Plaintiff attorney sued defendant online legal services provider for, inter alia, violation of the California Unfair Competition Law (UCL) based on the unauthorized practice of law. The provider purportedly undercut the competition by using unlicensed persons to perform legal work. The Orange County Superior Court, California, sustained the provider's demurrer without leave to amend. The attorney appealed.
Overview:
The court concluded that the attorney alleged an identifiable trifle of injury sufficient to withstand a demurrer. The attorney alleged that he suffered losses in revenue and asset value and was required to pay increased advertising costs specifically because of the provider's unlawful business practices. To have standing under the UCL, the attorney was not required to have engaged in business dealings with the provider. The court saw no reason why the alleged violation of statutes concerning the unauthorized practice of law could not serve as a predicate for the attorney's UCL action. According to the attorney, the provider's unlawful business practices had taken customers away from him.
Outcome
The judgment was reversed, and the matter was remanded.