Chicago Bar Association v. Quinlan and Tyson, Inc.
Supreme Court of Illinois
234 N.E.2d 27 (Ill. 1967)
Real estate brokers at Quinlan and Tyson (defendant) routinely prepared not only offers to purchase but also deeds and other title-transfer documents by filling in attorney-drafted standard forms with client-specific details; the Chicago Bar Association (plaintiff) sued to enjoin this practice as the unauthorized practice of law, and the trial court agreed except for offer-to-purchase forms, which it found were a necessary incident of brokering; the appellate court reversed that exception entirely, and Quinlan and Tyson appealed.
Whether a real estate broker's preparation of legal documents beyond simple purchase offers, including deeds and title-transfer instruments, constitutes the unauthorized practice of law, and whether filling in standardized purchase offer forms is similarly restricted.