ABSTRACT
In Bates v. State Bar of Arizona (1977), the US Supreme Court interpreted the First Amendment's free speech and press guarantees to protect commercial speech by lawyers. Thereby extending the reach of the Court's earlier decision in Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc., (1976), which had protected the rights of pharmacists to advertise prices and credit terms for prescription drugs. Bates involved the case of two Arizona lawyers, John Bates and Van O'Steen, who operated a legal clinic in Phoenix providing moderately priced legal services. Bates and O'Steen argued that their commercial speech was protected by the First Amendment under the precedent the Court had established in Board of Pharmacy one year earlier. As in Board of Pharmacy, the majority in Bates noted that the First Amendment's protection of commercial speech was not as extensive as its protection of political speech.
