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Florida Bar v. Brumbaugh

Supreme Court of Florida
355 So.2d 1186 (1978)


Marilyn Brumbaugh (defendant) operated a business in Florida called Marilyn’s Secretarial Service, in which she performed typing services for do-it-yourself divorces, wills, resumes, and bankruptcies. Brumbaugh, who was not licensed to practice law, prepared legal documents for her customers in uncontested marriage dissolutions, and advised the customers regarding the costs and procedures that needed to be followed in order to obtain marriage dissolution. Brumbaugh charged her clients $50 for her services. Brumbaugh did not provide her customers with blank forms, but typed the documents herself after obtaining information from her customers. The Florida Bar (plaintiff) filed a petition charging Brumbaugh with engaging in the unauthorized practice of law, and sought an injunction prohibiting Brumbaugh from engaging in the allegedly unlawful acts. A referee appointed by the Supreme Court of Florida determined that Brumbaugh had engaged in the unauthorized practice of law. Brumbaugh objected to the referee’s findings, arguing that her civil rights had been violated and that she had been denied the right to make an honest living.

Rule of Law


Holding and Reasoning (Per Curiam)

Concurrence (Karl, J.)

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