Can a lawyer display certificates for, or list, both an LLB and a JD when he earned only one law degree?

Plain-English summary

The Committee was asked whether it violates the Canons for an attorney to display certificates of both his LLB degree and his Juris Doctor degree when he earned only one degree in law, and whether it violates the Canons for such an attorney to list both the LLB and the JD when summarizing his academic background.

The Committee answered both questions in the affirmative. It explained that when an attorney has earned only one degree but displays two degrees in his office, or lists two degrees in summarizing his academic background, he is guilty of self-laudation in violation of Texas Canon 24. The Committee added that such conduct is misleading, because it would indicate that the attorney earned two degrees in law when he earned only one. The vote was 9-0.

Currency note

This opinion was issued in 1970, under the former Texas Canons of Ethics, which the Texas Disciplinary Rules of Professional Conduct replaced effective January 1, 1990. It also predates Bates v. State Bar of Arizona, 433 U.S. 350 (1977), which loosened categorical advertising restrictions; prohibitions on misleading communications were not eliminated by that decision. Misleading communications about a lawyer's qualifications are now governed by Texas Rule 7.01 and ABA Model Rule 7.1. Subsequent rule amendments or later opinions may have changed the analysis. Treat this page as historical context, not current guidance. Verify against current rules before relying on any specific rule, deadline, or requirement mentioned here.

Common questions

Q: May a lawyer display certificates for both an LLB and a JD if he earned only one law degree?

A: No. The Committee concluded that displaying two degrees when only one was earned is self-laudation in violation of Canon 24.

Q: May he list both degrees in summarizing his academic background?

A: No. The Committee answered this question in the affirmative as a violation, for the same reason: it is self-laudatory and misleading.

Q: Why is listing both degrees misleading?

A: The Committee said it would indicate the attorney earned two law degrees when he in fact earned only one.

Background and rules framework

The opinion interprets former Texas Canon 24, which barred self-laudatory and misleading communications. The modern analog is Texas Rule 7.01 and ABA Model Rule 7.1 (communications concerning a lawyer's services, including a lawyer's qualifications).

Citations and references

Rules of Professional Conduct:

• MR 7.1 (communications concerning a lawyer's services), as the modern analog
• Texas Canon 24 (former Texas Canons of Ethics)

See also

• TX Ethics Op. 354: Using the Title "Judge" on a Lawyer's Professional Card
• TX Ethics Op. 440: Specialization Claims on Firm Letterhead and Business Cards
• TX Ethics Op. 406: Letterhead Listing an Out-of-State Lawyer and CPA Credential

Source

• Landing page: https://www.legalethicstexas.com/resources/opinions/opinion-350/
• Original PDF: https://tcle-web.s3.amazonaws.com/public/documents/Opinion_350.pdf

Original opinion text

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

QUESTION PRESENTED

Is it a violation for an attorney to display certificates of his LLB degree and his Juris Doctor degree when he has earned only one degree in law ?
Is it a violation of the Canons of Ethics for such attorney to list both his LLB degree and his Juris Doctor degree when summarizing his academic background?

23 Baylor L. Rev. 892 (1972)

SOLICITATION - ADVERTISING - SELF-LAUDATION
An attorney who has received only one degree in law may not display certificates of his LLB degree and his Juris Doctor degree, and may not list both degrees when summarizing his academic background.

Canon 24

Both questions must be answered in the affirmative. When an attorney has earned only one degree but displays in his office two degrees or lists two degrees in summarizing his academic background, he is guilty of self-laudation in violation of Texas Canon 24. Further, such conduct is misleading since it would indicate that the attorney has in fact earned two degrees in law, when in fact he has only earned one degree. (9-0)

Tex. Comm. On Professional Ethics, Op. 350 (1970)