The Florida Bar

Bar Issue Papers

Separation of Powers

On This Page
I. Issue
II. Bar Position
III. Background
IV. Bibliographic Sources

I. Issue

Independence of the judiciary (the third branch of government, co­equal to the executive and legislative branches) has been a cherished hallmark of our democratic republic. The judiciary balances and, where necessary, checks the power of the other branches. Judges, in order to render decisions based on law and not people, must be protected from the influences of partisan politics. However, less clear is the protection stemming from separation of powers extended to "officers of the court'' -- lawyers. From time to time in Florida, the suggestion is made to place disciplinary regulation of lawyers under the executive branch or to subject the practice of law to legislative control, such as limiting fees or disclosing information that could fall under attorney­client privilege.
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II. Bar Position

The Florida Bar has long maintained that this state's separation of powers doctrine precludes legislative entry into the regulation of lawyers. Regulation of the legal profession is a unique and proper power of the courts in the exclusive exercise of the court's judicial function -- certainly as long as Article V. Section 15 of the Florida Constitution remains intact. The Bar's formal legislative position on this issue has typically been expressed as opposition to "amendments to the Florida Constitution which would alter the authority of the Supreme Court of Florida to regulate the admission of persons to the practice of law or the discipline of persons admitted."
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III. Background

A. United States -- Separation of Powers

The U. S. Constitution defines the power of the three main branches of the federal government as legislative, executive and judicial.

The U.S. Constitution provides the framework for the exercise of power by the federal government. Although the document contains no express separation of powers provision, the constitution defines and allocates the power of the federal government among the legislative, executive, and judicial branches. The framers of the constitution divided the exercise of governmental power into three branches to prevent that power from concentrating in one body. Checks to balance the power of the other branches are expressly provided in the constitution creating an overlap of power among the branches. In this way, the power of each branch is limited by giving to an equal branch one facet of another's unique power. Using these checks, the three branches compete among themselves to keep a relative balance of power. Therefore, each branch's exercise of its type of power is not absolute. Under a literal interpretation of the structure created in the constitution, violation of the separation of powers doctrine occurs whenever the power of one branch is exercised by another branch without express authority in the Constitution.

The separation of the powers of government is a fundamental principle of every free and good government and is historically a part of both the state and federal constitutions. It is fundamental to the very existence and perpetuity of the American form of government and is one of the most important principles guaranteeing the liberty of the people and preventing the exercise of autocratic power.
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1. Legislative

U.S. Constitution Article I, Section 1: "All legislative powers herein granted shall be vested in a Congress of the United States, which shall consist of a Senate and House of Representatives." Section 8 of that article enumerates those powers which, among others, include: (1) to lay and collect taxes, excises, imports and duties, to pay the debts and provide for the common defense and general welfare; (2) to regulate commerce; (3) to establish uniform laws of bankruptcy; (4) to coin money and punish counterfeiting; (5) to establish post offices and post roads; (6) to constitute tribunals inferior to the supreme court; (7) to declare war; (8) to raise and support armies and to provide and maintain a Navy; (9) to make rules for the government; and (10) to make all laws which shall be necessary and proper for carrying into execution the legislative powers and all other powers vested by the constitution by the government of the United States or in any department or officer thereof.

2. Executive

U.S. Constitution Article II, Section 1: "The executive power shall be vested in a President of the United States of America." Article II, Sections 2 and 3 define those powers: (1) The president shall be commander­in­chief of the Army and Navy of the U.S., and of the militia of the states, when called into the actual service of the U.S.; (2) the president shall have power, by and with the advice and consent of the Senate, to make treaties; (3) the president shall have power to fill up all vacancies that may happen during the recess of the Senate, by granting commissions which shall expire at the end of their next session; and (4) the president shall from time to time give to the Congress information of the state of the union, and recommend to their consideration such measures as the president shall judge necessary and expedient; the president may, on extraordinary occasions, convene both houses or either of them.

3. Judicial

The U.S. Constitution Article III, Section 1 reads: "The judicial power of the United States shall be vested in one supreme court and in such inferior courts as the Congress may from time to time ordain and establish." Judicial power shall extend to: all cases, in law and equity, arising under this constitution, the laws of the United States, and treaties made, or which shall be made, under their authority; all cases affecting ambassadors, other public ministers and consuls; all cases of admiralty and maritime jurisdiction; controversies to which the United States shall be a party; controversies between two or more states; cases between a state and citizens of another state; cases between citizens of different states, cases between citizens of the same state claiming lands under the grants of different states, and between a state, or the citizens thereof, and foreign states, citizens or subjects. Judicial power also extends to all cases affecting ambassadors, other public ministers and consuls, and those in which a state shall be a party, the supreme court shall have original jurisdiction. The trial of all crimes, except in cases of impeachment, shall be by jury. Such trial shall be held in the state where the said crimes shall have been committed.
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B. Florida -- Separation of Powers

According to the State of Florida Constitution Article II, Section 3, the powers of the state government shall be divided into legislative, executive and judicial branches. No person belonging to one branch shall exercise any powers appertaining to either of the other branches unless expressly provided.

1. Legislative

Article III Section 1 of the Florida Constitution states that the "legislative power of the state shall be vested in a legislature of the State of Florida, consisting of a senate composed of one senator elected from each senatorial district and a house of representatives composed of one member elected from each representative district." The legislature has been described generally as the lawmaking branch of government. It also has the broad purpose of determining policies and programs and reviewing program performance.

Basically, the legislature is empowered to enact statutes that: levy and collect taxes; oversee professional licensing boards; ensure the public's health, safety and welfare; define crime and provide punishment for violations; build highways; regulate marriage and divorce; authorize establishment of cities. In addition, the legislature may also overturn the governor's veto, determine fiscal policies in the preparation of the General Appropriations Act and conduct formal investigations of alleged misconduct by government agencies and even private businesses.

2. Executive

Article IV, Section 1 states that the supreme executive power shall be vested in a governor who shall: be commander­in­chief of all military forces of the state not in active service of the United States. The governor shall take care that the laws be faithfully executed, commission all officers of the state and counties, and transact all necessary business with the officers of government. The governor may require information in writing from all executive or administrative state, county or municipal officers upon any subject relating to the duties of their respective offices; initiate judicial proceedings in the name of the state against any executive or administrative state, county or municipal officer to enforce compliance with any duty or restrain any unauthorized act; request in writing the opinion of the justices of the Supreme Court of Florida as to the interpretation of any portion of the state constitution upon any question affecting the governor's executive powers and duties; have power to call out the militia to preserve the public peace, execute the laws of the state, suppress insurrection, or repel invasion; and by message, at least once in each regular session, inform the legislature concerning the condition of the state, propose such reorganization of the executive department as will promote efficiency and economy, and recommend measures in the public interest.

Additionally, the governor prepares a recommended balanced budget to be submitted prior to the legislative session. The governor retains line item veto of the General Appropriations Act and has other veto power in order to nullify any legislative act found unacceptable.

3. Judicial

The third branch of state government, the judiciary, exists because of Article V, Section 1 of the Florida Constitution. The judicial department of the government is that branch: intended to interpret, construe, and apply the law; and charged with the declaration of what the law is, and its construction so far as it is written law. Section 1 states that the "judicial power shall be vested in a supreme court, district courts of appeal, circuit courts and county courts. No other courts may be established by the state, any political subdivision or any municipality. The legislature shall, by general law, divide the state into appellate court districts an judicial circuits following county lines. Commissions established by law, or administrative officers or bodies may be granted quasi­judicial power in matters connected with the functions of their offices. The legislature may establish by general law a civil traffic hearing officer system for the purpose of hearing civil traffic infractions.''
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a) Supreme Court -- Jurisdiction

  1. Shall have exclusive jurisdiction to regulate the admission of persons to the practice of law and the discipline of persons admitted;
  2. Shall hear appeals from final judgments of trial courts imposing the death penalty and from decisions of district courts of appeal declaring invalid a state statute or a provision of the state constitution;
  3. When provided by general law, shall hear appeals from final judgments entered in proceedings for the validation of bonds or certificates of indebtedness and shall review action of statewide agencies relating to rates or service of utilities providing electric, gas, or telephone service;
  4. May review any decision of a district court of appeal that expressly declares valid a state statute, or that expressly construes a provision of the state or federal constitution, or that expressly affects a class of constitutional or state officers, or that expressly and directly conflicts with a decision of another district court of appeal or of the supreme court on the same question of law;
  5. May review any decision of a district court of appeal that passes upon a question certified by it to be of great public importance, or that is certified by it to be in direct conflict with a decision of another district court of appeal;
  6. May review any order or judgment of a trial court certified by the district court of appeal in which an appeal is pending to be of great public importance, or to have a great effect on the proper administration of justice throughout the state, and certified to require immediate resolution by the supreme court;
  7. May review a question of law certified by the Supreme Court of the United States or a United States Court of Appeals which is determinative of the cause and for which there is no controlling precedent of the Supreme Court of Florida;
  8. May issue writs of prohibition to courts and all writs necessary to the complete exercise of its jurisdiction;
  9. May issue writs of mandamus and quo warranto to state officers and state agencies;
  10. May, or any justice may, issue writs of habeas corpus returnable before the supreme court or any justice, a district court of appeal or any judge thereof, or any circuit judge;
  11. Shall, when requested by the attorney general pursuant to the provisions of Section 10 of Article IV, render an advisory opinion of the justices, addressing issues as provided by general law.

b) District Courts of Appeal -- Jurisdiction

  1. District courts of appeal shall have jurisdiction to hear appeals, that may be taken as a matter of right, from final judgments or orders of trial courts, including those entered on review of administrative action, not directly appealable to the supreme court or a circuit court. They may review interlocutory orders in such cases to the extent provided by rules adopted by the supreme court;
  2. District courts of appeal shall have the power of direct review of administrative action, as prescribed by general law;
  3. A district court of appeal or any judge thereof may issue writs of habeas corpus returnable before the court or any judge thereof or before any circuit judge within the territorial jurisdiction of the court. A district court of appeal may issue writs of mandamus, certiorari, prohibition, quo warranto, and other writs necessary to the complete exercise of its jurisdiction. To the extent necessary to dispose of all issues in a cause properly before it, a district court of appeal may exercise any of the appellate jurisdiction of the circuit courts.

c) Circuit Courts -- Jurisdiction

1) The circuit courts shall have original jurisdiction not vested in the county courts, and jurisdiction of appeals when provided by general law. They shall have the power to issue writs of mandamus, quo warranto, certiorari, prohibition and habeas corpus, and all writs necessary or proper to the complete exercise of their jurisdiction. Jurisdiction of the circuit court shall be uniform throughout the state. They shall have the power of direct review of administrative action prescribed by general law.

d) County Courts -- Jurisdiction

1. The county courts shall exercise the jurisdiction prescribed by general law. Such jurisdiction shall be uniform throughout the state.

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4. Judiciary and the Regulation of Attorneys

As previously mentioned, according to Florida Constitution Article V, Section 15, Attorneys; admission and discipline, "the Supreme Court shall have exclusive jurisdiction to regulate the admission of persons to the practice of law and the discipline of persons admitted.''

The distinguishing feature of the legal profession is that lawyers, in a real sense, are members of the judicial branch of government. They are truly "officers of the court." Their duties go far beyond representing a client's best interest and merely practicing law competently. They have duties to the system of justice itself. The Florida Constitution has specified for lawyers a special role in the state's judicial system. The system simply would not function without lawyers.

The practice of law differs from other professions because of its unique relationship to the judicial branch of government. Regulation of the bar and the practice of law is totally unlike regulation of professions for the reason that the functions of the courts are inextricably intertwined with the practice of law. The conduct of lawyers is, therefore, subject to special and stringent regulatory supervision because the functions performed by lawyers constitute an integral element of the judicial process. As expressed by the Florida Supreme Court when it unified the Florida State Bar: "It is hardly necessary to assert that the bar has responsibility to the public that is unique and different in degree from that exacted from the members of other professions." Petition of Florida State Bar Association, 40 So. 2d 902, 908 (Fla. 1949).

The Court further emphasizes these precepts in the preamble to Chapter 4 of the Rules Regulating The Florida Bar, which contains the rules of professional conduct for attorneys: "An independent legal profession is an important force in preserving government under law, for abuse of legal authority is more readily challenged by a profession whose members are not dependent on the executive and legislative branches of government for the right to practice. Supervision by an independent judiciary, and conformity with the rules the judiciary adopts for the profession, assures both independence and responsibility."

Currently changes in Chapter 3 and 4 of the Rules Regulating The Florida Bar are pending at the Florida Supreme Court.
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a) Constitutional History

1868 -- On February 25, 1868, a constitutional convention adopted a revised constitution which included: "Sec. 21. Attorneys at law, who have been admitted to practice in any court of record in any State of the Union or to any United States Court, shall be admitted to practice in any court of this State, on producing evidence of having been so admitted." Art. VI, section 21, Fla. Const. (1868).
1885 -- Art. VI, sec. 21, Fla. Const. (1868), repealed.
1956 -- House Joint Resolution 810 approved by the general populace, Art. V, sec. 23, Fla. Const. (1956).

"Section 23. Admission and discipline of attorneys. -- The supreme court shall have exclusive jurisdiction over the admission to the practice of law and the discipline of persons admitted. It may provide for an agency to handle admissions subject to its supervision. It may also provide for the handling of disciplinary matters in the circuit courts and the district courts of appeal, or by commissions consisting of members of the bar to be designated by it, the supreme court, subject to its supervision and review.''
1972 -- Senate Joint Resolution 52­0 approved November 1972 by the general populace (from the 1968 constitutional revision) renumbering and amending Art. V, sec. 23, Fla. Const. (1957) to Art. V, sec. 15, Fla. Const. (1972).

"Section 15. Attorneys; admission and discipline. -- The supreme court shall have exclusive jurisdiction to regulate the admission of persons to the practice of law and the discipline of persons admitted.''

During the period from 1830 to 1870, there was a movement which wasn't called deregulation. It was called deprofessionalism of the bar. As a result of that, anybody could be a judge or a lawyer without any kind of certification or training. The results were chaotic; the public was misled, defrauded, administration of justice deteriorated and great public mischief resulted. For a period of 120 years, prior to 1949, the legal profession of Florida was subject to the jurisdiction of the legislature. During that period, there were less than 30 reported cases of discipline in the State of Florida . . . and there were even fewer reports of any kind of punishment.

Over the years, several challenges to this constitutional section (Article V, Section 15) have occurred. Some were court cases, some were initiatives by special interest groups to amend the constitution and others were legislatively sponsored.
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b) Legislative Activity

Probably the most substantial challenge to the Supreme Court's regulation of the legal profession was the 1979 Legislative Subcommittee on the Legal Profession (Sheldon Committee) which studied the possible sunset of The Florida Bar's regulatory function. The Bar was obligated to prove its indispensability in the regulation of the legal profession. The conclusions and recommendations of the Sheldon Committee were published on June 5, 1980. The Committee at that time decided not to propose legislation or a constitutional amendment to alter control of the legal profession but instead recommended administrative changes including adding public members to the Bar's Board of Governors, removing the confidentiality in attorney discipline cases after probable cause has been ascertained, not using Bar dues for lobbying efforts without contributors' approval, and periodic sunset­type review by the Legislature.

One of the seminal arguments by the Bar to leave regulation of lawyers with the Supreme Court was the separation of powers doctrine which precludes legislative entry into this area. The Bar observed that regulation of the legal profession is a unique and proper power of the court in the exclusive exercise of the court's judicial function. The Sheldon Committee's response to the separation of powers argument was that the court, by compelling and spending Bar dues, may be using an exclusively "legislative" power. (Article V, S. 14 which states that the judiciary shall have no power to fix appropriations.) The Committee further noted that dues collected and spent by agencies of the court, in effect, "arms of the court," are public monies because the court, through its agencies, uses state power to raise that money. The Committee suggested that it is the exclusive inherent power of the Legislature, not the courts, to raise and regulate the spending of public money.

Throughout the existence of The Florida Bar there have been periodic efforts to introduce legislation that would pave the way for a popular vote on a constitutional amendment to alter the Supreme Court's authority to regulate and discipline attorneys. None of those measures has ever gained significant legislative momentum. And, the Bar has consistently opposed such proposals in its formal legislative advocacy.

During the 1990 Legislative Session, HB 2625 was introduced which would create an Attorney Discipline Study Committee composed of five members, including three nonlawyers. The panel would investigate, monitor and evaluate complaints about attorney unresponsiveness, incompetence, fee disputes and unethical conduct. A similar bill was introduced in 1989 but did not pass.

During the 1994 regular session, the Florida Legislature considered several measures that would have affected the authority of the Supreme Court of Florida to regulate the admission and discipline of lawyers. One House bill that died in committee would have urged the court to adopt rules amendments to require that bar admissions decisions be made public. Another Senate proposal would have sought a study of the due process aspects of the bar admissions application process -- that measure was withdrawn, and a Supreme Court study committee was named to consider the issue among others.

A special commission to review and make recommendations for change in the judicial article of the Florida Constitution was created during the 1994 regular legislative session: Ch. 94­138, Laws of Florida. Although the focus of the Article V Task Force is judicial matters and court structure, the enabling legislation calls for "additional recommendations to improve the administrative of justice."

The Task Force's final report of December 1995 included a unanimous recommendation to maintain Florida's current constitutional process for regulating and disciplining attorneys. "The statistics and testimony overwhelming support the current scheme," the report states, "and no evidence was offered to indicate that any other form of regulation and discipline would produce the same favorable results."

Nevertheless, during the 1996 Legislative Session, matching bills were introduced in the House (HB 1453 ­ Melvin) and Senate (SB 2456 ­ Gutman) to offer voters a proposed constitutional amendment giving the legislature oversight over lawyer admission and regulation. The sponsor of the House legislation withdrew the measure when it became obvious that it would fail in the Judiciary Committee. The Senate companion was never heard.

Also in 1996, the House Appropriations Committee separately considered a claim that the legislature, by virtue of 1992 amendments to Article III, Section 19, has full authority over the finances of the Bar, the Florida Board of Bar Examiners, and the Florida Bar Foundation. The issue died after one morning of committee testimony from Court and Bar officials, and -- aided by a scholarly analysis of the constitutional amendment in question -- when it became clear that the current fiscal processes of these entities had more than enough supporters to thwart further legislative inquiry.

Similar legislation was proposed during the 1997 Legislative Session. The proposal (HB 1817) passed in the House Criminal Justice Appropriations Committee, but died on the House floor.

And, in the 1998 session similar legislation to amend Art V §15 of the state constitution, to allow for legislative control of attorney admission and discipline, was introduced -- but thereafter withdrawn during session.
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c) Relevant Court Cases

1. Financial Disclosure

In re: The Florida Bar, Advisory Opinion Concerning Applicability of Chapter 74­177 [Chapter 112.312(2),(1989)], 316 So. 2d 45 (1975). This was an advisory opinion concerning the applicability of Chapter 74­177, Laws of Florida -- Financial Disclosure Law -- to members of The Florida Bar acting in their historical professional capacity as "officers of the court." The Supreme Court of Florida found the Financial Disclosure Law inapplicable as a code of conduct to officers of the judicial branch as the Supreme Court has the inherent right to supervise the bar as an incident to the Supreme Court's power to control, admit to practice and discipline attorneys based on Article V, Section 15, Florida Constitution.

2. Public Records

In re: The Florida Bar. In re: Advisory Opinion Concerning the Applicability of Chapter 119, Florida Statutes. 398 So. 2d 446 (1981). This was an advisory opinion concerning the applicability of the Public Records Law to The Florida Bar's unlicensed practice of law investigation files. The Court ruled that the UPL investigation files of The Florida Bar, as an official arm of the Court, were subject to the control and direction of the Supreme Court and not to either of the other branches of the government.

This notion was reiterated in Locke v. Hawkes, 595 So.2d 32 (Fla. 1992), which dealt with the applicability of Florida's public records law to certain personal records of state legislators. The Locke case, with its reconfirmation of Florida's separation of powers doctrine with respect to public records, became the impetus for an amendment of Article I, Section 24 of the Florida Constitution, adopted by the electorate in November 1992.

That measure established a public right of access to the records of all three state governmental branches, and to certain meetings of executive and legislative agencies. By virtue of the amendment, the legislature now possesses exclusive authority over all affected records and meetings, further restrained by various conditions on enacting any additional exceptions to such openness.

Meetings of the judicial branch were unaffected by the measure, and it specifically validated all rules of court regarding access to records in effect on the date that the amendment was adopted. Six days prior to voter approval of the amendment, the Supreme Court of Florida promulgated several records­related changes to the Rules Regulating The Florida Bar and the Rules of Judicial Administration: In Re Amendments to Fla. Rules, 608 So.2d 472 (Fla. 1992).

Additions to the Rules of Judicial Administration generally confirmed the right of public access to judicial branch records, but established 10 exceptions to such access. The other amendments clarified The Florida Bar's general records policy, and included specific provisions regarding professional ethics opinions, Clients' Security Fund claims, unlicensed practice of law matters, and the review of lawyer advertisements and solicitations.

In 1994 the Supreme Court's Study Committee on Confidentiality of Records of the Judicial Branch presented the court with additional amendments and commentary to Rule of Judicial Administration regarding public access to judicial records. The court's ultimate adoption of those revisions included, on its own motion, a preliminary policy statement concerning the use and maintenance of electronic mail transmissions which the court acknowledged as "judicial records" under the rule. In Re Amendments to Rule of Judicial Administration 2.051 -- Public Access to Judicial Records, 651 So.2d 1185 (Fla. 1995).
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3. Unlicensed Practice of Law

In 1956, Florida voters adopted a revised Article V of the state constitution. Section 23 of the new article, now Section 15, gave the Supreme Court of Florida "exclusive jurisdiction over the admission to the practice of law and the discipline of persons admitted." The Florida Supreme Court adopted as its own language from West Virginia State Bar v. Earley, 109 S.E. 2d 420 (W.Va. 1959) in the Sperry case (cited below) relevant to UPL and licensing: ". . . It would indeed be an anomaly if the power of the courts to protect the public from the improper or unlawful practice of law were limited to licensed attorneys and did not extend or apply to incompetent and unqualified laymen and law agencies. Such a limitation of the power of the courts would reduce the legal profession to an unskilled vocation, destroy the usefulness of licensed attorneys as officers of the courts, and substantially impair and disrupt the orderly and effective administration of justice by the judicial department of the government; and this the law will not recognize or permit."

4. Judicial Discipline:

The Florida Bar v. David Lucas McCain, 330 So. 2d 712 (1976). An attorney, who was formerly a Supreme Court Justice, moved to dismiss and/or quash a report by the Board of Governors of The Florida Bar of probable cause for further disciplinary proceedings against him. The Supreme Court held that the Board of Governors, serving as an adjunct or administrative agency of the Supreme Court, had jurisdiction to discipline an attorney for acts bearing on his fitness to practice law even when those acts occurred while the attorney held judicial office.

5. Legal Representation of the Poor

Amendments to Rules Regulating The Florida Bar -- 1­3.1(a) and Rules of Judicial Administration -- 2.065 (Legal Aid), 598 So. 2d 41 (Fla., 1992). Upon consideration of a report from a Joint Commission of Florida Bar and Florida Bar Foundation representatives, the Court approved an annual minimum of 20 hours of voluntary pro bono legal services to the poor, for each Florida Bar member, or an alternative contribution of $350 to a legal services agency. The Court noted: "What makes our legal system so different is the ability of lawyers to challenge the constitutionality of government conduct before a separate, independent judicial branch of government. Although an independent judiciary is essential, an independent legal profession plays a critical role in maintaining our constitutional structure." In support of pro bono, the opinion added: "We find it is important for an independent legal profession to provide a portion of indigent representation to ensure proper challenges against government violations of individual rights." Yet the Court further stressed: "To the legislature, we emphasize that the legal profession is not able to single­handedly resolve the problem of indigent legal representation, and, although there is a budget crisis, funding will eventually have to be provided to address a significant portion of the needs identified by the Commission and particularly legal representation that is now mandated by the Constitution.''
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IV. Bibliographic Sources

Buffington, Mary. "Separation of Powers and the Independent Governmental Entity After Mistretta v. United States," 50 Louisiana Law Review 117 (September 1989).

Drew, E. Harris. "Inherent Power of the Supreme Court with Special Reference to the Power to Regulate Disbarment of its Officers, and the Liability of the County to Defray the Expenses Incident Thereto," 15 Florida Bar Journal 303 (November 1941).

England, Arthur J., Jr. "In Defense of Regulation by the Supreme Court," 54 Florida Bar Journal 254 (April 1980).

Fay, Peter T. "Officers of the Court," 60 Florida Bar Journal 9 (December 1986).

Lehan, James E. "Lawyers are Different," 62 Florida Bar Journal 21 (October 1988).

Little, Joseph W. "An Overview of the Historical Development of the Judicial Article of the Florida Constitution," 19 Stetson Law Review 1 (Fall 1989).

Scanlon, Pat H. "The Unified Bar," The Mississippi Lawyer, March/April, p. 9, 1989.

Smith, William Reece, Jr. "In Support of the Integrated Bar," 54 Florida Bar Journal 258 (April 1980).

State of Florida, Legislature. Report of the Select Subcommittee on the Legal Profession (Sheldon Report). June 5, 1980.

Prepared by The Florida Bar Department of Public Information and Bar Services with assistance from the General Counsel and the Unlicensed Practice of Law Department.

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[Revised: 5/26/05]