Janson v. LegalZoom.com, Inc.
United States District Court for the Western District of Missouri
802 F. Supp. 2d 1053 (2011)
Janson and other customers (plaintiffs) sued LegalZoom (defendant) for unauthorized practice of law after using its website, which turned customer questionnaire answers into legal documents like wills and business-formation filings; nonlawyer employees reviewed submissions for completeness, inconsistencies, and errors, contacted customers to clarify issues, and provided customer service, though the site itself gave no direct legal advice. LegalZoom argued its service was merely a "self-help kit," akin to selling blank forms that customers filled out themselves. Janson moved for summary judgment.
Whether the drafting of documents in a representative capacity for use in connection with a legal proceeding constitutes the practice of law.