Unfair Trade Practices and the Practice of Law

By Jeffrey P. Lewis

 

            Many plaintiffs assert a claim under the Unfair Trade Practices and Consumer Protection Law (UTPCPL), 73 Pa.C.S. §§ 201-1 et seq. in professional liability actions against lawyers. The appeal of such a claim lies in the fact that (unlike in a claim for legal malpractice or breach of fiduciary duty) it allows, at the court’s discretion, an award of treble damages, costs and reasonable attorney fees. UTPCPL protects “[a]ny person who purchases or leases goods or services primarily for personal, family or household purposes and thereby suffers any ascertainable loss of money or property … as a result of the use or employment by any person of a method, act or practice declared unlawful by … this act … .” So, the argument goes, “services” in this context would include legal services and the “method, act or practice declared unlawful” by UTPCPL would include conduct that also constitutes legal malpractice or breach of fiduciary duty.

The majority of courts in other jurisdictions — all of which have similar consumer protection laws and have considered this issue — conclude that these laws do not apply to conduct that constitutes the practice of law. Some jurisdictions recognize an exception to this exclusion for conduct involving the entrepreneurial aspects of law practice. This would include, for example, debt collection and advertising. Although several lower Pennsylvania courts have weighed in on this issue in the past, only recently has the Pennsylvania Supreme Court considered UTPCPL’s application to lawyer conduct.

            In Beyers v. Richmond, --- A.2d ---, 2007 WL 4557840 (Pa.), decided December 28, 2007, the court holds that a lawyer’s conduct in distributing settlement proceeds constitutes the practice of law such that UTPCPL cannot apply. The case involves a lawyer who converted settlement funds and prepared a settlement distribution sheet that includes deductions for unsubstantiated costs. Five of the seven justices voted to reverse the Superior Court, which had affirmed the trial court’s finding that UTPCPL does apply to this conduct.

Then-Chief Justice Ralph J. Cappy, in one of the last opinions of his career as a jurist, and Justice Max Baer, however, find that only statutory construction of the law is necessary to conclude that it does not apply to this conduct. Justices Ronald D. Castille, Cynthia A .Baldwin and James Fitzgerald III, who wrote the plurality opinion, find that UTPCPL implicates the state constitution because it presents an unconstitutional intrusion by the legislature upon the court’s power to regulate the practice of law. Based upon the separation of powers doctrine, Article V Section 10(a) and Section 10(c), as the court interprets it, grant the court the exclusive power to monitor and regulate the practice of law. Instead, in the plurality’s view, Pennsylvania’s Rules of Professional Conduct and Rules of Disciplinary Enforcement “exclusively address the conduct complained of in this case.”

Justice J. Michael Eakin wrote a dissenting opinion, joined in by Justice Thomas G. Saylor. Although they recognize the court’s responsibility under the state’s constitution to supervise the practice of law, they also chide the plurality “for unrealistic micromanagement over provisions of general applicability.”  In their view, UTPCPL should withstand state constitutional muster because it is a law of general applicability where some of the persons it applies to “happen to be attorneys.”

From its review of other case law, the plurality would apply or not apply UTPCPL based upon whether the conduct complained of constitutes the practice of law. The two concurring justices would agree. Therefore, there appears to be little danger that UTPCPL claims will now ordinarily accompany lawyer malpractice claims, even, as here, where liability is premised upon intentional conduct. The majority, contrary to the Superior Court below, views the misdistribution of settlement proceeds as the practice of law.

But the plurality’s separation of powers approach raises another intriguing question: If the UTPCPL constitutes an impermissible intrusion by the Legislature upon the Supreme Court’s exclusive power to govern the practice of law, although it has general application, then does not the same fate befall other such statutes? For example, the Dragonetti statute applies to both lawyers and other persons who wrongfully bring a civil action. Indeed, the Supreme Court has promulgated Pa.R.C.P. 1023.1 et seq. to also address such conduct. No one would argue that a lawyer was not practicing law when he or she engaged in such conduct. Yet the Legislature provides a statutory remedy for such conduct. Maybe a distinction can be drawn because the legislation was replacing a common law tort to address such conduct. But this is not the case, for example, with respect to the passage of 42 Pa.C.S.A. Section 2503(7), which allows for the award of attorneys’ fees against parties and their lawyers for obdurate, vexatious and/or bad faith conduct. These statutes are the product of the Legislature and they seek to govern the conduct of lawyers engaged in the practice of law. How, the argument would go, would they also not violate the separation of powers doctrine if UTPCPL does? These are questions that have not yet been raised, and their resolution must wait for another day.

 

Jeffrey P. Lewis is a partner in the West Chester office of the Pittsburgh-based law firm of Eckert Seamans Cherin & Mellott L.L.C. He serves on the PBA Professional Liability Committee and is a PBA Zone 9 delegate.