FLBAR April 4, 1968

Can a lawyer display both an LL.B. and a J.D. diploma when the J.D. was issued as a substitute for the LL.B.?

Short answer: The opinion concluded that it would be improper for a lawyer to display both an LL.B. diploma and a J.D. diploma when the J.D. was granted as a substitution for the LL.B., because doing so would tend to give the false impression that the lawyer earned two separate degrees.

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This page answers the general question as of 1968. Ezel answers yours: whether it's allowed on your facts, under the current Florida Rules of Professional Conduct, with citations.

Currency note: this opinion is from 1968
Subsequent statutory amendments, court decisions, or later opinions or rule amendments may have changed the analysis. Treat this page as historical context, not current legal advice. Verify current law before relying on any specific rule, deadline, or remedy mentioned here.
Disclaimer: Advisory only. Not binding precedent.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official ethics opinion. The original opinion (linked on this page as a PDF) is the authoritative source for any reliance.
View original ethics opinion (PDF)

Plain-English summary

A lawyer asked whether it was unethical to display both an LL.B. diploma and a J.D. diploma in his offices when the granting institution had issued the J.D. as a substitute for the LL.B. The committee understood that the institution did not require return of the LL.B. diploma before issuing the J.D. diploma.

The committee concluded that displaying both diplomas would violate Canon 27, not only because the second diploma was issued to replace the first, but more particularly because it would tend to give the false impression that the attorney had been awarded both degrees.

Currency note

This opinion was issued in 1968, before The Florida Bar's adoption of the 2006 revisions to the Rules of Professional Conduct, and before the 1977 Bates v. State Bar of Arizona decision reshaped lawyer-advertising restrictions. It applied the former Canon 27 on advertising and holding out. Communications about a lawyer's services, including false or misleading statements, are now addressed by the advertising rules at Rule 4-7.13. Treat this page as historical context, not current guidance. Verify against the current rules before relying on any specific requirement mentioned here.

Common questions

Q: Can a lawyer hang both degree diplomas when one replaced the other?

A: Under this opinion, no. The committee found that displaying both an LL.B. and a substitute J.D. diploma would violate Canon 27 because it would tend to give the false impression that the lawyer had earned two separate degrees.

Q: Why did the committee object?

A: The committee objected both because the J.D. was issued to replace the LL.B. and, more particularly, because displaying both would falsely suggest the lawyer held two distinct degrees.

Background and rules framework

The opinion applied the former Canon 27, which restricted how lawyers could hold themselves out to the public. The prohibition on false or misleading communications about a lawyer's qualifications is now addressed by the advertising rules of the Rules Regulating The Florida Bar, including Rule 4-7.13; the Model Rule analogue is Rule 7.1.

Citations and references

Rules of Professional Conduct:

  • Canon 27 [Canons of Professional Ethics; misleading-communication duties now in Rule 4-7.13]

See also

Source

Original opinion text

Reproduced from the official source for research purposes. The linked source is authoritative.

FLORIDA BAR ETHICS OPINION
OPINION 68-9
April 4, 1968
Advisory ethics opinions are not binding.
It would be improper for a lawyer to display in his offices both an LL.B. diploma and a J.D. diploma if the latter was granted as a substitution for the LL.B. diploma.
Canon: 27
Chairman MacDonald stated the opinion of the committee:
A member of The Florida Bar asks the following question:
Is it unethical for a member of The Florida Bar to display an LL.B. diploma and a J.D. diploma in his offices when the institution granting the degrees did so on the basis of substituting the J.D. diploma for the LL.B. degree diploma?
It is our understanding that the institution in question does not require the return of the diploma evidencing the award of the Bachelor of Laws degree before issuing the diploma evidencing the Juris Doctor degree.
It is our opinion that it would be a violation of Canon 27 for the lawyer publicly to display in his offices both diplomas, not only because the second diploma presumably was issued to replace the first one, but more particularly because it would tend to give a false impression that in fact the attorney had been awarded both degrees.

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