WSBA 1985

Can a lawyer use direct-mail advertising and offer free seminars to a retirement community to attract clients?

Short answer: The committee concluded that direct-mail advertising is permitted if it is not misleading or deceptive; it split 6 to 4 on a proposed free seminar for a retirement community, the majority allowing the offer so long as later contact with participants complied with DR 2-104.

Apply this to your situation

This page answers the general question as of 1985. Ezel answers yours: whether it's allowed on your facts, under the current rules of professional conduct in your state, with citations.

Currency note: this opinion is from 1985
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 Not binding precedent.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) is the authoritative source for any reliance.

Plain-English summary

The committee was asked about direct-mail advertising and about offering a free seminar to members of a retirement community as a way to attract clients. On the mailings, the committee concluded that direct-mail advertising is not prohibited, provided that it is not misleading or deceptive.

On the seminar, the committee split by a vote of 6 to 4 on whether the proposed free seminar might be misleading or deceptive. The majority concluded the lawyer could make the offer, provided that future contact with the seminar participants complied with the requirements of DR 2-104. The minority concluded that the offer was in fact designed to obtain business from the participants and therefore would violate DR 2-104.

Currency note

This opinion was issued under Washington's former Code of Professional Responsibility, which the Rules of Professional Conduct later replaced. It was issued in 1985, before the 2006 revisions to the Washington Rules of Professional Conduct. Subsequent rule amendments, later opinions, and court decisions on commercial speech 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 Treat this page as historical context, not current guidance.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: Was direct-mail advertising allowed under this opinion?

A: Yes. The committee concluded that direct-mail advertising is not prohibited, provided that it is not misleading or deceptive.

Q: Could a lawyer offer a free seminar to a retirement community to find clients?

A: The committee divided 6 to 4. The majority concluded the lawyer could make the offer, provided future contact with the seminar participants complied with DR 2-104; the minority concluded the offer was designed to obtain business and would violate DR 2-104.

Q: What was the dividing line in the committee's vote?

A: Whether the free-seminar offer was misleading or deceptive, and whether the lawyer's later contact with participants would meet DR 2-104. The majority focused on compliant follow-up contact; the minority viewed the offer itself as a means of obtaining business.

Background and rules framework

The opinion applies DR 2-104 of the Washington Code of Professional Responsibility then in force, which governed a lawyer's contact with prospective clients to whom unsolicited advice had been given. Both the majority and minority framed the seminar question around compliance with DR 2-104. The advertising and solicitation duties at issue are now addressed by Washington RPC 7.1 and RPC 7.3 and by Model Rules 7.1 and 7.3.

Citations and references

Rules of Professional Conduct:

  • DR 2-104 (former Washington Code of Professional Responsibility): contact with prospective clients following unsolicited advice (advertising and solicitation duties now addressed by RPC 7.1 / RPC 7.3 / Model Rules 7.1 and 7.3).

See also

Source

Original opinion text

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

Advisory Opinion: 847
Year Issued: 1985
RPC(s): DR 2-104
Subject: Direct mail advertising; providing free seminars to solicit clients

The Committee is of the opinion that direct mail advertising is not prohibited provided that it is not misleading or deceptive. The Committee was split, however, by a vote of 6 to 4, on whether your proposed offer to provide a free seminar to members of the retirement community might be misleading or deceptive. The majority was of the opinion that you could make such an offer, provided that your future contact with the seminar participants complied with the requirements of DR 2-104. The minority was of the opinion that the offer was in fact designed to obtain business from the seminar participants and therefore would violate DR 2-104.

[Editor's Note: The Code of Professional Responsibility was superseded by the Rules of Professional Conduct after this opinion was issued.]

Get today's answer for your situation

You just read a 1985 opinion on this question. Ezel checks the current rules of professional conduct in your state and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the rules it relies on.