(a) The phrase "practice law" as used in this Chapter is defined to be performing any legal service for any other person, firm or corporation, with or without compensation, specifically including the preparation or aiding in the preparation of deeds, mortgages, wills, trust instruments, inventories, accounts or reports of guardians, trustees, administrators or executors, or preparing or aiding in the preparation of any petitions or orders in any probate or court proceeding; abstracting or passing upon titles, the preparation and filing of petitions for use in any court, including administrative tribunals and other judicial or quasi-judicial bodies, or assisting by advice, counsel, or otherwise in any legal work; and to advise or give opinion upon the legal rights of any person, firm or corporation: Provided, that the above reference to particular acts which are specifically included within the definition of the phrase "practice law" shall not be construed to limit the foregoing general definition of the term, but shall be construed to include the foregoing particular acts, as well as all other acts within the general definition.
(b) The phrase "practice law" does not encompass:
(1) The drafting or writing of memoranda of understanding or other mediation summaries by mediators at community mediation centers authorized by G.S. 7A-38.5 or by mediators of employment-related matters for The University of North Carolina or a constituent institution, or for an agency, commission, or board of the State of North Carolina.
(2) The selection or completion of a preprinted form by a real estate broker licensed under Chapter 93A of the General Statutes, when the broker is acting as an agent in a real estate transaction and in accordance with rules adopted by the North Carolina Real Estate Commission, or the selection or completion of a preprinted residential lease agreement by any person or website provider. Nothing in this subdivision or in G.S. 84-2.2 shall be construed to permit any person or website provider who is not licensed to practice law in accordance with this Chapter to prepare for any third person any contract or deed conveying any interest in real property, or to abstract or pass upon title to any real property, which is located in this State.
(3) The completion of or assisting a consumer in the completion of various agreements, contracts, forms, and other documents related to the sale or lease of a motor vehicle as defined in G.S. 20-286(10), or of products or services ancillary or related to the sale or lease of a motor vehicle, by a motor vehicle dealer licensed under Article 12 of Chapter 20 of the General Statutes. (C.C.P., s. 424; 1870-1, c. 90; 1871-2, c. 120; 1880, c. 43; 1883, c. 406; Code, ss. 27, 28, 110; Rev., ss. 210, 3641; 1919, c. 205; C.S., s. 198; 1933, c. 15; 1941, c. 177; 1943, c. 543; 1945, c. 468; 1995, c. 431, s. 3; 1999-354, s. 2; 2004-154, s. 2; 2013-410, s. 32; 2016-60, s. 1; 2025-25, s. 29(5).)
Notes of Decisions
Cited in
40
cases (
6 in the last 5 years), 1962–2025 · leading case:
In Re Springs, 358 B.R. 236 (Bankr. M.D.N.C. 2006).
In Re Springs, 358 B.R. 236 (Bankr. M.D.N.C. 2006).
· cites it 5× “§ 84-4. The practice of law specifically includes performing any legal service for another person, preparing petitions, or assisting by advice, counsel, or otherwise in any legal work.”
The NC State Bar v. Livingston, 809 S.E.2d 183 (N.C. Ct. App. 2017).
· cites it 2× “5 The unauthorized practice of law in North Carolina is defined by statute, see N.C. Gen. Stat. § 84-2.1 (2015), which prohibits the practice of law by corporations: It shall be unlawful for any corporation to practice law .”
Gardner v. North Carolina State Bar, 341 S.E.2d 517 (N.C. 1986).
· cites it 3× “The practice of law is defined in North Carolina as “performing any legal service for any other person, firm or corporation, with or without compensation .”
Capital Associated Indus. v. Josh Stein, 922 F.3d 198 (4th Cir. 2019).
“" N.C. Gen. Stat. § 84-2.1 (a). The statutory definition provides a lengthy but unexhaustive list of what does and doesn't count as a legal service.”
In Re Gertzman, 446 S.E.2d 130 (N.C. Ct. App. 1994).
· cites it 4× “The court cited N.C. Gen. Stat. § 84-2.1 , which defines the practice of law in North Carolina as “ ‘performing any legal service for any other person, firm or corporation, with or without compensation, .”
Allied Env't v. Dept. of Env., 653 S.E.2d 11 (N.C. Ct. App. 2007).
· cites it 10× “§ 84-5 and N.C. Gen. Stat. § 84-2.1 , which expressly forbid a corporation from filing a petition with an administrative tribunal on behalf of any other corporation.”
Capital Associated Indus., Inc. v. Cooper, 129 F. Supp. 3d 281 (M.D.N.C. 2015).
· cites it 3× “Section 84-2.1 defines' the practice of law, in pertinent part; as “performing any legal service for any other person, firm or corporation, with or without compensation, specifically including .”
Appeal of Stroh Brewery Co., 447 S.E.2d 803 (N.C. Ct. App. 1994).
· cites it 3× “§ 84-4 (1985), see N.C.G.S. § 84-2.1 (1985) (“practice law” means “performing any legal service for any other person, firm or corporation”), dismissal of the appeal is not an appropriate remedy.”
In Re Moore, 290 B.R. 287 (Bankr. E.D.N.C. 2003).
· cites it 2× “North Carolina General Statutes § 84-2.1 defines the practice of law as follows: The phrase “practice law” as used in this Chapter is defined to be performing any legal service for any other person, firm or corporation, with or without compensation, specifically including the…”
Dallaire v. Bank of Am., N.A., 738 S.E.2d 731 (N.C. Ct. App. 2012).
· cites it 2× “” We have placed this language in quotations because a title search in North Carolina is an act which constitutes the practice of law as defined by N.C. Gen. Stat. § 84-2.1 (2011). We also note that corporations are prohibited from practicing law.”
State v. Pledger, 127 S.E.2d 337 (N.C. 1962).
· cites it 2× “(I)t shall be unlawful for any person or association of persons except members of the Bar, for or without a fee or consideration, to . . . prepare for another person, firm or corporation, any .”
— N.C. Gen. Stat. § 84-2.1(a) — 1 case
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