Sylvia Ibanez advertised her qualifications as a member of the Florida Bar, a certified financial planner, and a certified public accountant. She was reprimanded by the Florida Board of Accountancy. Ibanez challenged the Board decision, and the United States Supreme Court ruled in her favor in Ibanez v. Florida Department of Business & Professional Regulation, Board of Accountancy, 114 S. Ct. 2084, 2086 (1994). This Note examines Ibanez and considers the substantial government interests states must demonstrate before they may regulate truthful commercial speech. It concludes that the Ibanez Court failed in its reasoning and holding to extend—under its own precedent—the maximum possible protection to consumers who may be misled, or at least left uninformed, by professional advertising similar in content and form to that used by Ibanez.
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