other than simple retail transactions, which arise in the usual course of the car dealer’s business; (4) The forms must be used only in connection with motor-vehicle-sale transactions actually handled by the car dealer as a motor-vehicle dealer; (5) The car dealer must not charge for filling in the blanks; and (6) The car dealer must not give advice or opinions as to the legal rights of the parties, as to the legal effects of instruments to accomplish specific purposes, or as to the validity of the contract.71 The court declined to offer a reason for extending this exception to car dealers, saying only, “While we are cognizant of the fact that the forms at issue in this case do not involve real-estate matters, it is clear to this court that the restrictions set forth in Suggs have equal application to the forms used in the motor-vehicle-sales business.”72 Conclusion Typically, the unauthorized practice of law arises in three scenarios: (1) the practice of law by a nonlawyer; (2) the practice of law by an attorney not licensed to practice in Arkansas and not admitted pro hac vice; and (3) the practice of law by a corporation. The Arkansas Supreme Court, however, has created two exceptions to the prohibition against the unauthorized practice of law. First, in 1963, the court began allowing real estate brokers, within certain restrictions, to fill in the blanks of legal documents without thereby engaging in the unauthorized practice of law. Then, in 2011, the court extended this exception to car dealers. Interestingly, when the court chose to allow car dealers to fill in the blanks of legal documents, it stated, “[T]his court . . . has remained steadfast . . . that the completion of forms legal in nature by nonlawyers, while ordinarily the practice of law, may be permitted, but only within very certain, specific parameters.”73 This language suggests that other businesses—not just real estate brokers and car dealers—may fill in the blanks of legal documents. Indeed, it is likely that other businesses—such as title and abstract companies, rent-to-own businesses, and car rental companies—may now fill in the blanks of standardized, preapproved legal documents, under restrictions similar to those set out in Suggs74 and Campbell,75
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without thereby engaging in the unauthorized practice of law. Endnotes 1. See Preston v. Stoops, 373 Ark. 591, 594, 285 S.W.3d 606, 609 (2008); McKenzie v. Burris, 255 Ark. 330, 341, 500 S.W.2d 357, 364 (1973); see also Ark. Const. amend.
XXVIII (LEXIS Repl. 2004) (“The Supreme Court shall make rules regulating the practice of law and the professional conduct of attorneys at law.”). 2. See Ligon v. Stilley, 2010 Ark. 418, at 3, 371 S.W.3d 615, 623; In re Petition of Anderson, 312 Ark. 447, 451–52, 851 S.W.2d 408, 410 (1993); McKenzie, 255
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