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  • Chicago Bar Association v. Quinlan and Tyson…Chicago Bar Association v. Quinlan and Tyson, Inc.
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Chicago Bar Association v. Quinlan and Tyson, Inc.

Supreme Court of Illinois
214 N.E.2d 771 (1966)


Quinlan and Tyson, Inc. (defendant) employs licensed real estate brokers and salesmen who, during the course of their duties, prepare offers to purchase property, contracts of purchase and sale, deeds, and other instruments used to clear and transfer title. The documents originate as standard forms initially drawn up by licensed attorneys, which the brokers complete by filling in with relevant facts and information about the parties. The Chicago Bar Association (the association) (plaintiff) brought suit to enjoin Quinlan and Tyson from continuing this practice, contending that such actions constituted the unauthorized practice of law by individuals who are not licensed attorneys. The trial court agreed with the association, except that it permitted Quinlan and Tyson to fill in offer for purchase forms, which the court determined were a necessary component of Quinlan and Tyson’s business. The appellate court reversed the exception, concluding that none of the activities could be performed by non-lawyers. Quinlan and Tyson appealed, contending that their filling in of standardized forms is a simple task requiring only ordinary business intelligence.

Rule of Law


Holding and Reasoning (Per curiam)

Dissent (Underwood, J.)

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