Edenfield v. Fane

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In Edenfield v. Fane, 507 U.S. 761 (1993), the U.S. Supreme Court struck down a ban on solicitation from accountants to potential clients. The Court there made clear that Ohralik v. Ohio State Bar Ass'n "did not hold that all personal solicitation is without First Amendment protection." 507 U.S. at 774. It further noted that "Ohralik's holding was narrow and depended upon certain 'unique features of in-person solicitation by lawyers' that were present in the circumstances of that case." Ibid. (quoting Zauderer v. Office of Disciplinary Counsel of Supreme Court of Ohio, 471 U.S. 626, 641 (1985)).

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