from 	sharing 	(sic] 	fees 	~ha~ a~e 	less 	than' custor..ary. '" 	This
commenta~ will 	avoid 	lawyers' 	in~e~p~eting t~is 	language 	to 	~ar
"un~easonably" low 	fees. 	I~ will 	~hus 	allow 	price 	co:npetition
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Hono~able 	~obe~~ 	F. 	S~ephens--?age 3
among 	t~aditional practitioners 	and 	also 	might 	prc~ote
competition 	f~om legal 	clinics 	and 	other 	nont~adi~:onal providers
of 	legal 	services.
Although 	proposed 	Rule 	l.S(a) 	would 	permit 	mo~e price
competition 	in 	certain 	respects, 	it 	nevertheless 	is 	undesirable
insofar 	as 	it 	may 	set 	a 	ceiling 	on 	fees. 	We 	do 	no~ believe 	that
consumers 	of 	legal 	services 	benefit 	from 	price 	regulation,
whether 	a 	minimum 	or 	maxi~um price 	is 	imposed. 	Setting 	a 	minimum
price 	may 	increase 	prices 	and 	set~ing a 	maximum 	price 	may 	reduce
the 	quality 	of 	services 	offe~ed. 	For 	that 	reason, 	we 	believe
that 	proposed 	Rule 	l.S(a) 	should 	be 	applied 	only 	in 	extreme 	cases
where 	an 	attorney's 	fee 	is 	so 	high 	that 	it 	represents 	a 	clear
abuse 	of 	the 	client 	or 	suggests 	a 	possible 	breach 	of 	fiduciary
duty. 	We 	there~ore 	suggest.that 	the 	commentary 	make 	clear 	that
fees 	may 	be 	found 	to 	be 	unreasonably 	high 	only 	if, 	under 	the
circumstances, 	the 	attorney 	appears 	to 	be 	exploiting 	the 	client.
P~c~osed Rule 	I.See): 	Fee-Snlitting
Proposed 	Rule 	l.S(e), 	apparently 	derived 	from 	Rule 	l.S(e) 	of
the 	ABA's 	Model 	Rules 	of 	Professional 	Conduct, 	states 	that
division 	of 	fees 	between 	lawyers 	who 	are 	not 	in 	the 	same 	fi~ may
be 	made 	only ,in 	two 	alternative 	circumstances. 	;irst, 	division
of 	fees 	is 	pe~itted if 	the 	division 	is 	in 	proportion 	to 	the'
services 	performed 	by 	each 	lawyer. 	Alternatively, 	division 	of
.fees 	is 	permitted 	according 	to 	the 	allocation 	agreed 	on 	by 	the
lawyers 	if, 	by 	written 	agreement 	with 	the 	client, 	each 	lawyer
assumes 	joint 	~esponsibility for 	the 	representation. 	In 	either
case, 	the 	client 	must 	be 	advised 	of 	and 	not 	object 	to 	the
participation 	of 	all 	the 	lawye~s involved 	and 	the 	total 	fee 	must
be 	"reasonable." 	We 	are 	concerned 	that 	the 	proposed 	rule 	might
unnecessarily 	discourage 	both 	referrals 	and 	associations 	between
lawyers 	in 	diffe~ent law 	firms 	under 	ci~cumstances in 	which 	such
. activity 	may 	benefit 	consumers.
Division 	of 	fees 	can 	provide 	incen~ives for 	at~orney
refe~rals and 	associations 	that 	are 	desi~able for 	the 	client .	. .
Unlike 	lawyers 	in 	large 	firms, 	who 	can 	refer
matte~s to 	thei~ partne~s and 	receive 	a 	share
of 	the 	fees, 	when 	lawye~s in 	small 	firms
receive 	a 	matte~ 	tha~ 	is. outside 	thei~ normal
expertise, 	they 	~ay not 	forward 	it 	~o 	a 	more
qualified 	attorney 	and 	still 	partici?a~e in
the 	fee. 	Consequently, 	they 	have 	leps
incentive 	to 	~efe~ matters 	to 	more 	cualified
counsel. 	[Division 	of 	fees] 	will 	benefit
clients 	because 	it 	~akes 	it 	mo~e likely 	t~at
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Honorab:e 	Robe=~ F. 	S~ephens--Page ~
their 	ma~te=s will 	be 	forwarded 	to 	the 	most
appropriate 	counsel •...3
Proposed 	Rule 	1.5(e) 	would 	inhibit 	referrals 	by 	lawyers.
First, 	the 	requirement 	that 	a 	division 	of 	fees 	be 	"in 	proportion
to 	the 	services 	performed 	by 	each 	lawyer ll 	might 	be 	interpreted 	to
prohibit 	referral 	fees, 	because 	it 	is 	unclear 	whether 	giving 	a
prospective 	client 	the 	name 	and 	telephone 	number 	of 	another
lawyer 	competent 	to 	handle 	that 	client's 	legal 	problems
constitutes 	compensable 	Ilservices ll 	under 	the 	language 	of 	the
proposed 	rule. 4 	Even 	if 	this 	provision 	were 	interpreted 	to
permit 	referral 	fees, 	it 	might 	be 	interpreted 	to 	allow 	only 	a
very 	small 	portion 	of 	the 	total 	fees 	to 	be 	paid 	to 	the 	referring
attorney. 	Second, 	the 	alternative 	re~~irement that 	a 	referring
attorney 	assume 	responsibility 	for 	the 	independent 	professional
jUdgmen~s of 	the 	attorney 	who 	is 	actually 	handling 	the 	case 	is
likely 	to 	deter 	referrals. 	Because 	of 	the 	liability 	for
malpractice 	that 	joint 	responsibility 	might 	entail,~ the
referring 	at~orney probably would 	be 	compelled 	to 	review 	the
o~her attorney's 	work. 	This 	could 	result 	in 	costly 	duplication
of 	effort. 	It 	would 	seem 	that 	the 	referring 	attorney 	and 	the
.3 	Report 	of 	the 	Special 	Committee 	to 	Consider Adoption 	of
the 	ABA Mocel 	Rules 	of 	Professional 	Conduct 	or 	to 	Consider
Revisions 	of 	the 	1969 	Code 	at 	8-9 	(March 	1986) .	..
4 	A referral 	may 	be 	a 	valuable 	service. 	But 	according 	to
state 	cou=t 	and 	ABA 	opinions, 	a 	Ilmere ll 	referral 	does 	not
constitute 	a 	"service" 	and 	therefore 	an 	at~orney is 	not 	entitled
'to 	any 	portion 	of 	the 	fee 	when 	he 	or 	she 	has 	merely 	referred 	a
clien~ 	~o 	another. 	See 	Corti 	v. 	Fleisher, 	93 	Ill. 	App.3d 	517,
417 	N.E.2d 	764, 	772 	(1981); 	Palmer v. 	Breyfogle, 	217 	Kan. 	128,
~35 	P.2d 	955, 	958 	(1975); 	McFarland 	v. 	George, 	316 	S.W.2d 	662
(Mo. 	1968); 	Note, 	Referral 	Fees 	and 	the 	Effect 	of 	Disciolinarv
Rule 	2-107, 	8 	J. 	Legal 	Prof. 	225, 	228-29 	(1983); 	Note, 	Division
of 	?ees 	Between 	Attornevs, 	3 	J. 	Legal 	Prof. 	179, 	186 	(1978)
(citing 	ABA 	Opinions).
5 	The 	comment 	to 	orooosed 	Rule 	1.5 	on 	divis~on of 	fees
states 	tha~ 	"[j)oint 	responsibility 	for 	the 	representation
en~ails the 	obliga~io~s stated 	in 	Ru~e 5.1 	fer 	purposes 	of 	the
ma~~er involved." 	Proposed 	Rule 	5.1 	governs 	r~sponsibilities of
ao par~ner 	for 	~he 	ethical 	conduct 	of 	another 	at~orney in 	the 	sa~e
law 	fi=m, 	as 	well 	as 	responsibilities 	of 	supervisory 	lawyers.
Because 	it 	focuses 	on 	thes~ relationshios, 	its 	aoolication 	in 	the
context 	of 	a 	"joint 	responsibility" 	si~~ation is-~nclear.
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Ho~o~a~le 	Rc~e~~ 	F. 	Step~ens--?age 5
attorney 	handling 	the 	case 	should 	be 	able 	to 	determine 	among
themselves 	how 	to 	divide 	the 	total 	legal 	fee.
Two 	justifications 	have 	been 	offered 	to 	support 	bans 	on
referral 	fees. 	First, 	it 	has 	been 	argued 	that 	permitting
referral 	fees 	would 	tempt 	some 	lawyers 	to 	refer 	legal 	matters 	to
the 	lawyer 	who 	pays 	the 	highest 	referral 	fee, 	rather 	than 	to 	the
best 	qualified 	lawyer. 	In 	personal 	injury 	and 	other 	cases 	that
are 	taken 	on 	a 	contingent 	fee 	basis, 	however, 	the 	referring
lawyer 	typ~cally receives 	one-third 	of 	any 	fee 	recovered 	by 	the
lawyer 	who 	handles 	the 	case. 6 	ThUS, 	it 	is 	probable 	that 	the
referring 	a~torney will 	select 	the 	lawyer 	who 	he 	or 	she 	believes
is 	the 	most 	likely 	to 	~ecover the 	largest 	awa~d for 	the
prospective 	client. 	Clearly, 	20% 	of 	an 	attorney's 	recovery 	in 	a
contingent 	fee 	case 	is 	better 	than 	40% 	of 	nothing; 	to 	this
extent, 	the 	attorney's 	and 	the 	client's 	interests 	are 	the 	same.
Even 	When 	no 	contingency 	fee 	is 	involved,. a 	lawyer 	referring 	a
client 	to 	a 	specialist 	has 	every 	incentive 	to 	make 	suitable
referrals 	in 	order 	to 	maintain 	client 	goodwill, 	in 	the 	interest
of 	Obtaining 	repeat 	business 	and 	of 	preserving 	his 	or 	her
professional 	reputation.
Second, 	some 	have 	argued 	that 	the 	attorney 	to 	whom 	a 	case 	is
referred 	will 	increase 	the 	total 	fee 	paid 	by 	the 	client 	in 	order
to 	recoup 	the 	referral 	fee. 	This 	does 	not 	aooear 	to 	be 	a 	valid
concern. 	First, 	the 	attorney 	could 	not 	raise 	his 	or 	her 	fees
~ithout losing 	some 	clients 	who 	are 	price-sensitive. 	In
·addition, 	by 	facilitating 	referrals 	to 	experts, 	referral 	fees 	may
actually 	reduce 	the 	total 	fees 	charged 	to 	clients. 	Because 	of
their 	more 	predictable 	and 	more 	specialized 	workload, 	expe~ts may
be 	a~le to 	reduce 	costs 	and 	pass 	on 	such 	savings 	to 	clients.
Associations 	of 	two 	or more 	lawyers 	in 	different 	firms 	may
also 	benefit 	consumers. 	The 	corwment 	to 	orooosed 	Rule 	1.5
entitled 	"Division 	of 	Fee" 	correctly 	rec~gnlzes that 	such
associations 	may 	benefit 	a 	client 	in 	cases 	in 	which 	neither
attor~ey alone 	could 	se=ve 	the 	client 	as 	well. 	For 	example, 	one
lawyer 	may 	not 	have 	SUfficient 	time, 	resources, 	or 	expertise 	to
handle 	all 	aspects 	of 	a 	particular 	client's 	case. 	An 	attorney
from 	Firm 	X 	might 	se=ve 	as 	chief 	trial 	attorney, 	while 	his 	or 	her
co-counsel 	from· Firm 	Y might 	perform the 	bulk 	of 	the 	pretrial
preparation.
Prooosed 	Rule 	1.5(e) 	might 	discourage 	such 	associations.
The 	provlsion 	that 	a 	division 	of 	fees 	between 	attorneYS 	in
different 	law 	firms 	be 	proportional 	to 	the 	services 	perfo~ed by
6 	Referral 	Fees: 	~verv~odv Does 	It, 	But 	Is 	It 	OK?,
A. B • A. 	J'., 	Feb. 	1985, 	at 	40.
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Honora~le 	Robe~~ 	F. 	S~ephe~s--?age 6
each 	lawyer 	would 	impose 	rigidity 	on 	the 	alloca~ion of 	the 	fee.
I! 	lawye~s we~e allowed 	to 	negotiate 	their 	respective 	shares 	of
the 	total 	legal 	fee, 	they 	could 	allocate 	the 	fee 	according 	to 	the
!acto~s they 	deem 	important, 	including 	nu~~er of 	hours 	spent,
prior 	knowledge 	of 	the 	facts, 	relationship 	with 	the 	client, 	o~
deg~ee of 	expertise. 	The 	alternative 	provision, 	imposing 	joint
responsibility 	on 	one 	attorney 	for 	the 	independent 	professional
jUdgments 	of 	another, 	also 	appears 	likely 	to 	deter 	associations
of 	attorneys 	in 	different 	law 	firms, 	just 	as 	joint 	responsibility
would 	deter 	attorney 	referrals.
For 	the 	reasons 	s~ated above, 	we 	urge 	the 	Court 	to 	delete
proposed 	Rule 	1.S(e) 	in 	its 	entirety. 	It 	is 	not 	clear 	that 	any
regulation 	of 	fee 	division 	is 	necessary. 	Should 	the 	Court 	deem
it 	to 	be 	necessary, 	the 	les~ restrictive 	alternative 	of 	re~iring
disclosure 	might 	be 	imposed. 	If 	consumers 	are 	not 	generally
aware 	of 	the 	practice 	of 	paying 	referral 	fees, 	disclosure 	may 	be
necessary 	so 	that 	consumers 	can 	assess 	referrals 	effectively. 	If
the ~ourt decides 	to 	require 	disclosure, 	however, 	the 	requirement
should be 	devised 	carefully 	to 	avoid 	imposing 	unnecessary 	costs.
Prooosed 	Rule 	5.4: 	Professional 	!ndeoendence 	of 	a 	Lawver
Proposed 	rtule 	5.4 	prohibits 	a 	lawyer 	from 	forming 	a
partnership 	or 	sharing 	legal 	fees 	with 	a 	nonlawyer, 	except 	under
limited 	circums~ances, or 	from 	practicing 	in 	an 	organization
authorized 	to 	practice 	law 	for 	a 	profit 	if 	a 	nonlawyer 	owns 	an
interest 	in 	the 	organization. 	This 	proposed 	rule 	would 	limit 	the
ability 	of 	lawyers 	to 	establish 	mUlti-disciplinary 	practices 	with
other 	professionals, 	such 	as 	psychologists 	or 	accou~tants, to
deal 	efficiently 	wi~h both 	the 	legal 	and 	nonlegal 	aspects 	of
.specific 	problems. 	Proposed 	Rule 	5.4 	also 	would 	appear 	to 	bar
lawyers 	from 	inclUding 	any 	lay 	persons, 	such 	as 	marketing
cirec~ors, as 	partners 	in 	their 	law 	fi=ms. 	Finally, 	such 	a
restric~ion would 	appear 	to 	prohibit 	corporate 	prac~ice, and
~hereby preven~ the 	use 	of 	potentially 	efficient 	business
formats.
The 	Commission 	has 	examined 	similar 	=es~rictions on
associations 	between 	physicians 	and 	nonphysicians 	and 	concluded
that 	they 	restrain 	competition 	unnecessarily. 	In 	Arne~ican
Medical 	Association, 	94 	F.T.C. 	701, 	1017-18 	(1979), 	a:f'd, 	638
:.2d 	443 	(2d 	ci~. 	1980), 	atf'c 	me~. 	bv 	an 	e~allv div:ced 	Court,
455 	U.S. 	676 	(1982), 	the 	:ederal 	Trade 	Commission 	found 	tha~ the
AY~'s ethical 	restric~ions on 	the 	for~rr.ation of 	o~ofessional
associations 	with 	no~=hvsicia~s had 	an 	acverse 	~ffect on
competition. 	The 	A¥~is-form of 	practice 	res~rictions prec~uded a
wide 	variety 	of 	professional 	ventures 	and 	potentially 	efficient
business 	formats, 	such 	as 	health 	rnain~enance orcanizations 	and
prepaid 	health 	care 	plans. 	The 	co~~ission concluded 	that 	~he
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Hono~able 	Rc=e~~ 	F. 	Stephens--?age 	7
prohibi~ions 	were 	much 	broader 	than 	needed 	~o prevent
non~hvsician influence 	over medical 	~rocedures or 	consumer
deception 	about 	the 	skills 	of 	a 	nonphysician 	partner 	or
associate.
The 	co~~ission staff 	has 	studied 	the 	benefits 	to 	consumers
of 	associations 	between 	professionals 	and 	lay 	persons. 	The 	staff
of 	the 	Federal 	Trade 	Commission's 	Bureau 	of 	~conomics concluded
from 	a 	study 	of 	the 	optomet~ic profession 	that 	the 	price 	of
optometric 	services 	is 	lower 	in 	jurisdic~ions in 	which 	business
associations 	between 	p~ofessionals and 	lay 	persons 	are
permitted. 7 	Restrictions 	on 	such 	business 	associations 	impede
the 	forma~ion of 	chain 	firms 	and 	other volume 	operations 	and 	thus
make 	it 	difficult 	to 	achieve 	economies 	of 	scale.
Proposed 	Rule 	5.4 	might 	limit 	potentially 	procompetitive
professional 	ventures, 	innovative 	business 	forma~s, 	and 	perhaps
some 	:o~s of 	prepaid 	legal 	services. 	By 	imposing 	restric~ions
on 	business 	associations 	between 	lawyers 	and 	nonlawyers, 	proposed
Rule 	5.4 	might 	prevent 	lawyers 	from 	achieving 	savings 	in
~arketing that 	could 	be 	passed 'on 	to 	consumers. 	For 	example, 	the
proposed 	rule 	would 	no~ permit 	a 	retailer 	such 	as 	Sea~s to 	employ
attorneys 	to 	provide 	legal 	services 	to 	the 	public. 	If 	attorneys
were 	permitted 	to 	enter 	into 	such 	an 	arrangement, 	it 	would 	be
feasible 	for 	them 	to 	adver~ise on 	a 	national 	scale 	and 	share
adver~ising time 	wi~h other 	Sears 	service 	providers, 	such 	as 	its
.insurance, 	stock 	brokerage, 	and 	realty 	subsidiaries.
Nonlawyer 	officers 	and 	directors 	may 	provide 	law 	firms 	with
managerial 	or marketing 	expertise. 	Proposed 	Rule 	5.4 	would
permit 	nonlawyers 	to 	be 	corporate 	directcrs 	and 	officers 	in 	law
firms, 	which 	would 	enable 	law 	firms 	to 	secure 	~heir exper~ise.
We 	are 	concerned, 	however, 	that 	the 	p~oposed rule 	would
discourage 	nonlawyers 	from 	seeking 	such 	positions, 	since
paragraph 	(a) 	and 	subparagraph 	(d) (1) 	would 	prohibi~ nonlawyers
~ from 	sharing 	the 	profits 	or 	owning 	an 	interest 	in 	~he 	law 	firm.
Subparagraph 	(d) (2) 	provides 	that 	a 	lawyer 	shall 	not
practice 	with 	a 	for-profit 	organization 	if 	a 	nonlawye~ 	has 	the
right 	to 	direct 	or 	control 	the 	lawyer's 	professional 	jUdgment.
That 	subparagraph 	alone 	should 	adequately 	prese=ve 	the 	lawye~'s
indepe~dent p~ofessional jUdgment which, 	acco~ding to 	the
co~~entary to 	proposed 	Rule 	5.4, 	was 	the 	purpose 	of 	this
disciplinary 	~le.
7 	Bureau 	of 	Economics, 	Feceral 	Trade 	Co~~ission, ~::ects 0:
Res~ric~ions on 	Advertising 	and 	Corr~ercial ?rac~ice in 	~he
?ro:essions: 	The 	Case 	of 	Optome~ry 25-26 	(1950).
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Honora~le 	Ro~er~ 	F. 	S~e?hens--Page 8
Proposed 	Rule 	5.4(c) 	is 	apparently 	intended 	as 	a 	further
guaran~ee of 	the 	lawyer's 	independent 	professional 	jUdgment. 	Th~
proposed 	rule 	provides 	that 	"(a] 	lawyer 	shall 	not 	permit 	a 	person
who 	recommends, 	employs, 	or 	pays 	the 	lawyer 	to 	render 	legal
services 	for 	another 	to 	direct 	or 	regulate 	the 	lawyer's
professional 	jUdgment 	in 	renderi:-.g 	such 	legal 	services." 	The
word 	"person" 	in 	the 	proposed 	rule 	appears 	to 	encompass 	bo~h
lawyers 	and 	nonlawyers. 8 	If 	so, 	the 	proposed 	rule, 	in 	effect,
would 	prOhibit 	an 	at~orney handling 	a 	case 	based 	on 	a 	referral
from 	allowing 	his 	or 	her 	professional 	judgment 	to 	be 	directed 	or
regulated 	by 	the 	referring 	attorney. 	The 	attorney 	accepting 	a
referral 	would 	be 	unable 	to 	base 	a 	decision 	concerning 	a
partiCUlar 	legal 	issue 	on 	a 	consultation 	with 	the 	referring
attorney, 	even 	when 	that 	consultation 	might 	be 	beneficial 	to 	the
partiCUlar 	client.
Furthermore, 	proposed 	Rule 	5.4(c) 	appears 	to 	conflict 	with
proposed 	Rule 	1.5(e). 	One 	circumstance 	under 	which 	proposed 	Rule
1.5(e) 	would 	permit 	attorneys 	from 	different 	firms 	to 	divide 	fees
is 	where 	"each 	lawyer 	assumes 	joi,nt 	responsibility 	for 	the 	'
representation. ,,9 	Proposed 	Rule 	S.4(C), 	on 	the 	other 	hand,
would 	prohibit 	the 	referring 	attorney 	from 	directing 	or
regulating 	the 	professional 	jUdgment 	o! 	the 	attorney 	who 	received
the 	referral. 	Thus, 	the 	proposed 	rules 	would 	leave 	the 	referring
attorney 	in 	the 	predicament 	where 	he 	or 	she 	might 	be 	liable 	for
the 	other 	attorney's 	handling 	of 	the 	case, 	but 	still 	could 	not
influence 	that 	attorney's 	professional 	jUdgment.
We 	therefore 	urge 	the 	Court 	to 	delete 	all 	of 	proposed 	Rule
5.4, 	except 	paragraph 	(c) 	and 	subparagraph 	(d) (2), 	and 	to 	amend
paragraph 	(c) 	so 	that 	it 	applies 	only 	where 	a 	nonlawyer 	directs 	a
lawyer's 	professional 	jUdgment.
Pronosed 	R~le 7.1: 	coremunications 	Concern ina 	a 	~awver's 	Services
The 	beneficial 	effects 	of 	advertising 	are 	widely 	recognized.
TruthfUl, 	nondecep~ive advertising 	communicates 	information 	about
individuals 	or 	fi=ms 	offering 	the 	services 	that 	consumers 	may
wish 	to 	nurchase. 	Such 	information 	helns 	consumers 	make
decisions 	that 	reflect 	their 	true 	preferences 	and 	promotes 	the
efficient 	delivery 	of 	services. 	Before 	advertising 	by 	attorneys
8 	A literal 	reading 	of 	pro?osed 	Rule 	5.4 	(c) 	would 	prohibit
an 	associate 	a~~orney from 	allowing 	his 	or 	her 	professional
jUdgment 	to 	be 	influenced 	by 	a 	par~ner 	in 	the 	same 	fi~. 	This
undoubtedly 	was 	no~ the 	in~ention of 	the 	Bar.
9 	Proposed 	Kentucky 	Rule 	of 	Professional 	Conduc~
1.5(e) (1) (b).
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11
Hono~able Rcber~ F. 	S~~phens--?age 9
~as 	permitted, 	many 	Americans 	failed 	to 	obtain 	the 	se~ices of 	an
attorney, 	even 	~hen t~ey had 	serious 	legal 	problems,10 	primarily
because 	t~ey feared 	that 	legal 	representation 	~ould cos~ too 	muc~
or 	they 	~ere unable 	to 	locate 	a 	lawyer 	sUfficiently 	skilled 	at
handling 	their 	particular 	problems.~l 	A recent 	empirical 	study
suggests 	that 	the 	removal 	of 	restrictions 	on 	the 	dissemination 	of
truthful 	information 	about 	lawyers 	and 	legal 	services 	~ill tend
to 	enhance 	competition 	and 	lo~er prices. 12 	Although 	concern 	has
been voiced 	that 	advertising 	may 	lead 	to 	lo~er quality 	legal
services, 	the 	empirical 	evidence 	suggests 	that 	the 	quality 	of
legal 	services 	provided 	by 	firms 	that 	advertise 	is 	at 	least 	as
high 	as, 	if 	not 	higher 	than, 	that 	provided 	by 	firms 	that 	do 	not
advertise. 13
We 	fully 	endorse 	the 	view 	that 	false 	and 	deceptive
advertising 	should 	be 	prohibited. 	Nonetheless, 	as 	set 	forth
belo~, 	~e believe 	that 	the 	definition 	of 	"false 	or misleading"
contained 	in 	proposed 	Rule 	7.1 	may 	prohibit 	much 	truthful,
no~deceptive advertising.
Prooosed 	Rule 	7.1(b): 	"Unjustified 	Exnectations"
The 	State 	Bar 	of 	Kentucky 	proposes 	that 	the 	Court 	adopt, 	in
connection 	with 	proposed 	Rulp- 	7.1(b), 	the 	comments 	drafted 	by 	the
American 	Bar Association 	~ith respect 	to 	the 	identical 	provisions
in 	ABA Model 	Rule 	7.1. 	The ABA 	comments 	state:
The 	prohibition 	in 	paragraph 	(b) 	of
statements 	that 	may 	create 	"unjustified
10 	For 	example, 	a 	nation~ide 	survey 	in 	1974 	by 	the 	American
Bar 	Foundation 	and 	the 	American 	Bar 	Association 	found 	that 	only
nine 	percent 	of 	the 	people ~ho had 	property 	damage 	problems, 	ten
. percent 	of 	those 	~ho had 	landlord 	problems, 	and 	one 	percent 	of
those 	~ho 	felt 	that 	they 	~ere the 	victims 	of 	employment
discrimination 	sought 	t~e 	services 	of 	an 	attorney 	after 	the 	most
recent 	occurrence. 	B. 	Curran, 	The 	Legal 	Needs 	of 	the 	Public:
The 	Final 	Report 	of 	a 	National 	Survey 	135 	(1977).
rd. 	at 	228, 	231.
12 	Cleveland 	Regional 	Office 	and 	Bureau 	of 	Economics,
Federal 	Trace Commission, 	Improving 	Consumer 	Access 	to 	Legal
Services: 	The 	Case 	=or 	Removing 	Res~rictions on 	Truthful
Advertising 	(1984).
13 	Muris 	& McChesney, 	Advertisina 	and 	the 	Pri=e 	and 	Qualitv
o~ Lecal 	Services: 	The 	Case 	~or Le=al 	Clinics, 	1979 	Am. 	B.
Found. 	Research 	J. 	179.
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Hono~able 	Rober~ 	:. 	S~ephens--Page 10
expecta~ions" would 	ordinarily 	preclude
adve~~isements about 	results 	obtained 	on
behalf 	of 	a 	client, 	such 	as 	the 	amount 	of 	a
damage 	award 	or 	the 	lawyer's 	record 	in
obtaining 	favorable 	verdicts, 	and
advertisements 	containing 	client
endorsemen-:.s.
The 	comments 	suggest 	that 	information 	about 	past 	results 	"may
c~eate the 	unjustified 	expec~ation that 	similar 	results 	can 	be
obtained 	for 	othe~s without 	reference 	to 	the 	specific 	factual 	and
legal 	circumstances." 	This 	interpretation 	of 	the 	phrase 	"likely
to 	create 	an 	unjustified 	expectation" 	is 	so 	broad 	that 	it 	cou~d
chill 	the 	use 	of 	much 	adve~tising that 	is 	truthful 	and 	beneficial
to 	consumers. 	For 	example, 	consumers 	may 	wish 	to 	consider 	an
atto~ney's past 	results 	as 	one 	of 	several 	factors 	in 	selecting 	a
lawyer.: 	While 	it 	may 	be 	impossible 	to 	provide 	complete
information 	about 	prior 	cases 	in 	an 	advertisement, 	there 	is 	no
reason 	to 	believe 	an 	advertisement 	of 	prior 	experience 	could 	not
be 	p~esented in 	a 	way 	~hat is 	not 	deceptive. 	Information 	that 	is
less 	than 	complete 	may, 	nonetheless, 	not 	be 	misleading 	as 	long 	as
it 	does 	not 	omit 	~aterial facts. 	"[I)t 	seems 	peculiar 	to 	deny
the 	consumer, 	on 	the 	ground 	that 	the 	information 	is 	incomplete,
at 	least 	some 	of 	the 	relevant 	information 	needed 	to 	reach 	an
informed 	decision." 	Bates 	v. 	S~ate 5ar 	of 	A~izona, 	433 	U.S. 	350,
37'4 	(1977).
Advertising 	by 	means 	of 	testimonials 	and 	endorsements 	has
t~aditionally been 	recognized 	as 	effective 	by 	sellers 	of 	goods
ahd 	se~ices. 	For 	example, 	the 	listing 	of 	certain 	clients 	such
as 	major 	banks 	or 	corporations 	in 	the 	Martindale-Hubbell
dir.ectory 	suggests 	that 	a 	firm 	can 	han~le complicated 	legal
?r9blems 	in which 	large 	sums 	of money 	may 	be 	at 	risk. 	.
Adve~tising 	in 	which 	clients 	attest 	tru~hfully that 	they 	use 	a
firm's 	legal 	services 	provides 	the 	general 	pUblic·the 	same
information 	that 	is 	available 	to 	users 	of 	legal 	directo~ies.
Advertising 	in 	which 	clients 	discuss 	thei~ ~easons for
satisfaction 	with 	a 	law 	firm 	conveys 	even 	more 	information 	than
do 	legal 	directo~ies. 	An 	advertisement 	in 	which 	a 	famous 	athlete
or 	ac~or s~ates truthfully 	that 	he 	or 	she 	uses 	a 	particular 	firm
or 	attorney 	indicates 	to 	consu~ers tha~ someone 	who 	can 	spend 	a
substantial 	sum 	~o 	find 	a 	good 	atto~ney, 	and 	who 	may 	have
significant 	assets 	a~ 	stake, 	believes 	a 	part~cular 	law:e~ 	to 	be
effective. 	Testi~onials are 	not 	necessarily 	misle;ding 	and 	may
be 	effec-:.ive 	in 	attracting 	and 	~etaining consume~ inte~es~ in 	-:.he
advertiser's 	message.
:n 	short " 	we 	believe 	that 	advertisements 	containing 	c2.ient
endorsements 	or 	information 	about 	oast 	successes 	can 	be 	presented
in ways 	not 	likely 	to 	create .unjus~ified expectations. 	We
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Ho~o=a~le 	Rc=e=~ 	F. 	S~epher.s--?age 11
therefo=e 	urge 	the 	Cou=t 	to 	modify 	the 	ABA 	corr~entary 	with
respect 	to 	proposed 	Rule 	7.l(b) 	and 	make 	clear 	that
advertisements 	containing 	tru~hful and 	nondeceptive 	endorsements,
testimonials, 	and 	statements 	of 	a~torneys' prior 	results 	are
permitted. 14
Proposed 	Rule 	7.1(c): 	Comparative 	Advertising
Proposed 	Rule 	7.1(c) 	provides 	that 	a 	lawyer 	shall 	not
compare 	"the 	lawyer I s 	services 	with 	other 	lawyers I 	service's,
unless 	the 	comparison 	can 	be 	factually 	substantiated." 	We
believe 	that 	this 	rule 	may 	un~ecessarily inhibit 	competition 	by
prohibiting 	lawyers 	from 	maki~g truthful 	adver~ising claims 	that
are 	not 	amenable 	to 	empirical 	substantiation. 	Information 	that
accurately 	compares 	the 	par~icular qualities 	of 	competing 	law
firms 	may 	encourage 	improvement 	and 	innovation 	in 	the 	delivery 	of
services 	and 	assist 	consumers 	in 	making 	rational 	purchase
decisions. 	Of 	course, 	comparisons 	containing 	false 	or 	deceptive
statements 	of 	fact, 	either 	about 	the 	advertiser 	or 	a 	competitor,
can 	be 	harmful. 	However, 	such 	statements 	already 	are 	prohibited
by 	proposed 	Rule 	7.1(a).
We 	are 	concerned 	that 	proposed 	Rule 	7.1(c) 	may 	deter 	the 	use
of 	comparati~e adve=tising 	and 	preclude 	truthful, 	nondeceptive
statements 	merely 	because 	they 	are 	not 	amenable 	to 	empirical
testing. 1S 	Examples 	of 	such 	statements 	are 	"Friendlier 	service"
14 	In 	addition, 	we 	recommend 	that 	the 	Court 	delete 	Rule
3.135 	(5) (a) (ii), 	which 	is 	SUbstantially 	similar 	to 	proposed 	Rule
7.l(b), 	or 	clarify 	that 	this 	p=ovision 	does 	not 	prohibit
advertisements 	=ontaining 	endorsements 	and 	testimonials.
15 	In 	a 	statement 	of 	policy 	regarding 	comparative
advertising, 	the 	Federal 	Trade 	Commission 	recognized 	the 	benefits
of 	comparative 	advertising 	and 	indicated 	concern 	about 	s~andards
set 	by 	self-regulatory 	bodies 	that 	might 	discourage 	the 	use 	of
such 	advertising:
On 	occasion, 	a 	higher 	standa=d 	of
s~bstantiation by 	advertisers 	using
compa=ative 	advertising 	has 	been 	required 	by
self-=egulation 	entities. 	The 	Commission
evaluates 	comparative 	acvertising 	in 	the 	same
~anner as 	i~ evaluates 	all 	other 	advertising
techniques 	.... 	(I)nterpretations 	tha~
ir.pcse 	a 	highe= 	standard 	of 	subs~antiation
:0= 	cor.para~ive clai~s than 	fo= 	unilateral
claims 	are 	inappropriate 	and 	should 	be 	,
( 	.. • 	...:l 	)	
con ... J..nue ......
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Eonorable 	Ro~ert F. 	Step~ens--Page 12
or 	":!'1ore 	convenient 	hours." 	:::ven 	tl":.ou;h 	such 	sta te:nents 	are 	not
readily 	su~ject to 	verifica~ion, they 	may 	be 	truthful 	and
nondeceptive, 	and 	indicate 	the 	qualities 	that 	the 	advertiser
believes 	are 	important 	to 	consumers. 	Moreover, 	such 	statements
can 	attract 	consumers' 	attention 	to 	the 	advertising 	attorney.
:::ven 	advertising 	that 	is 	designed 	only 	to 	attract 	attention 	can
inform 	consumers 	of 	a 	lawyer's 	presence 	in 	a 	community, 	which 	is
itself 	useful 	information.
Proposed 	Rule 	7.1 	(c) 's 	requirement 	of 	factual
substantiation 	appears 	to 	~e broader 	than 	necessa=y 	to 	prevent
deception. 	The 	Commission 	generally 	requires 	that 	advertisers
have 	a 	"reasonable 	basis" 	for 	any 	objectively 	verifiable 	and
material 	claims 	that 	they 	make, 	because 	the 	act 	of 	making 	such 	a
claim 	i~?lies some 	basis 	fo~ it, 	and 	consumers 	would 	be 	deceived
if 	a 	reasonable 	level 	of 	support 	were 	lacking. 16 	However,
"pUffery" 	and 	SUbjective 	claims 	do 	not 	similarly 	imply 	that
sUbs~antiation exists,'and 	so 	may 	be 	used 	without 	it.
We 	therefore 	recommend 	that' "the 	Court 	modify 	proposed 	Rule
7.1(c) 	to 	require 	only 	that 	an 	attorney 	have 	a 	reasonable 	basis
for 	any 	material, 	objective 	claims, 	and 	that 	such 	claims 	be
t~thful and 	nondeceptive. 17
Prooosed 	Rule 	7.2(a): 	Permissi~le Advertisi~cr Media
Attorneys 	may 	interpret 	the 	list 	of 	media 	in 	proposed 	Rule
7.2(a) 	as 	exclusive 	and 	conclude 	that 	advertising 	in 	media 	not
listed 	is 	prohibited. 	The 	listing 	of 	specific 	media 	that 	may 	~e
used 	in 	advertising 	could 	also 	discourage 	innovation 	in 	ways 	not
,intended 	by 	the 	Cour't., 	especially 	since 	the 	ph::'~se "pu~l ic 	media"
is 	ambiguous. 	For 	example, 	the 	rule 	might 	be 	inte::,preted 	to
prohi~it 	sponsorship 	of 	museum 	exhibits. 	In 	addition " 	the
specificity 	of 	the 	rule 	fails 	to 	anticipate 	changing
technologies. 	Thus, 	for 	example, 	the 	rule 	m~ght be 	interpreted
to 	exclude 	advertising 	in 	compu't.er bulletin 	boards, 	on-line
directories, 	or 	similar media 	that 	may 	play 	inc::,easingly
, 5 ( 	.. . 	d)	-: 	•.• con ... J.nue
revised.
16 	C.F.R. 	l4.15(c) (2) 	(1966).
16 	See 	FTC 	Policy 	Statement 	Rega::'ding 	Advertising
Su~stantiation, 104 	F.T.C. 	839 	(1984).
17 	Rule 	3.135(5) (a) (iii) 	contains 	a 	p::,ovision 	similar 	to
proposed 	Rule 	7.l(c) 	and 	we 	suggest 	that 	this 	po::'~ion of 	the
exis't.ing 	~~le be 	deleted.
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Ho~o~able 	~~~e~~ 	F. 	S~ep~er.s--?a;e 13
important 	roles 	as 	elec~ronic communication 	becomes 	more
common. 	The~efore, we 	recommend 	that 	the 	Court 	delete 	proposeq
Rule 	7.2(a) .18
Rule 	3.135 (6) (a) (i): 	Permiss ibl e 	Contents 	of 	Adver': isements
Rule 	3.135(6) (a) (i) 	specifies 	the 	types 	of 	information 	that
attorneys 	may 	include 	in 	an 	advertisement. 	Rule 	3.135(6) (b)
provides 	that 	an 	attorney 	who 	wants 	to 	include 	information 	not
specified 	in 	sUbparagraph 	(a) (i) 	must 	send 	a 	copy 	of 	the
advertisement 	to 	the 	Attorneys 	Advertising 	Commission 	thirty 	days
in 	advance 	of 	dissemination. 	The 	ABA 	has 	recognized 	the 	dange~
of 	imposing 	such 	restrictions: 	limiting 	the 	types 	of 	information
that 	may 	be 	advertised 	would 	impede 	the 	flow 	of 	information 	about
legal 	services 	to 	many 	sectqrs 	of 	the 	public 	and 	"assumes 	that
the 	bar 	can 	accurately 	forecast 	the 	kind 	of 	information 	that 	the
public 	would 	regard 	as 	relevant.,,19 	We 	share 	the 	ABA'S 	concern
;and 	believe 	that 	only 	false 	and 	deceptive 	advertising 	should 	be
prohibited. 	Nor 	is 	it 	clear 	that 	the 	exception 	provided 	in
paragraph 	(b) 	is 	adequate 	to 	overcome 	the 	deficiencies 	of 	this
rule. 	The 	exception 	contains 	an 	advance 	notice 	requirement 	that
is 	likely 	to 	delay 	the 	dissemination 	of 	information 	and 	reduce
lawyers' 	abili~y to 	compete 	through 	a¢vertising. 	Because, of 	the
built-in 	delay 	in 	securing 	approval 	and 	the 	uncertainty 	of
approval, 	the 	exception 	may 	be 	insufficient 	to 	overcome 	the
rule's 	effect 	of 	discouraging 	attorneys 	from 	providing
information 	to 	consumers, 	other 	than 	that 	contained 	in 	the
categories 	specified 	in 	subparagraph 	(a) (i). 	Accordingly, 	we
recommend 	that 	the 	Court 	delete 	Rule 	3.135(6).
18 	We 	agree 	with 	the 	Bar's 	decision 	not 	to 	propose 	that 	the
Court 	adopt 	ABA Model 	Rule 	7.2(b) 	and 	(d). 	ABA 	Model 	Rule 	7.2(b)'
! sta~es 	that 	a 	"copy 	or 	recording 	of 	an 	advertisement 	or 	wri~ten
co~~unication shall 	be 	kept 	for 	two 	years 	after 	its 	last
dissemination 	along 	with 	a 	record 	of 	when 	and 	where 	it 	was 	used."
~~is recordkeeping 	requirement 	would 	entail 	administrative 	costs
and 	thus 	might 	discourage 	attorney 	advertising. 	ABA Model 	Rule
7.2(d) 	requires 	that 	lawyers 	include 	in 	their 	advertisements 	"t~e
name 	of 	at 	least 	one 	lawyer 	responsible 	for 	its 	content."
Inclusion 	of 	a 	lawyer's 	name 	might 	distrac~ ~onsumers' 	atte~~ion
from 	the 	informa~ion ~~e 	lawyer 	or 	firm 	wants 	to 	communicate 	in
the 	advertisement 	and 	thus 	reduce 	the 	effectiveness 	of 	the
advertisement.
19 	Comment 	to 	A3A Model 	Rule 	of 	Professional 	Conduct 	7.2
(Aug. 	2, 	1983).
Complete printed PDF page 13
Eono~able 	Robe~~ 	F. 	Stephe~s--?age 14
Rule 	3.!35(~): 	Un:~i; a~d 	Sel:-Lau~atc;v Clair.s
Rule 	3.135(~) 	p~ohibits at~or~eys f~o~ including 	in 	their
adve~tisements "a 	s~atement o~ claim which 	is 	false 	or 	tends 	to
be 	misleading, 	deceptive, 	or 	unfair, 	or 	which 	is 	self-laudatory
rather 	than 	designed 	to 	inform 	the 	pUblic."
We 	do 	not 	question 	the 	need 	to 	prohibit 	the 	use 	of 	"unfair"
statements 	or 	claims 	in 	attorney 	advertisements. 	In 	fact,
Section 	Five 	of 	the 	Federal 	Trade 	Commission 	Act 	prohibits
"(u)nfair methods 	of 	competition ... 	and 	unfair. 	. 	acts 	or
practices .... ,,20 	We 	are 	concerned, 	however, 	that 	without 	an
explanation 	of 	what 	constitutes 	an 	"unfair" 	statement 	or 	claim,
the 	term 	"unfair" 	might 	be 	interpreted 	by 	some 	attorneys 	to
prohibit 	advertising 	that 	poses 	little 	risk 	of 	consumer 	injury.
In 	a 	statement 	of 	policy, 	the 	Federal 	Trade 	Commission 	set 	forth
a 	test 	for 	determining 	whether 	a 	consumer 	injury 	is 	legally
"un~air."21 	To 	justify 	a 	finding 	of 	unfairness, 	the 	injury 	must:
(1) 	-be 	s-..:bstantia1 22 ; 	(2) 	not 	be 	outweighed 	by 	any 	countervailing
benefits 	to 	consumers 	or 	competition 	that 	the 	practice
produces 23 ; 	and 	(3) 	be 	an 	injury 	that 	consume~s themselves 	could
not 	reasonably 	have 	avoided.~~ 	We 	suggest 	that 	the 	Court
consider 	this 	interp~etation of 	"unfair" 	and 	ensu~e that 	the
20 	15 	U.S.C. 	§ 	45(a) (1).
21 	Letter 	from 	Federal 	Trade 	Commission 	to 	Senators 	Wendell
H. 	Ford 	and 	John 	C. 	Danforth 	5 	(Dec. 	17, 	1980).
22 	In 	most 	cases, 	a 	substantial 	inju~y involves 	moneta~y
'harm, 	as 	when 	selle~s coerce 	consumers 	into 	purchasing 	unwanted
goods 	or 	services. 	"Emotional 	impact 	and 	other 	more 	SUbjective
types 	of 	ha~, 	on 	the 	other hand, 	will 	not 	ordinarily 	make 	a
practice 	u~fair. 	ThUS, 	for 	example, 	the 	Commission 	will 	not 	seek
to 	ban 	an 	advertisement 	merely 	because 	it 	offends 	the 	tastes 	or
social 	beliefs 	of 	some 	viewers .... " 	rd. 	at 	5-6.
23 	Most 	business 	oractices 	involve 	a 	mixture 	of 	costs 	and
benefits 	to 	purchasers.· 	The 	Commission 	recognizes 	these
tradeoffs 	and 	will 	not 	find 	a 	practice 	unfair 	unless 	its 	net
effects 	are 	injurious. 	The 	cor.~ission also 	considers 	the 	costs
that 	a 	remedy 	would 	entail. 	rd. 	at 	6.
24 	Normally 	consumers' 	purchase 	decisions 	control 	the
market 	without 	regulatory 	intervention. 	Certain 	types 	of 	sales
techniqu~s, however, 	may 	prevent 	consume~s from 	effectively
making 	their 	own 	decisions, 	in 	which 	case 	corrective 	action 	may
be 	neoessary. 	Id. 	at 	7.
Complete printed PDF page 14
commenta~y 	clea~ly 	conveys 	to 	lawye~s what 	advertising 	is
permitted.
The 	prohibition 	of 	self-laudatory 	advertising 	may 	p~eclude
virtually 	all 	supe~iority claims. 	This 	prohibition 	~ay also
~est~ict many 	forms 	of 	comparative 	advertising, 	which, 	as 	we
stated 	above 	in 	our 	discussion 	of 	proposed 	Rule 	7.1 	(c), 	can 	be 	a
highly 	effective 	means 	of 	informing 	a~d attracting 	clients. 	When
at~orneys 	cannot 	truthfully 	compare 	the 	attributes 	of 	their
se~ices to 	those 	of 	their 	competitors, 	their 	incentive 	to
improve 	their 	se~ices or 	reduce 	their 	prices 	is 	likely 	to
decrease.
Bans 	on 	self-laudatory 	claims 	are 	particularly 	likely 	to
injure 	competition 	and 	consumers 	when 	they 	are 	interpreted 	to
prohibit 	a 	wide 	range 	of 	factual 	statements. 	For 	example,
virtually 	all 	statements 	about 	an 	attorney's 	qualifications,
experience, 	or 	performance 	can 	be 	considered 	to 	be 	self-
laUdatory. 	Bans 	on 	all· such 	claims 	would 	make 	it 	very 	difficult
for 	attorneys 	to 	provide 	consumers 	with 	truthful 	information
about 	their 	services.
By 	prohibiting. attorneys 	from 	engaging 	in 	advertising 	that
is 	"self-laud~tory rather 	than 	designed 	to 	inform 	the 	public,"
Rule 	3.135(4) 	could 	c~ill attorney 	advertising. 	!t may 	be
difficult 	for 	attorneys 	to 	predict 	what 	statements 	or 	claims 	the
Court 	might 	regard 	as 	informative 	rather 	than 	self-~audatory.
Attorneys 	may 	interpret 	the 	rule 	to 	pro~ibit advertising 	of 	any
category 	of 	information 	not 	listed 	in 	Rule 	3.135(6) (a) (i).
For 	these 	reasor-s, 	we 	urge 	the 	Court 	to 	amend 	Rule 	3.l35(~)
to 	eliminate 	the 	restrictions 	on 	self-laudatory 	statements 	and
the 	requirement 	that 	sta~ements be 	designed 	to 'inform 	the 	pU~lic,
and 	to 	clarify 	~~at s~atements or 	claims 	the 	Court 	considers 	to
be 	"unfair."
?rooosed 	Rule 	7.2(b): 	La~~er Referral 	Services
Prooosed 	Rule 	7.2(b) 	appears 	to 	preclude 	the 	use 	of 	for-
prOfit 	lawyer 	referral 	se~ices or 	other 	legal 	service
organizations. 	such 	organizations 	enable 	law~ers to 	pool 	their
advertising 	resources 	while 	mai~taining independent 	practices.
Consumers 	in 	need 	of 	legal 	advice 	on 	a 	particular 	sUbj~~t may
benefit 	from 	the 	knowledge 	such 	se~ices possess 	abou~ ~he
parti~ular expertise 	of 	each 	member 	attorney. 	For-profit
referral 	se~ices may 	be 	able 	to 	provide 	more 	useful 	info~ation
to 	consumers 	than 	no~profit bar 	a5socia~ion referral 	services,
which 	may 	be 	o~liged ~o give 	referrals 	on 	an 	equal 	basis 	to 	all
at-torneys.
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Propose~ 	Rule 	7.2(b) 	also 	appears 	to 	prohibit 	the 	paymen~ of
fees 	to 	lawyers 	who 	refer 	prospective 	clients 	to 	other 	lawyers.
As 	we 	mentioned 	above 	in 	our 	discussion 	of 	proposed 	Rule 	l.5(e),
such 	a 	prohibition 	could 	have 	substantial 	anticompetitive
ef~ects. 	For 	these 	reasons, 	we 	urge 	the 	Court 	to 	delete 	the
requirements 	in 	proposed 	Rule 	7.2(b) 	that 	lawyers 	not 	pay
referral 	fees 	~o 	other 	lawyers, 	and 	that 	lawyer 	referral 	services
and 	similar 	legal 	service 	organizations 	be 	not-for-profit.
Prooosed 	Rule 	7.3: 	Direct 	Contact 	with 	Prosoec~ive Clients
Proposed 	Rule 	7.3 	would 	prohibit 	virtuall y 25 	all 	forms 	of
direct 	client 	solicitation 	because, 	according 	to 	the 	comment 	to
the 	proposed 	rule, 	th~re is 	a 	"potential 	for 	abuse 	inherent 	in
direct 	solicitation."..:: 6 	We j::)elieve 	that 	solicitation 	can 	provide
consumers 	with 	helpful 	informa~ion about 	the 	na~ure and
availability 	of 	legal 	services, 	and 	that 	any 	potential 	abuses 	can
be 	ef£ectively 	prevented 	through 	more 	limited 	and 	specific 	.
regUlatory 	provisions. 	We 	urge 	the 	Court, 	therefore, 	to 	modify
orooosed 	Rule 	7.3 	and 	adoot 	more 'limited 	restric~ions on
~ollcitation. 	.
Written 	co~unications from 	lawyers 	may 	provide 	useful
information 	to 	prospective 	clients. 	For 	example, 	by 	targeting
let~ers to 	a 	particular 	audience, 	the 	lawyer 	can 	provide
information 	to 	those 	consumers 	who 	are 	most 	likely 	to 	need 	legal
services 	and 	to 	benefit 	from 	information 	about 	what 	services 	are
available, 	Soencer 	v. 	Honorable 	Justices 	of 	the 	Suoreme 	Court 	of
?ennsvlva~~a, 579 	F. 	Supp. 	880, 	891 	(~.D. 	Pa. 	198~), 	aff'd 	mem.,
760 	F.2d 	261 	(3d 	eire 	1985), 	and 	who 	may 	need 	to 	have 	a 	lawyer
take 	action 	expeditiously 	on 	their 	behalf. 	As 	the 	court 	stated
'in 	Koffler 	v. 	Joint 	Bar 	Association, 	51 	N.Y.2d 	140, 	1~6, 	412
N.~.2d 927, 	931, 	432 	N.Y.S.2d 	872, 	875-76 	(1980), 	cert. 	de~ied,
~50 U.S. 	1026 	(1981):
!
25 	The 	proposed 	rule
family 	members 	or 	of 	those
professional 	relationship,
significant 	motive 	for 	the
would 	not 	apply 	to 	the 	solicitation
with 	whom the 	lawyer 	had 	a 	prior
or 	where 	pec~niary gain 	was 	not 	a
,. 	' 	'	
SO_1.c~ 	a,-~on.
of
26 	We 	understand 	that 	t~e Court's 	order 	in 	Shaoero 	v.
Ke~tuckv Bar 	Association, 	86-SC-335-K3 	(Ky. 	March 	27, 	1987),
modified 	Rule 	3.135(5) (b) (i) 	as 	to 	mail 	advertising, 	using
language 	virtually 	identical 	to 	proposed 	~ule 7.3. 	Our 	comments
on 	proposed 	Rule 	7.3 	would 	~herefore apply 	e~~ally to 	the 	curre~~
rule.
Complete printed PDF page 16
Hcno~a~le 	~o~er~ 	F. 	Step~ens--?age 17
To 	o~tlaw t~e use 	of 	letters. 	. 	addressed
to 	t~ose most 	likely 	to 	be 	in 	r.eed 	of 	legal
services 	. 	. 	. 	ignores 	t~e strong 	societal
and 	individual 	interest 	in 	the 	free
dissemination 	of 	truthful 	price 	information
as 	a 	means 	of 	assuring 	infor:ned 	and 	reliable
decision 	making 	in 	our 	free 	enterprise 	system
The 	Seventh 	Circuit 	reasoned 	similarly 	in 	Adams 	v. 	Attornev
Recistration 	and 	Disciolinarv 	Commission, 	801 	F.2d 	968, 	973 	(7t~
Cir. 	~986), 	that 	"(p]rohibiting 	direct 	mailings 	to 	those 	who
might 	most 	desire 	and 	might 	most 	benefit 	from 	an 	attorney's
services 	~ns afoul 	of 	the 	concerns 	for 	an 	informed 	citizenry
t~at lay 	at 	the 	heart 	of 	Bat.es." 	Without 	truthful 	information,
consumers 	are 	not 	able 	to 	select 	the 	quality 	and 	price 	of 	legal"
services 	that 	best 	suit 	their 	needs.
Lawyers 	may 	be 	able 	to 	communicate 	with 	prospective 	clients
more 	efficiently 	by 	using 	targeted 	mailings 	and 	te~egrams than 	by
using 	other 	forms 	of 	advertising. 	Targeted mailing 	and 	telegrams
may 	be 	costly. 	Because 	they 	are 	sent 	to 	consumers 	who 	have 	the
greatest 	need 	for 	legal 	services, 	however, 	they 	are 	likely 	to
have 	a 	higher, response 	rate 	than 	other 	forms 	of 	advertising.
Consumers 	who 	choose 	to 	res~ond to 	such 	written 	communications
incur 	lower 	search 	costs 	because 	they 	need 	not 	contact 	numerous
~awyers to 	find 	one 	able 	to 	hancle 	a 	legal 	problem.
Targeted mail 	and 	telegraph 	advertising, 	as 	long 	as 	it 	is
truthful 	and 	nondeceptive, 	poses 	little 	danger 	of 	consumer 	harm.
Although 	it 	is 	not 	impossible, 	it 	is 	unlikely 	that 	written
communications 	will 	be 	intrusive 	or 	coercive, 	or 	involve
intimidation 	or 	duress. 	In 	~e Von 	Wiecren, 	63 	N.Y.2d 	163, 	170,
470 	N.~.2d 63o, 	841, 	481 	N.Y.S.2d 	40, 	43 	(1984), 	cert. 	denied 	sub
. nQID. 	Co~~ittee 	on 	Professional 	Standards 	v. 	Von 	Wie=en, 	105
S. 	ct. 	2701 	(1985); 	Koff~er, 	51 	N.Y.2d 	at 	149, 	412 	N.E.2d 	at 	933,
~32 	N.Y.S.2d 	at 	877-78. 	A letter 	or 	a 	telegram 	from 	an 	attorney
offering 	legal 	services 	requires 	no 	immediate 	response. 	The
cons~mer can 	give 	the 	communication 	careful 	consideration 	and
make 	a 	reasone~ decision 	about 	selecting 	a 	lawyer.
In-person 	contact 	may 	also 	provide 	consumers 	wit~ truthful,
nondeceotive 	information 	that 	will 	hel~ them 	select 	a 	laWYer. 	As
the 	Sup=eme 	Court 	stated 	in 	Ohralik 	v.·Ohio 	State 	Bar 	•
Association, 	436 	U.S. 	447, 	457 	(1978), 	in-person 	contacts 	can
convey 	information 	about 	t~e availability 	and 	terms 	of 	a 	lawyer's
legal 	services-and, 	in 	this 	respect, 	serve 	much 	t~e 	same 	f~nction
as 	ac.vertising.
Complete printed PDF page 17
?ono~able 	~~be~~ 	F. 	S~e~ta~s--Page 13
In-pe~son solicita~ion by 	lawyers 	in 	many 	ins~ances does 	not
involve 	coercion 	or 	the 	exercise 	of 	undue 	influence. 	Lawye~s
o~~en encounter 	prospec~ive clients 	at 	meetings 	of 	political 	a~d
business 	organizations 	and 	at 	social 	events .. Indeed, 	many
lawyers 	traditionally 	have 	built 	their 	law 	practices 	th~ough such
contacts. 	Under 	such 	circumstances, 	the 	possibility 	of 	abuse
seems 	minuscule. 	Similarly, 	lawyers 	present 	speeches 	and
seminars 	to 	prospective 	clients 	that 	establish 	goodwill 	and 	help
attendees 	to 	understand 	the 	law 	and 	identify 	situations 	in 	which
they 	might 	need 	a 	lawyer. 	Such 	personal 	contacts 	present 	little
risk 	of 	undue 	influence, 	bu~ do 	provide 	the 	benefit 	of 	enabling
prospective 	clients 	to 	assess 	the 	personal 	qualities 	of
attorneys. 	Since 	lay 	persons 	might 	find 	aggressive 	solicitation
to 	be 	offensive, 	lawyers 	have 	an 	incentive 	not 	to 	engage 	in 	such
solicitation.
We 	recognize 	that 	abuses 	may 	result 	from 	in-person
solicitation 	by 	lawyers. 	Injured 	or 	emotionally 	distressed
peop·le 	may 	be 	vulnerable 	to 	the 	exercise 	of 	u:1due 	influence 	when
face 	to 	face 	with 	a 	lawyer, 	as 	the 	Supreme 	Court 	reasoned 	in
Ohralik, 	436 	U.S. 	at 	465. 	We 	do 	not 	believe, 	however, 	that 	this
justifies 	a 	broad 	prohibition 	on 	all 	in-person 	solicitation. 	The
Federal 	Trade 	Commission 	considered 	the 	concerns 	that 	underlie
the 	Ohralik 	opinion 	when 	it 	d~cided American 	Medical 	Association,
94 	F.T.C. 	701 	(1979), 	aff'd, 	638 	F.2d 	443 	(2d 	Cir. 	1980), 	aff'd
memo 	bv 	an 	e~allv divided 	Court, 	455 	U.S. 	676 	(1982). 	After
weighing 	the 	possible 	harms 	and 	benefits 	to 	consumers, 	the 	FTC
ordered 	the 	AMA 	to 	cease 	and 	desist 	from 	banning 	all
solicitation, 	but 	permitted 	it 	to 	proscribe 	uninvited, 	in-person
solicitation 	of 	persons 	who, 	because 	of 	their 	particular
circumstances, 	are 	vulnerable 	to 	undue 	influence .. Telephone 	solicitation 	can 	also 	provide 	useful 	information,
and 	it 	may 	present 	less 	risk 	of 	harm 	to 	consumers 	than 	does 	in-
person 	solicitation. 	We 	recognize, 	of 	course, 	that 	telephone
sales 	can 	be 	used 	to 	injure 	consumers. 	Consequently, 	we 	would
not 	oppose 	a 	prohibition 	on 	false 	or 	deceptive 	telephone
solicitation. 	However, 	the 	use 	of 	the 	telephone 	to 	sell 	goods
and 	services 	has 	become 	relatively 	common 	in 	our 	society. 	It 	is
not 	clear 	to 	us 	that 	telephone 	solicitation 	by 	lawyers 	is
necessarily 	likely 	to 	harm 	consumers. 	For 	exarn;le, 	a 	lawyer 	may
call 	an 	acquaintance 	who 	owns 	a 	business 	and 	offer 	a 	legal
service, 	or 	a 	lawyer 	may 	hire 	a 	telephone 	marke~ing fi~ to 	call
all 	reside:1ts 	of 	a 	neighborhood 	a:1d 	offer 	t~e 	lawyer's 	services
to 	wri~e a 	will. 	In 	bo~h cases, 	consumers 	w~ll be 	~rovided
useful 	info~ation and 	the 	likelihood 	of 	ha~ seems· small.
Thus, 	we 	oppose 	t~e proposed 	broad 	~an on 	solicitation.
We 	would 	not 	oppose 	more 	limited 	restrictions 	O~ 	solicitatio~
di=e=~ed a~ 	ac~ual abuses. 	:o~ example, 	we 	believe 	i~ would 	be
Complete printed PDF page 18
app~opriate 	fo~ 	the 	Court 	to 	prohibit 	false 	or 	deceptive
solicitation~7 and 	solicitation 	directed 	to 	any 	person 	who 	has
made 	it 'known 	that 	he 	or 	she 	does 	not 	wish 	to 	receive
c~mmunications from 	the 	lawye~.
In 	addition, 	the 	Court 	may 	wish 	to 	prohibit 	solicitation
involving, 	in 	the 	language 	of 	the 	comment 	to 	proposed 	Rule 	7.3,
"undue 	influence, 	intimidation, 	(or] 	overreaching.,,28 	If 	the
Court 	concludes 	that 	such 	a 	prohibi~ion 	is 	necessary, 	we 	urge
that 	its 	te=ms 	be 	interpreted 	na~~owly. 	Some 	licensi~g boards
and 	p~ivate associations 	i~ 	othe~ p~ofessions have 	i~~erpreted
these 	or 	similar 	te~s broadly 	and 	have 	applied 	them 	t~ 	ban
solicitation 	under 	circumstances 	that 	pose 	no 	danger 	of 	abuse.
So 	long 	as 	these 	terms 	are 	interpreted 	fairly 	and 	objectively,
such 	a 	provision 	would 	adequ~tely pr~tect consumers 	and
simUltaneously 	allow 	them 	to 	receive 	helpful 	information 	about
legal 	se=vices.
Advertisincr 	of 	Fields 	of 	Practice
Prooosed 	Rule 	7.4
, 	Proposed 	Rule 	7.4 	and 	its 	accompanying 	comment 	would
prohibit 	the 	use 	of 	the 	te:=:m 	"specialist," 	or 	any 	othe::- 	claim
"implying" 	that 	a 	lawye::- 	is 	a 	specialist, 	unless 	the 	a:;torney
practices 	patent 	law 	or 	admiralty, 	or 	has 	been 	certified 	as 	a
specialist 	th::-ough 	a 	state 	certification 	p~og~am. 	While 	the
proposed 	=ule 	would 	allow 	a 	lawyer 	to 	indicate 	fields 	of
practice,29 	we 	believe 	that 	it 	is 	overly 	b~oad in 	restricting 	an
27 	P::-oposed 	Rule 	7.l(a) 	already 	prohibits 	false 	or
deceptive 	corr~unications.
28 	Different 	kinds 	of 	solicitation 	may 	present 	diffe~ent
'::-isks 	of 	abuse, 	so 	the 	proper 	interpretation 	of 	these 	te~s may
!depend 	on 	whether 	the 	solicitation 	at 	issue 	involves 	mail,
telephone, 	or 	in-person 	contact. 	As 	noted 	above, 	written
communication 	seems 	to 	present 	little 	danger 	of 	coercion 	or 	undue
influence. 	Telephone 	solicitation may 	present 	less 	potential 	for
abuse 	than 	in-person 	solicitation 	because 	telephone 	calls 	are
easier 	to 	te:=:minate 	tha~ face-to-face 	c~nversations.
29 	If 	the 	orooosed 	Guidelines 	f~r Certification 	of
S 	"'" 	. 	.." 	.. " 	k 	. 	"" 	d 	""h 	' d....' 	"" 	d	pec~a_~s~s 	~n 	~en_uc 	y 	a~e 	acop_e 	, 	~.ey wou_ 	~e 	~nco~pora_e
into 	proposed 	R~le 7.4(c). 	They would 	prOhibit 	an 	attor~ey who
is 	not 	Board 	certified 	f::-om 	advertising 	fields 	of 	practice
without 	includi~g a 	prescribed 	disclaimer, 	which 	might 	discourage
advertising 	of 	areas 	0= 	practice. 	We 	discuss 	the 	pr~posed
Guidelines 	below.
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Honorable 	Rober~ F. 	S~ephens--?age 20
attor~ey's ability 	to 	make 	truthful 	claims 	that 	he 	or 	she 	has
developed 	dis~inct skills 	in 	a 	specific 	area 	of 	the 	law. 	A true
statement 	that 	an 	attorney 	is 	a" member 	of 	an 	organization 	of
trial 	lawyers, 	for 	example, 	misht 	be 	outlawed 	as 	an 	implied 	claim
of 	specialization, 	even 	though 	it 	info~s consumers 	that 	the
attor~ey has 	sufficient 	interest 	in 	trial 	advocacy 	to 	joi~ such
an 	organization 	and 	has 	access 	to 	the 	organization's 	training 	and
materials. 	There 	are 	many 	ways 	to 	obtain 	expertise, 	and
information 	that 	an 	attorney 	has 	experience 	or 	special 	skills 	in
a 	particular 	field 	is 	clearly 	useful 	to 	consumers 	needing 	help 	in
that 	field. 	Furthermore, 	the 	use 	of 	the 	tenn 	"specialist" 	may 	be
the 	clearest, 	most 	efficient 	way 	to 	communicate 	such 	infonnation.
We 	do 	not 	believe 	that 	advertising 	oneself 	as 	a 	"specialist" 	in 	a
particular 	field 	of 	law 	implies-that 	the 	attorney 	is 	certified 	as
a 	specialist 	by 	the 	state. 	Nor 	do 	we 	believe 	that 	advertising 	as
a 	"specialist" 	would 	create 	an 	unjustified 	expectation 	about 	the
results that 	a 	lawyer 	can 	achieve, 	any 	more 	than 	identifying
oneself 	as 	a 	surgeon 	generates 	an 	expectation 	that 	every
procedure 	that 	the 	surgeon 	performs'will 	be 	a 	success.
Therefore, 	we 	recommend 	that 	the 	Court 	remove 	all 	prOhibitions
against 	truthful, 	nondeceptive 	claims, 	express 	or 	implied, 	that 	a
laWyer 	is 	a 	specialist .
.. Rule 	3.135 (5) (b) (ii) 30
Rule 	3.135(5) (b) (ii) 	requires 	all 	advertisements 	that 	list
or 	suggest 	areas 	of 	an 	attorney's 	practice 	to 	state, 	in 	print 	of
e~~al size 	and 	character 	to 	the 	print 	used 	in 	listing 	the 	areas
of 	practice, 	"This 	is 	an 	adve:.-tisen:ent. 	Kentucky 	law 	does 	not
ce:.-tify 	specialties 	of 	legal 	practice." 	This 	disclosu::e
requirement 	appears 	to 	in:pose 	unne=essa:.-y 	burdens 	on 	atto:.-neys
who 	wish 	to 	inform 	the 	pUblic 	of 	t~e a:.-eas 	of 	law 	i~ wh~ch they
prpvide 	se:.-vices, 	and 	might 	discourage 	lawye:.-s 	from 	advertising
their 	areas 	of 	practice. 	.
The 	rule 	is 	likely 	to 	reduce 	the 	effectiveness 	of
advertisemer.~s of 	areas 	of 	practice 	because 	the 	disclaime:.- 	might
c:.-eate 	a 	negative 	impression 	in 	consume:.-s' 	minds. 	The 	disclaimer
may 	suggest 	to 	some 	consumers 	that 	it 	is 	improper 	to 	mention 	a
oa:.-ticula:.- 	area 	of 	orac~ice in 	an 	adve:.-tiseme~t if 	the 	State 	of
Kentucky 	does 	not 	t~st the 	p:.-actitione:.-'s 	expe:.-tise. 	The
disclosure 	mig~~ also 	c::eate 	the 	erroneous 	impression 	that 	the
lawyer 	la=ks 	expertise 	in 	the 	area 	of 	law reentioned 	in 	the
adve:.-tisement. 	Consequently, 	some 	attorneys"may 	refrain 	from
30 	It 	is 	ou:.- 	uncerstanding 	that 	proposed 	Guideline 	VII., 	if
adopted, 	would 	supersede 	existing 	Rule 	3.135(5) (b) (ii), 	but 	we
ofter 	ou:.- 	views 	on 	the 	:.-ule 	because 	the 	Court 	may 	not 	adopt 	the
proposed 	Guidelines.
Complete printed PDF page 20
adve=~ising 	t=uthful, 	nondeceptive 	in:o~ation abo~t thei=
expe=~ise.
The 	rule 	also 	would 	increase 	the 	cost 	of 	advertising 	by
requi=ing 	lawyers 	to 	pu=chase 	additional 	adve=tising 	time 	and
space 	~o 	include 	~he p=esc=ibed 	statement. 	?ar~icularly for 	an
attorney 	with 	a 	limited 	adver~ising budget, 	such 	as 	one 	who 	can
afford 	only 	a 	two- 	or 	three-line 	advertisement 	in 	the 	classified
section 	of 	a 	daily 	newspape=, 	the 	additional 	costs 	imposed 	by 	the
~~le could 	be 	significant.
The 	conce=n 	expressed 	in 	subpa=agraph 	(5) (b) (ii) 	appears 	to
be 	that 	consume=s 	will 	mistake 	adve=tising 	claims 	concerning
a=eas 	of 	practice 	fo= 	claims 	of 	Boa=d 	certification 	of
specialties. 	We 	have 	no 	evidence 	indicating 	that 	a 	me=e
statement 	of 	area 	of 	p=actice 	connotes 	ce=tification 	cf
specialty. 	We 	believe 	it 	is 	undesirable 	to 	impose 	a 	disclosure
=equi=ement 	that 	may 	deter 	t~thful, nondeceptive 	advertising
absent 	evidence 	or 	a 	=easonable 	belief 	that 	advertising 	without
the 	disclosure 	is 	likely 	to 	mislead 	consume=s. 	We 	therefore
. recommend 	that 	the 	Cou=t 	delete. Rule 	3.135(5) (b) (ii).
P=coosed 	G~ideline VTI 3l
The 	proposed 	Guidelines 	for 	ce=tification 	of 	Specialists 	in
~entucky might 	disco~rage atto=neys 	from 	advertising 	their
experience 	or 	even 	tha 	fact 	that 	they 	offer 	services 	in 	a
particular 	field 	of 	law. 	Proposed 	Guideline 	VII.A 	p=ovides 	that
attorneys 	certified 	in 	a 	particular 	field 	of 	law 	by 	the 	sta~e's
Specialization 	commission 	may 	advertise 	"Soard 	Certi:ied 	as 	a
Specialist" 	i~ that 	a=ea, 	but 	that 	attor~eys not 	so 	certified 	by
the 	Commission 	who 	wish 	to 	advertise 	services 	in 	a 	particular
field 	of 	law must 	include 	in 	their 	advertisements 	a 	disclaime=
sta~i~g, 	"Not 	Soard 	Certi:ied 	as 	a 	specialist" 	in 	tha~ area. 	In
addition, 	proposed 	Guideline VII.B 	provides 	that, 	"[w)here 	the
'co~ission has 	not 	yet 	designated 	an 	area 	of 	law 	and 	has 	not 	yet
! certified 	attorneys 	in 	that 	a=ea, 	any 	attorney 	wishing 	to
advertise 	that 	he 	or 	she 	renders 	legal 	services 	in 	that 	area 	must
include 	in 	such 	advertising 	[the 	disclaimer] 	'Kentucky 	does 	not
presently 	certify 	specialists 	in 	'"
31 	We 	o::er 	our 	co~~ents only 	on 	proposed 	Guidelines 	:or
Certi:ication 	of 	Specialists 	in 	Kentucky 	VI! 	and 	IV.E, 	and 	do 	not
~ake a 	position 	on 	other 	aspects 	of 	the 	proposed 	Guidelines, 	such
as 	the 	merits 	of 	the 	certi:ication 	program.
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Eono=able 	rtcbe=~ .. 	Step~er.s--?age 22
The 	s~ated purpose 	of 	these 	guidelines 	is 	to 	"(lJi~it
misleading 	and 	deceptive 	adver-cising 	of 	legal 	services.,,32 	We
ag=ee 	that 	adve='Cising 	should 	not 	be 	false, 	~isleadi~g, or
deceptive. 	Clea=ly, 	it 	~ould be 	deceptive 	for 	an 	attorney 	to
advertise 	that 	he 	or 	she 	is 	"Board 	cer-cified ll 	in 	a 	field 	of 	la~
if 	no 	Board 	certification 	for 	that 	field 	exists, 	or 	if 	the
attorney 	has 	not 	obtained 	such 	Board 	certification. 	Advertising
of 	that 	sort, 	ho~eve=, ~ould be 	prohibited 	by 	proposed 	Rule
7.l(a). 	Absent 	evidence 	or 	a 	reasonable 	belief 	that 	consumers
~ould be 	misled 	by 	truthful 	advertisemen~s of 	areas 	of 	prac~ice,
it 	does 	not 	appear 	that 	any 	additional 	regUlation 	on 	special~y
advertising, 	such 	as 	one 	imposing 	disclosure 	requirements, 	is
necessary.
Advertising 	Board 	certLfication 	in 	a 	partiCUlar 	field 	of 	law
can 	provide 	consumers 	~ith beneficial 	information 	about
attorneys' 	special 	skills 	if 	certification 	requirements 	are
reasonably 	related 	to 	assuring 	p=oficiency 	in 	the 	SUbject 	area
certified. 	On 	the 	other hand, 	~hen attorneys 	~ho are 	not 	Board
certified 	are 	deterred 	by 	a 	re~~ired disclaimer 	from 	truthfully
advertising 	their 	training 	and 	skills, 	consumers 	~ill be 	dep=ived
of 	information 	to 	help 	them 	choose 	among 	qualified
practitioners. 3,3 	A statement 	in 	an 	advertisement 	of 	a 	field 	of
la~ that 	the 	advertising 	attc=ney 	is 	llnot 	Board 	certified 	as 	a
specialist ll 	has 	a 	negative 	connotation. 	Consumers 	could 	be 	led
t~.believe erroneously 	that 	that 	attorney 	is 	incompetent 	to
handle 	their 	legal 	needs 	in 	a 	partiCUlar 	field 	~hen the 	attorney
may 	actually 	have 	such 	expertise 	but merely 	has 	not 	completed 	the
certification 	procedures •. The 	potential 	consumer
misunderstanding 	engendered 	by 	this 	proposed 	guideline 	could, 	by
reducing 	the 	number 	of 	practitioners 	that 	the 	pUblic 	~ill
'patronize, 	lessen 	competition 	in 	fields 	for 	~hich Board
cer~ification is 	available, 	and 	could 	thereby 	raise 	legal
s.ervices 	costs 	in 	those 	sUbj ect 	areas.
Proposed 	Guideline 	VII.B 	requires 	attorneys 	who 	wish 	to
advertise 	that 	they 	render 	legal 	services 	in 	a 	partiCUlar 	field
for 	which 	no 	Board 	certification 	exists 	to 	include 	a 	statement 	in
their 	acvertisements ,that 	Kentucky 	does 	not 	presently 	certify
specialists 	in 	that 	field. 	As 	discussed 	with 	respect 	to 	the
32 	See 	Kentucky 	Bar Association 	Board 	of 	Governors,
Guidelines 	for 	Certification 	of 	Specialists 	in 	Kentucky 	2
(March 	13, 	1987).
33 	As 	we 	stated 	above 	in 	our 	discussion 	of 	Rule
3.135(5) (b) (ii), 	such 	disclosure 	require~ents also 	increase 	the
cost 	of 	advertising 	by 	~andating that 	lawyers 	purcr.ase 	additional
time 	and 	space 	to 	include 	the 	disclaimer.
Complete printed PDF page 22
similar 	disclaimer 	required 	by 	Rule 	3.135(5) (b) (ii), 	co~s~~ers
~igh~ be 	led 	~o believe 	erroneously 	that 	the 	lawyer 	lacks
exper~ise or 	should 	not 	list 	an 	area 	of 	practice 	for 	which 	there
is 	no 	cer~ification program. 	This 	disclaimer 	requirement 	could
ha~ consumers 	who 	need 	to 	obtain 	legal 	services 	in 	a 	particular
field 	by 	deterring 	attorneys 	from 	adver~ising an 	area 	of
prac~ice. 	For 	these 	reasons, 	we 	urge 	the 	Court 	to 	dele~e
proposed 	Guideline 	VII.A.2 	and 	B.
Prooosed 	Guideli~e IV.;: 	Li~:tatio~s on 	Soecialization
Proposed 	Guideline 	IV.E 	would 	provide 	that 	"[w]here 	a 	client
is 	referred 	by 	an 	attorney 	to 	a 	certified 	specialist 	for
representation 	in 	the 	specialist's 	area 	of 	law, 	the 	specialist
may 	not 	enlarge 	the 	scope 	o~ services 	beyond 	the 	area. 	The
specialist 	shall 	encourage 	the 	client 	to 	return 	to 	the 	referring
attorney 	for 	handling 	fu~ure legal 	needs 	or 	referral 	in 	another
area." 	We 	are 	concerned 	that 	this 	proposed 	guideline 	would
reduce 	competition 	between 	referring 	lawyers 	and 	certified
sp~cialists.
T~e proposed 	guideline 	would 	appear 	merely 	to 	protec~
referring 	attorneys 	from 	competi~ion and 	not 	to 	protec~ consumers
in 	any 	way. 	In 	fact, 	it 	would 	reduce 	consumer 	c~oice by
requiring 	the'specialist 	to 	s~eer the 	client 	~ack to 	the
referring 	lawyer. 	hccording 	to 	the 	proposed 	guideline, 	the
specialis~ is 	not 	supposed 	to 	offer 	services 	outside 	the
specialty 	even 	under 	circumstances 	in 	which 	~he 	specialist 	has
more 	time, 	resources, 	or ,expertise 	than 	the 	referring 	attorney 	to
perform 	the 	necessary 	legal 	services. 	Since 	consumers 	of 	legal
se=vices 	could 	~e ha~ed if 	proposed 	Guideline 	IV.E 	were 	ado?~ed,
we 	recommend 	that 	the 	Court 	delete 	i~.
Conclusion
Certain 	features 	of 	the 	proposed 	Kentucky 	Rules 	of
!Professional 	Conduct 	might 	injure 	consumers 	by 	imposing
unnecessa=y 	restric~ions on 	price 	competition, 	referrals 	and
associa~ions, efficient 	forms 	of 	practice, 	and 	dissemination 	of
info~ation about 	legal 	services. 	Rule 	3.135 	may 	prohibit 	the
dissemination 	of 	truthful, 	nondeceptive 	advertising. 	The
orooosed 	Guidelines 	miaht 	deorive 	consumers 	of 	useful 	informa~ion
~bo~~ at~orneys' exp~rfise a~d areas 	of 	prac~ice, 	and 	reduce
competition 	between 	referring 	attorneys 	and 	certified
specialists. 	We 	urge 	that 	the 	Court 	eliminate 	u~necessary
res~rictions on 	competition 	among 	attorneys 	by: 	(1) 	clarifying
in 	the 	cc:me~tary to 	proposed 	Rule 	1.5(a) 	tha~ only 	fees 	tha~ are
so 	high 	as 	to 	suggest 	a 	breac~ of 	fiduciary 	duty 	to 	the 	client
would 	be 	unreasonable; 	(2) 	deleting 	~ropcsed ~ule 	1.5(e) 	so 	as
not 	to 	discourage 	referrals 	and 	associatio~s of 	attorneys 	in
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Eo~orab~e 	Ro=e~~ 	•. 	S~ephe~s--?age 24
differe~t law 	fi=ms 	for 	particular 	cases; 	(3) 	elimina~ing the
rest=ic~ior.s in 	proposed 	Rule 	5.4 	on 	practice 	with 	nonlawyers,
and 	on 	lawyers 	influencing 	the 	professional 	judgment 	of 	other
lawyers; 	(4) 	amending 	proposed 	Rule 	7.1 	to 	clarify 	that 	tr~~hful,
nondeceptive 	endorsements 	and 	experience, 	success, 	and 	compariso~
claims 	are 	pe=mit~ed; 	(5) 	deleting 	proposed 	Rule 	7.2(a) 	to 	permit
advertising 	in 	any 	media; 	(6) 	deleting 	Rule 	3.135(6) (a) (i) 	to
allow 	attorneys 	to 	advertise 	all 	~ruthful, nondeceptive
in~o=mation; 	(7) 	amending 	Rule 	3.135(4) 	to 	elimina~e the
restrictions 	on 	the 	use 	of 	self-laudatory 	statements 	a~d the
recr..li::-ement 	that 	statements 	in 	advertisements 	be 	"informative,"
and 	clarifying 	what 	the 	Court 	interprets 	as 	"unfair";
(8) 	modifying 	proposed 	Rule 	7.2(b) 	to 	allow 	the 	payment 	of
refer::-al 	fees 	to 	attorneys 	and 	the 	use 	of 	for-profit 	referral
se=vices; 	(9) 	modifying 	proposed 	Rule 	7.3 	to 	remove 	the 	broad 	ban
en 	solicitation; 	(10) 	modifying 	proposed 	Rule 	7.4 	to 	allow
express 	and 	implied 	claims 	of 	specialty, 	and 	deleting 	Rule
3.1~5(5) (b) (2) 	and 	proposed 	Guideline VII.A.2 	and 	B of 	the
proposed 	Guidelines 	for 	Certification 	of 	Specialists 	in 	Kentucky
~o encourage 	specialty 	advertising; 	and 	(11) 	deleting 	proposed
Guideline 	IV.E 	so 	as 	not 	to 	discourage 	competition 	between 	Board
certified 	specialists 	and 	referring 	attorneys.
We 	hope 	th~t this 	letter 	is 	helpful 	in 	assessing 	how
particular 	rules 	and 	guidelines 	may 	rest::-ict 	competition 	and
injure 	consumers. 	We 	appreciate 	this 	opportunity 	to 	present 	our
views.
Respectfully 	submitted,
Jeffre 	I~J::~Director
Complete printed PDF page 24

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