§ 2524. Penalty for unauthorized practice of law.
(a) General rule.--Except as provided in subsection (b), any person, including, but not limited to, a
paralegal or legal assistant, who within this Commonwealth shall practice law, or
who shall hold himself out to the public as being entitled to practice law, or use
or advertise the title of lawyer, attorney at law, attorney and counselor at law,
counselor, or the equivalent in any language, in such a manner as to convey the impression
that he is a practitioner of the law of any jurisdiction, without being an attorney
at law or a corporation complying with 15 Pa.C.S. Ch. 29 (relating to professional
corporations), commits a misdemeanor of the third degree upon a first violation. A
second or subsequent violation of this subsection constitutes a misdemeanor of the
first degree.
(b) Practice by associations.--
(1) An association does not violate subsection (a) if it provides legal services only
through officers, employees or agents who are duly admitted to practice law. The association
may employ persons not admitted to practice law, but those persons shall not render
any legal services rendered or to be rendered by the association.
(2) This subsection shall not be interpreted to preclude the use of clerks, secretaries,
administrators, bookkeepers, technicians and other assistants who are not usually
and ordinarily considered by law, custom and practice to be rendering legal services
nor to preclude the use of any other person who performs all his employment under
the direct supervision and control of a person duly admitted to practice law. A person
shall not, under the guise of employment, render legal services unless duly admitted
to practice law.
(3) Notwithstanding any other provision of law, an association may charge for the legal
services of its officers, employees and agents, may collect those charges and may
compensate those who render the professional services.
(c) Injunction.--In addition to criminal prosecution, unauthorized practice of law may be enjoined
in any county court of common pleas having personal jurisdiction over the defendant.
The party obtaining such an injunction may be awarded costs and expenses incurred,
including reasonable attorney fees, against the enjoined party. A violation of subsection
(a) is also a violation of the act of December 17, 1968 (P.L.1224, No.387), known
as the Unfair Trade Practices and Consumer Protection Law.
(Dec. 21, 1988, P.L.1444, No.177, eff. Oct. 1, 1989; Dec. 7, 1994, P.L.703, No.106,
eff. 60 days; July 11, 1996, P.L.607, No.104, eff. 60 days)
1996 Amendment. Act 104 amended subsec. (a) and added subsec. (c).
Notes of Decisions
Harkness v. Unemployment Comp. Bd. of Review, 920 A.2d 162 (Pa. 2007).
· cites it 2× “42 Pa.C.S. § 2524(a). [5] These activities and type of proceedings can be contrasted with the situation in Shortz, relied upon by the Commonwealth Court in this matter, in which our Court found non-lawyer representation during workers' compensation proceedings to constitute the…”
Commonwealth v. Pilchesky, 151 A.3d 1094 (Pa. Super. Ct. 2016).
· cites it 4× “■ The Commonwealth charged Pilchesky with four counts of the unauthorized practice of law in violation of 42 Pa.C.S. § 2524(a) on February 27, 2013.”
Barrett, A. v. M&B Med. Billing, Inc., 291 A.3d 371 (Pa. Super. Ct. 2022).
· cites it 2× “See 42 Pa.C.S. § 2524(a). Additionally, the Courts of this Commonwealth have held that artificial entities, such as corporations, may only appear in court through counsel.”
Gmerek v. State Ethics Comm'n, 751 A.2d 1241 (Pa. Commw. Ct. 2000).
· cites it 4× “The present form of the statute prohibiting such conduct may be found at Section 2524 of the Judicial Code, 42 Pa.C.S. § 2524, which states, in pertinent part: (a) General rule.”
Haymond v. Lundy, 205 F. Supp. 2d 390 (E.D. Pa. 2002).
· cites it 3× “Hochberg claims the court made a novel ruling on state law when it held that being a managing partner of a Pennsylvania law-firm is equivalent to practicing law here, in violation of 42 Pa. Cons.Stat.Ann. § 2524. He cites to the court’s opinion: The question of the rights and…”
Commonwealth v. Kitchen, 162 A.3d 1140 (Pa. Super. Ct. 2017).
“To do so is a violation of a criminal statute, 42 Pa.C.S. § 2524(a). Therefore, it should not be assumed by this court, or any other court, that to practice law without a license is not a big deal.”
Pennsylvania Dep't of Banking v. NCAS of Delaware, LLC, 995 A.2d 422 (Pa. Commw. Ct. 2010).
· cites it 2× “For example, 42 Pa.C.S. § 2524 (penalty for unauthorized practice of law) provides that (c) "[i]n addition to criminal prosecution, unauthorized practice of law may be enjoined in any county court of common pleas having personal jurisdiction over the defendant .”
Off. of Disciplinary Couns. v. Marcone, 855 A.2d 654 (Pa. 2004).
“See also, 42 Pa.C.S. § 2524 (setting forth penalty for those who within Commonwealth practice law or hold themselves out as being entitled to practice law without being an attorney at law); 42 Pa.”
Nolan v. Dep't of Pub. Welfare, 673 A.2d 414 (Pa. Commw. Ct. 1995).
· cites it 3× “§ 7311, and because Nolan is illegally engaged in the practice of law pursuant to 42 Pa.C.S. § 2524. The Secretary affirmed the OHA’s order prohibiting Nolan from representing clients before the OHA and Nolan appealed to this Court.”
Commonwealth v. Garzone, 34 A.3d 67 (Pa. 2012).
“”); 42 Pa.C.S. § 2524 (individual found to have committed unauthorized practice of law may be subject to pay party bringing successful action "costs and expenses incurred, including reasonable attorney fees”); 42 Pa.”
Delaware Valley Landscape Stone v. RRQ, LLC, 2022 Pa. Super. 173 (Pa. Super. Ct. 2022).
“See 42 Pa.C.S. § 2524(a). Additionally, the courts of this Commonwealth have stated that artificial entities, such as corporations, may only appear in court through counsel.”
— 42 Pa. Cons. Stat. § 2524(a) — 18 cases
Harkness v. Unemployment Comp. Bd. of Review, 920 A.2d 162 (Pa. 2007).
“42 Pa.C.S. § 2524(a). [5] These activities and type of proceedings can be contrasted with the situation in Shortz, relied upon by the Commonwealth Court in this matter, in which our Court found non-lawyer representation during workers' compensation proceedings to constitute the…”
Commonwealth v. Pilchesky, 151 A.3d 1094 (Pa. Super. Ct. 2016).
“■ The Commonwealth charged Pilchesky with four counts of the unauthorized practice of law in violation of 42 Pa.C.S. § 2524(a) on February 27, 2013.”
Barrett, A. v. M&B Med. Billing, Inc., 291 A.3d 371 (Pa. Super. Ct. 2022).
“See 42 Pa.C.S. § 2524(a). Additionally, the Courts of this Commonwealth have held that artificial entities, such as corporations, may only appear in court through counsel.”
Commonwealth v. Kitchen, 162 A.3d 1140 (Pa. Super. Ct. 2017).
“To do so is a violation of a criminal statute, 42 Pa.C.S. § 2524(a). Therefore, it should not be assumed by this court, or any other court, that to practice law without a license is not a big deal.”
Gmerek v. State Ethics Comm'n, 751 A.2d 1241 (Pa. Commw. Ct. 2000).
“The present form of the statute prohibiting such conduct may be found at Section 2524 of the Judicial Code, 42 Pa.C.S. § 2524, which states, in pertinent part: (a) General rule.”
— 42 Pa. Cons. Stat. § 2524(c) — 2 cases
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