In Re Review of Opinion 475 of the Advisory Committee on Professional Ethics & DR 2-102(C)

HANDLER, J.,

concurring in part and dissenting in part.

I concur in the essential judgment of the Court that DR 2-102(C) prohibits the inclusion in a firm name of lawyers not authorized to practice law in this State and is constitutional. I subscribe to this determination because the Court also recognizes the right of New Jersey attorneys to affiliate with a national law firm and to advertise their association. Hence, the firm name restriction is extremely narrow.

I do not believe, however, that the Court should deal with the question whether a national law firm such as Jacoby & Meyers or a local affiliate of that firm will be in violation of our State’s ban on television and radio advertising if the local office lawfully advertises its affiliation through the conventional print media, while the national firm continues to advertise on out-of-state television without even mentioning its New Jersey affiliate. That question is premature, complex and controversial. While it is entirely appropriate to note these issues, there is no need to resolve them in this case. By ruling on an interim basis that our State’s ban on attorney broadcast advertising will apply to certain kinds of television advertising involving affiliated law firms, the Court may be thought to have turned a narrow firm name controversy into a TV advertising case with substantial constitutional and public policy implications. I am not prepared in this case to resolve even provisionally the issue of whether *98broadcast advertising is permissible. I therefore write separately to explain my views and misgivings on this significant point.

It is important to keep a sharp focus on the real issue in this case. Petitioner Jacoby & Meyers, a national law firm with offices throughout California and New York, is considering . opening several branches in New Jersey and wants to operate under its existing name of Jacoby & Meyers. However, our State’s disciplinary rules prohibit the mention in the firm name of any lawyer not licensed to practice in New Jersey. DR 2-102(C). Neither Mr. Jacoby nor Mr. Meyers is licensed to practice in this state.

Petitioner initiated this action to challenge the constitutionality of our firm name rule. In today’s decision the Court has rejected that challenge. I agree with the majority that DR 2-102(C) bars petitioner’s use of its existing name as its firm name in New Jersey and, as narrowly construed and applied in our decision in this case, is constitutional. The firm name is not truly commercial expression or speech. Rather, it is a quasi-official designation which can be reasonably regulated by the State without encroaching upon protected areas of commercial speech.1 See ante at 87-88. However, I have serious reservations about the wisdom and continued viability of our firm name restriction in this era of multijurisdictional practice and widespread legal advertising. I therefore welcome the majority’s decision to refer this matter to a special Supreme Court committee for consideration of whether to change our *99present rule, as well as our State’s total ban on broadcast advertising by attorneys.

The majority further states that our firm name restriction presents no barrier to a New Jersey law office advertising its affiliation with a national firm. The New Jersey branch of the firm may note such an association on office signs, professional cards and letterheads, as long as the reference is not misleading. See ante at 88. It may also utilize all currently permissible forms of commercial advertising. See ante at 88. As far as I am concerned, recognition of the right to advertise affiliation draws the sting from the firm name restriction and constitutes the only basis for its acceptability.

I do not believe the Court is required to confront more than the foregoing propositions. Nevertheless, the Court has felt constrained to address television advertising, which is prohibited under our disciplinary rules. See DR 2-102(D) (“A paid advertisement ... shall be communicated to the public only in print media”). The majority expresses its understandable concern over the fact that Jacoby & Meyers relies heavily on broadcast media advertising and maintains offices in New York, where there is no ban on television and radio advertising by lawyers. It should suffice on this aspect of the case simply to note this fact and the potential conflict which may arise from attempted uses of broadcast advertising by Jacoby & Meyers regarding a New Jersey law firm affiliate.

The Court, for purposes of this case, states that “if petitioner were allowed to use its firm name in New Jersey in any form its television advertising [in New York] could give it a substantial competitive advantage [over New Jersey firms].” See ante at 88. According to the majority: “Any New Jersey law firm that advertised in print its association with petitioner is likely to gain a real benefit from petitioner’s television advertising.” Ante at 89. In my view, the record in this case is too slim to resolve the fact-sensitive question of whether Jacoby & Meyers’ New York television advertising would constitute a direct bene*100fit and unfair trade advantage for itself or its New Jersey branches, at least where the advertising does not mention the name of the firm’s New Jersey affiliate. It seems a very debatable proposition that a measurable benefit in New Jersey will accrue to petitioner or its local affiliate if the New Jersey law firm is never mentioned in the New York ads.2

Of greater concern than the Court’s expressed belief that Jacoby & Meyers’ New Jersey affiliate would reap an unfair trade advantage from advertising practices in New York is the cast which its discussion could place on future cases or proceedings which may be more appropriate for determining the permissible scope of attorney broadcast advertising. The majority forewarns Jacoby & Meyers that if it intends to continue running television commercials in New York, it must forego advertising its affiliation with New Jersey firms not only in the broadcast but also in the print media. It serves a similar warning upon any New Jersey firm affiliating with petitioner.

This in futuro disposition by the Court necessarily involves speculation on distant problems which are not ripe for a reasoned resolution. Cf. Clay v. Sun Ins. Office Limited, 363 U.S. 207, 221, 80 S.Ct. 1222, 1230, 4 L.Ed.2d 1170, 1175 (1960) (Frankfurter, J.). (“[W]e do not remotely hint to an answer to a question that is prematurely put”). Furthermore, in discussing the question of permissible television advertising, the majority addresses an issue with significant constitutional and public policy implications. Such matters should be kept at arms length until their proximity to the heart of the controversy makes hand-to-hand combat with them unavoidable. Cf. Donadio v. Cunningham, 58 N.J. 309, 325-326 (1971) (“a court should not reach and determine a constitutional issue unless absolutely imperative in the disposition of the litigation”). See, e.g., Ahto *101v. Weaver, 39 N.J. 418, 428 (1963); Lordi v. UA New Jersey Theaters, Inc., 108 N.J.Super. 19, 33 (Ch.Div.1969).

Despite my reservations, I am somewhat mollified because the Court’s decision is intended to be temporary. It is made in the context of a potential change in our rules governing this entire subject. Were this not a provisional ruling, our decision might place us on a collision course with the principles enunciated in the United States Supreme Court’s latest decision on the scope of legal advertising. See In the Matter of R. M. J.,- U.S. -, 102 S.Ct. 929, 71 L.Ed.2d 64 (1982). In that decision Justice Powell, writing for a unanimous Court, underscored the point that regulations restricting the right of attorneys to advertise are valid only “where the record indicates that a particular form or method of advertising has in fact been deceptive.” Id. at -, 102 S.Ct. at 937. Justice Powell further explained that the scope of any such restriction must be “no broader than reasonably necessary to prevent the deception.” Id. at-, 102 S.Ct. at 937.

This Court is mindful of the great changes which have occurred in the practice of law throughout the country. It is fully aware of the direction which the Supreme Court is taking on attorney advertising. I am confident that we will navigate within the constitutional markers set by the Supreme Court. Such a course would acknowledge that there is nothing inherently deceptive or misleading about television and radio advertising.3 Moreover, it would recognize that a blanket prohibition *102against such advertising may sweep more broadly than necessary to effectuate the State’s legitimate ends.4

In the wake of the R. M. J. decision, questions have surfaced not only as to the continued constitutional validity of our State’s total ban on television and radio advertising by lawyers but also as to its desirability as a matter of policy. At least 39 other states, plus the District of Columbia, now allow attorneys to advertise on television or radio in some form. See Andrews, “Lawyer Advertising and the First Amendment,” 1981 Am. B. Foundation Research J. 967, 1014-1015; “Lawyer Takes To T.V.,” 109 N.J.L.J. 183 (1982). In addition, the new ABA Model Rules of Professional Conduct provide that lawyers may advertise their services through public media, including radio and *103television. See Rule 7.2(a), ABA Model Rules of Professional Conduct (Alt.Draft 1981). Thus, DR 2-101(D) may be constitutionally vulnerable; it may not comport with current public policy; and, assuredly, it is ripe for reconsideration.

I recognize the majority’s sincere conviction that something be said about the rule’s present application. However, I have a lingering concern about the effect of this ruling on petitioner’s otherwise permissible advertising practices. As already mentioned, a New Jersey firm may freely advertise its association with a national law firm, as long as that advertising is not deceptive or misleading. See ante at 88. Nevertheless, the Court rules today that such nonmisleading advertising can be banned simply because the national law firm simultaneously exercises television advertising rights allowed it in another state, even though that advertising makes no reference to the firm’s New Jersey affiliate. This ruling tends to contradict the Court’s basic rationale for sustaining the firm name restriction—that New Jersey lawyers can fully advertise their associations with national firms. However, I do not surmise that, even in the immediate future while our rules are being studied anew, this Court will prohibit reasonable, nondeceptive advertising or deny lawyers the right to contest any adverse restrictions placed upon permissible advertising efforts.

I would see no need to comment on the subject of attorney television advertising in this case were it not for the Court injecting the issue into its decision. I would much prefer to be able to consider these problems either in a more appropriate case raising these issues on an adequate record or in a rulemaking proceeding which seeks the formulation of an appropriate regulation.

To the extent the majority’s decision may be thought to be an imprimatur on our current strictures against television advertising, I merely want to state that I do not think this is so and to suggest that our rules may not be deserving of a vigorous *104defense.5 The Court itself recognizes that we may be out of step with the times and should consider bringing our attorney advertising rules into conformity with the rest of the country. Ante at 96-97. See “Living Up to the First Amendment,” 109 N.J.L.J. 204 (1982); Andrews, supra, 1981 Am. Foundation Research J. at 1020-1021. I fully expect the special committee entrusted with the task of reviewing this subject matter—and then this Court in due time and with an adequate record—to propose and adopt rules which are constitutional and solicitous of the public and the profession. I would therefore await a more suitable case or proceeding than this one for determining the right of attorneys to advertise on television and radio.

The majority further holds that “[t]he use of a firm name in New Jersey that includes attorneys not admitted to our bar is certain to deceive at least some consumers of legal services.” See ante at 86. On an abstract level, that may be so, but I seriously question the pertinency of that proposition. Any potential deception can be dissipated by a simple rule change. I see nothing inherently deceptive about the practice of using a firm name which includes out-of-state lawyers. Certainly, were we to change our rule to permit nonlicensed attorneys to be included in a firm name, we would not be authorizing a deceptive practice. The vast majority of jurisdictions now allows the firm name to follow the firm. In fact, New Jersey is one of only two states which have retained this firm name restriction.

Even the majority has admitted that the extent and intensity of petitioner’s , New York television advertising is not a matter of record in this case and that the Court has no way of measuring the influence or effect of such advertising. See ante at 88.

The majority refers to the landmark case of Bates v. State Bar of Arizona, 433 U.S. 350, 97 S.Ct. 2691, 53 L.Ed.2d 810 (1977), wherein the Supreme Court first declared that lawyers have the constitutional right to advertise their services. See ante at 89. In that case, the Court stated in regard to television and radio advertising: “[T]he special problems of advertising on the electronic broadcast media will warrant special consideration.” 433 U.S. at 384, 97 S.Ct. at 2709, 53 L.Ed.2d at 836. I agree that television and radio advertising warrant our special concern because those media provide the speaker with a unique opportunity to reach a widespread audience with relative ease. Nevertheless, in my mind, that concern alone may not consti*102tute sufficient justification for a total ban on television and radio advertising by lawyers.

Of course, the State may place reasonable time, place and manner restrictions on attorney advertising. See Bates; In re Ethics Opinion 447, 86 N.J. 473 (1981). However, the mere fact that DR 2-101(D) restricts only the manner of advertising, rather than its content, does not mean the State’s regulation may sweep more broadly than necessary in restricting the manner of advertising. See, e.g., In the Matter of R. M. J.,--U.S.-, 102 S.Ct. 929, 71 L.Ed. 64 (1982) (rule prohibiting attorneys from mailing announcement cards to persons other than lawyers, former clients, relatives or friends held unconstitutional); Koffler v. Joint Bar Association, 51 N.Y.2d 140, 412 N.E.2d 927, 432 N.Y.S.2d 872 (1980) (attorney mass mailings to real estate owners and brokers found constitutionally protected); In re Appert, 315 N.W.2d 204 (Minn.Sup.Ct.1981) (lawyer advertising through distribution of brochures and letters protected under First Amendment).

Moreover, by prohibiting lawyers from advertising on television and radio, it can certainly be argued that New Jersey has denied attorneys access to the most effective means of commercial advertising. As the Supreme Court has noted in the context of political speech: “[The public’s] increasing dependence on television, radio and other mass media for news and information has made these expensive modes of communication indispensible instruments of effective ... speech.” Buckley v. Valeo, 424 U.S. 1, 19, 96 S.Ct. 612, 635, 46 L.Ed.2d 659, 688 (1976). See generally Mastro, Costlow and Sanchez, “Taking the Initiative: Corporate Control of the Referendum Process Through Mass Media Spending and What to Do About It,” 32 Fed.Comm.L.J. 315 (1980).

As a recent editorial in the New Jersey Law Journal noted:

[I]t is clear that purely dignitary limitations can no longer be imposed upon lawyer advertising. The freedom that attaches to other, like-situated commercial speakers now attaches to members of the bar. Perhaps that is exactly as it should be. We are, after all, a nation that stakes its best hopes on untrammeled expression. [“Living Up to the First Amendment,” 109 N.J.L.J. 204 (1982)]