What Disciplinary Action Can Be Taken Against a Lawyer for Improper Solicitation ?

In Florida Bar v. Scott, 197 So. 2d 518, 520 (Fla. 1967) (quoting State ex rel. Florida Bar v. Dawson, 111 So. 2d 427, 431 (Fla. 1959)), this Court found that direct solicitation by a lawyer is a "serious breach of the Canon of Ethics demanding severe treatment of the offending lawyer." In State ex rel. Florida Bar v. Dawson, 111 So. 2d 427, 431 (Fla. 1959), this Court noted that in solicitation cases, "the exact nature of the disciplinary action to be taken is a problem which must be resolved on the basis of the factual situation presented by each particular case." As a result, in the past the discipline imposed for improper attorney solicitation has varied from disbarment to public reprimand. See: Florida Bar v. Weinstein, 624 So. 2d 261 (Fla. 1993) (disbarment); Florida Bar v. Stafford, 542 So. 2d 1321 (Fla. 1989) (six-month suspension); Florida Bar v. Sawyer, 420 So. 2d 302 (Fla. 1982) (eighteen- month suspension); Florida Bar v. Gaer, 380 So. 2d 429 (Fla. 1980) (public reprimand); Florida Bar v. Curry, 211 So. 2d 169 (Fla. 1968) (six-month suspension); Florida Bar v. Abramson, 199 So. 2d 457 (Fla. 1967) (public reprimand); Scott (six- month probation); Florida Bar v. Britton, 181 So. 2d 161 (Fla. 1965) (three-month suspension); State ex rel. Florida Bar v. Swidler, 159 So. 2d 865 (Fla. 1964) (public reprimand); State ex rel. Florida Bar v. Bieley, 120 So. 2d 587 (Fla. 1960) (six-month suspension); Dawson (eighteen-month suspension); State ex rel. Florida Bar v. Murrell, 74 So. 2d 221 (Fla. 1954) (one-year minimum suspension).