The Florida Bar v. Elizabeth Hidalgo

• Court: Supreme Court of Florida
• Decided: July 2, 2026
• Docket: SC2025-0636
• Status: Published

Opinion

Supreme Court of Florida THURSDAY, JULY 2, 2026

The Florida Bar, SC2025-0636 Petitioner(s) Lower Tribunal No(s).: v. 20244074(11D)

Elizabeth Hidalgo, Respondent(s)

The uncontested report of the referee and plea agreement are

approved and Respondent Elizabeth Hidalgo is found guilty of

indirect criminal contempt for violating previous orders of this

Court. See Fla. Bar v. Hidalgo, 888 So. 2d 624 (Fla. 2004); Fla. Bar

v. Hidalgo, 139 So. 3d 888 (Fla. 2014); Fla. Bar v. Hidalgo, No.

SC2021-1264, 2021 WL 4317401 (Fla. Sep. 23, 2021). Respondent

is placed on probation and GPS monitoring for five months subject

to the probationary supervision of the Advocate Program or similar

program and must pay the costs associated with the probation and

GPS monitoring to the Advocate Program, under the terms and

conditions set forth in the report and plea agreement.

As a condition of probation, Respondent is sentenced to five

months in the Miami-Dade County Jail. However, the jail sentence CASE NO.: SC2025-0636 Page Two

shall be suspended pending completion of probation and GPS

monitoring, including abiding by all of the conditions of probation

as specified in the report and plea agreement.

Respondent shall not engage in the unlicensed practice of law

and the orders dated October 28, 2004, April 15, 2014, and

September 23, 2021, enjoining Respondent from engaging in the

unlicensed practice of law in Florida shall continue in their present

form. See Hidalgo, 888 So. 2d at 624; Hidalgo, 139 So. 3d at 888;

Hidalgo, 2021 WL 4317401, at *1. Respondent is directed to

comply with all other terms and conditions of the report and plea

agreement.

Judgment is entered for The Florida Bar, 651 East Jefferson

Street, Tallahassee, Florida 32399-2300, for recovery of costs from

Elizabeth Hidalgo in the amount of $1,692.71, for which sum let

execution issue.

COURIEL, C.J., and LABARGA, MUÑIZ, GROSSHANS, FRANCIS, and SASSO, JJ., concur. TANENBAUM, J., dissents with an opinion.

NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED. CASE NO.: SC2025-0636 Page Three

TANENBAUM, J., dissenting.

We have exclusive jurisdiction “to regulate the admission of

persons to the practice of law and the discipline of persons

admitted.” Art. V, § 15, Fla. Const. This administrative authority

extends only to the privilege being regulated. That means a person

is subject to this court’s regulatory authority at all only if he or she

applies to be admitted to practice law or in fact has been admitted

to practice law. This court’s administrative authority—which is an

extraordinary grant in the first place—can go no further than the

constitution’s text allows. The respondent is not a “person[]

admitted” to the practice of law, so she is not subject to this court’s

otherwise limited regulatory power. Id. Moreover, this court’s

contempt power is inherent in, and necessary to, the exercise of its

judicial power, but the court does not exercise judicial power in its

administrative capacity.

The Legislature, vested with the State’s legislative power, has

the exclusive authority to regulate the unlicensed practice of law,

and it has enacted a statute that makes it a third-degree felony to CASE NO.: SC2025-0636 Page Four

do so. See § 454.23, Fla. Stat. The respondent remains subject to

prosecution in a criminal proceeding that comports with the usual

constitutional protections. The order being entered in this case

exceeds the constitutional bounds of this court’s authority.

A True Copy Test:

SC2025-0636 7/2/2026

SO

Served:

HON. ROSA DE LA CARIDAD FIGAROLA JACQUELYN PLASNER NEEDELMAN JEFFREY TODD PICKER ROSIE CORDERO-STUTZ, SHERIFF (FOR SERVICE ON MATTHEW ERIC LADD AND EDWARD TAPANES)