N.C. Gen. Stat. » Chapter 84
NC General Statutes

N.C. Gen. Stat. § 84-37 (2026)

State Bar may investigate and enjoin unauthorized activities

✓ current as of July 2026
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(a) The Council or any committee appointed by it for that purpose may inquire into and investigate any charges or complaints of (i) unauthorized or unlawful practice of law or (ii) the use of the designations, "North Carolina Certified Paralegal," "North Carolina State Bar Certified Paralegal," or "Paralegal Certified by the North Carolina State Bar Board of Paralegal Certification," by individuals who have not been certified in accordance with the rules adopted by the North Carolina State Bar. The Council may bring or cause to be brought and maintained in the name of the North Carolina State Bar an action or actions, upon information or upon the complaint of any person or entity against any person or entity that engages in rendering any legal service, holds himself or herself out as a North Carolina certified paralegal by use of the designations set forth in this subsection, or makes it a practice or business to render legal services that are unauthorized or prohibited by law. No bond for cost shall be required in the proceeding.

(b) In an action brought under this section, the final judgment if in favor of the plaintiff shall perpetually restrain the defendant or defendants from the commission or continuance of the unauthorized or unlawful act or acts. A temporary injunction to restrain the commission or continuance of the act or acts may be granted upon proof or by affidavit, that the defendant or defendants have violated any of the laws applicable to unauthorized or unlawful practice of law or the unauthorized use of the designations set forth in subsection (a) of this section or any other designation implying certification by the State Bar. The provisions of law relating generally to injunctions as provisional remedies in actions shall apply to a temporary injunction and the proceedings for temporary injunctions.

(c) The venue for actions brought under this section shall be the superior court of any county in which the relevant acts are alleged to have been committed or in which there appear reasonable grounds that they will be committed in the county where the defendants in the action reside, or in Wake County.

(d) The plaintiff in the action shall be entitled to examine the adverse party and witnesses before filing complaint and before trial in the same manner as provided by law for examining parties.

(e) This section shall not repeal or limit any remedy now provided in cases of unauthorized or unlawful practice of law. Nothing contained in this section shall be construed as disabling or abridging the inherent powers of the court in these matters.

(f) The Council or its duly appointed committee may issue advisory opinions in response to inquiries from members or the public regarding whether contemplated conduct would constitute the unauthorized practice of law. (1939, c. 281; 1979, c. 570, s. 9; 1995, c. 431, s. 26; 2004-174, s. 2.)

 

Notes of Decisions
Cited in 7 cases (1 in the last 5 years), 1999–2025 · leading case: Frazier v. Murray, 519 S.E.2d 525 (N.C. Ct. App. 1999).
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Frazier v. Murray, 519 S.E.2d 525 (N.C. Ct. App. 1999). · cites it 16× “1(b1), on the other hand, is a generalized statement regarding the DHC's power to hold people, firms or corporations in contempt.”
Disciplinary Hearing Comm'n v. Frazier, 556 S.E.2d 262 (N.C. 2001). · cites it 15× “Under N.C.G.S. § 84-37, the North Carolina State Bar may investigate “any charges or complaints of unauthorized or unlawful practice of law.”
Capital Associated Indus., Inc. v. Cooper, 129 F. Supp. 3d 281 (M.D.N.C. 2015). “Only State Prosecutors may initiate criminal- proceedings against a party that has violated the UPL Statutes.”
N.C. State Bar v. Musinguzi (N.C. Ct. App. 2025). · cites it 4× “” N.C. Gen. Stat. § 84-37 (2023). The unauthorized practice of law is forbidden by statute.”
legalzoom.com, Inc. v. the North Carolina State Bar, 2012 NCBC 47 (N.C. Bus. Ct. 2012). · cites it 4× “N.C. Gen. Stat. § 84-37 . In addition to its investigatory powers, it may obtain injunctive relief in the Superior Court.”
N. Carolina State Bar v. Lienguard, Inc., 2014 NCBC 11 (N.C. Bus. Ct. 2014). · cites it 4× “N.C. Gen. Stat. § 84-37 (2013) (giving the State Bar the authority to “inquire into and investigate” any charges of unauthorized practice of law and bring an action in superior court to enjoin such practice).”
State v. Orion Processing, LLC, 2017 NCBC 20 (N.C. Bus. Ct. 2017). · cites it 2× “In accordance with N.C. Gen. Stat. § 84-37 and N.C. R. Civ. P.”
— N.C. Gen. Stat. § 84-37(a) — 1 case
Disciplinary Hearing Comm'n v. Frazier, 556 S.E.2d 262 (N.C. 2001). “Under N.C.G.S. § 84-37, the North Carolina State Bar may investigate “any charges or complaints of unauthorized or unlawful practice of law.”
— N.C. Gen. Stat. § 84-37(b) — 1 case
Disciplinary Hearing Comm'n v. Frazier, 556 S.E.2d 262 (N.C. 2001). “Under N.C.G.S. § 84-37, the North Carolina State Bar may investigate “any charges or complaints of unauthorized or unlawful practice of law.”
— N.C. Gen. Stat. § 84-37(c) — 2 cases
Frazier v. Murray, 519 S.E.2d 525 (N.C. Ct. App. 1999). “1(b1), on the other hand, is a generalized statement regarding the DHC's power to hold people, firms or corporations in contempt.”
Disciplinary Hearing Comm'n v. Frazier, 556 S.E.2d 262 (N.C. 2001). “Under N.C.G.S. § 84-37, the North Carolina State Bar may investigate “any charges or complaints of unauthorized or unlawful practice of law.”
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