Chicago Bar Association v. Quinlan and Tyson, Inc.
Illinois Supreme Court
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.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,600 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.