Grievance Committee v. Trantolo

470 A.2d 235, 192 Conn. 27, 1984 Conn. LEXIS 499
Supreme Court of Connecticut·Decided January 3, 1984·No. 10774·Published·Cited by 6 cases

Opinion

Speziale, C. J.

This case involves the same parties as a case also decided this date. Grievance Committee [29]*29v. Trantolo, 192 Conn. 15, 470 A.2d 228 (1984). The defendants appeal from the judgment of the trial court holding the defendants in violation of the Code of Professional Responsibility and contend that their actions were constitutionally protected. Because we find that the defendants have violated no constitutionally permissible rule, we find error.

The case encompasses two separate incidents. On April 7,1978, the defendants, attorneys Joseph Tran-tolo and Vincent Trantolo, held an open house in connection with the opening of “The Law Clinic of Trantolo & Trantolo.” Printed announcements previously had been mailed to approximately twenty-five Hartford area realtors, at least some of whom had no professional or personal relationship with the defendants. The mailing included a brochure entitled “A Message to Our Clients” explaining the nature of the clinic, its method of operation, the types of matters that it handled, and a schedule of fees charged for certain specific kinds of legal services.

On May 1, 1978, the Trantolos published a notice in a Hartford area newspaper that prominently displayed the following quotation by John Locke: “The end of law is not to abolish or restrain, but to preserve and enlarge freedom; for in all the states of created beings capable of laws, where there is no law, there is no freedom.”1 The following appeared below the printed quotation: “The Law Clinic of Trantolo & Trantolo Salutes Law Day, May 1, 1978.”

On January 16,1981, the plaintiff filed a substituted complaint alleging professional misconduct by the [30]*30defendants.2 On April 22, 1981, the trial court found that the mailing of brochures and the invitation to an “open house” constituted solicitation in violation of Disciplinary Rule 2-103 (C)3 (hereinafter DR 2-103 (C)) and that the Law Day statement violated Disciplinary Rule 2-101 (B)4 (hereinafter DR 2-101 (B)) and Ethical Con[31]*31siderations 2-9 and 2-10.* ***5 The court imposed no disciplinary measures due to the uncertainty surrounding the propriety of attorney advertising at the time of the defendants’ actions and because it felt the Law Day statement was “an isolated incident.”

[32]*32The defendants appealed to this court claiming that their actions were constitutionally protected under the first amendment to the United States constitution and article first, § 4 of the Connecticut constitution.

I

Open House and Brochure

DR 2-103 (C) provides that “[a] lawyer shall not request a person or organization to recommend or promote the use of his services.” The trial court found “that the mailing of the announcement together with the brochure indicates that it was the intention of the senders that the recipient recommend or promote the use of their services within the meaning of the Disciplinary Rule.” Thus, the court concluded that the disciplinary rule prohibiting solicitation also encompasses and prohibits mailings to third parties.

It is well recognized that attorney advertising is commercial speech entitled to first amendment protection. In the Matter of R.M.J., 455 U.S. 191, 102 S. Ct. 929, 71 L. Ed. 2d 64 (1982); Ohralik v. Ohio State Bar Assn., 436 U.S. 447, 98 S. Ct. 1912, 56 L. Ed. 2d 444 (1978); Bates v. State Bar of Arizona, 433 U.S. 350, 97 S. Ct. 2691, 53 L. Ed. 2d 810, reh. denied, 434 U.S. 881, 98 S. Ct. 242, 54 L. Ed. 2d 164 (1977); see Grievance Committee v. Trantolo, supra. The United States Supreme Court has defined commercial speech as “expression related solely to the economic interests of the speaker and its audience.” Central Hudson Gas & Electric Corporation v. Public Service Commission of New York, 447 U.S. 557, 561, 100 S. Ct. 2343, 65 L. Ed. 2d 341 (1980). The plaintiff characterizes the mailings as solicitation; the defendants characterize the mailings as advertisements. “[A]ll advertising either implicitly or explicitly involves solicitation.” Koffler v. Joint Bar Assn., 51 N.Y.2d 140, 146, 412 N.E.2d 927 (1980). [33]*33Whether the instant mailing is characterized as an advertisement or as solicitation, it is commercial speech, and entitled to some protection, because it relates “to the economic interests of the speaker.” Central Hudson Gas & Electric Corporation v. Public Service Commission of New York, supra.

Although commercial speech enjoys the protection of the first amendment, the state may impose appropriate restrictions. The question before us is whether DR 2-103 (C), which the trial court held to be a blanket prohibition of mailed solicitation, is an appropriate restriction that passes constitutional muster. We hold that it is not.

A four part analysis determines the validity of state restrictions on commercial speech. In the Matter of R.M.J., supra, 203-204 n.15. The first part of the analysis is a threshold test that determines whether the commercial speech is entitled to any protection under the first amendment. First, the speech in question must concern lawful activity and not be misleading. Only if the speech passes this threshold test do we move on to the remaining parts of the analysis: second, the asserted governmental interest in regulating the speech must be substantial; third, the regulation must directly advance the governmental interest asserted; and fourth, the regulation must be narrowly drawn and must not be more extensive than is necessary to serve that interest. Central Hudson Gas & Electric Corporation v. Public Service Commission of New York, supra, 566.

In applying this analysis to the present case we note first that there has been no finding, nor does the record indicate, that the mailing of the brochure and open house announcement was unlawful or misleading. We conclude therefore that the mailing passes the threshold [34]*34test and is entitled to the protection accorded commercial speech. As to the second part of the analysis, concerning the governmental interest, the plaintiff asserted that the only purpose of the brochure and open house announcement would be to induce the realtors to recommend the Law Clinic of Trantolo & Trantolo to property sellers and buyers. The asserted governmental interests in the prohibition of mailing to such intermediaries are the preservation of the personal relationship between lawyer and client and the prevention of the evils of solicitation. The United States Supreme Court has recognized that these are substantial state interests and may be the basis for a ban on certain in-person solicitations.6 Ohralik v. Ohio State Bar Assn.,

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Grievance Committee v. Trantolo, 470 A.2d 235, 192 Conn. 27, 1984 Conn. LEXIS 499 (Colo. 1984).

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