People v. California Protective Corp

In People v. California Protective Corp. (1926) 76 Cal. App 354, the entity was incorporated for the purpose of " 'collecting debts due to its members or clients. . . . employing attorneys for its said members or clients, and . . . paying for such legal services for and on behalf of its said members or clients.' " (California Protective, supra, 76 Cal. App.. at p. 358.) Its clientele paid yearly fees for the services of lawyers to, among other things, give " 'legal advice and consultation on all business, personal and private matters at the attorney's office.' " (Id. at p. 359.) The court followed Merchants Protective and concluded the corporation was unquestionably engaged in the unlawful practice of law. (Id. at p. 360.) It reasoned: "It is true that individuals who are duly licensed members of the bar may 'lawfully' associate themselves in any unincorporated form of association, such as a partnership, for the practice of law. But such individuals may not associate themselves for the practice of law under the aegis of a corporation. Though all the directors and officers of the corporation be duly licensed members of the legal profession, the practice of law by the corporation would be illegal nevertheless. At any time those directors and officers, by death or by the transfer of their shares, might be succeeded by laymen none of whom possessed the right to practice law." (Id. at pp. 360-361.)