The Florida Bar v. Elizabeth Hidalgo
The Florida Supreme Court approved an uncontested referee report and plea agreement finding Hidalgo guilty of indirect criminal contempt for violating prior orders enjoining her from the unlicensed practice of law, imposing probation with a suspended jail sentence. Justice Tanenbaum dissented, arguing that the Court's constitutional authority over the practice of law reaches only persons admitted or seeking admission and that unlicensed practice is a matter for legislative criminal prosecution.
Key facts
- Elizabeth Hidalgo had been enjoined from engaging in the unlicensed practice of law in Florida by prior Supreme Court orders entered in 2004, 2014, and 2021.
- The Florida Bar sought to hold her in indirect criminal contempt for violating those injunctions.
- +1 more key fact with a free trial
Holdings
- The Florida Supreme Court may enforce its prior injunctions against the unlicensed practice of law through indirect criminal contempt, approving an uncontested referee report and plea…
Why it matters
For professional-responsibility practitioners, the decision reaffirms that the Court will enforce unlicensed-practice-of-law injunctions through criminal contempt backed by a suspended jail sentence. Justice Tanenbaum's… — full analysis with a trial
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