The Arizona Supreme Court addressed the unauthorized practice of law by land title and trust companies. The State Bar argued that these commercial entities were illegally engaging in legal practice by preparing complex legal instruments—such as deeds, mortgages, and trust agreements—for their customers incident to their title-insurance transactions. The court ruled in favor of the State Bar, holding that while title companies may prepare simple, routine forms strictly necessary to their own business, they cannot draft instruments or provide legal advice affecting the substantial legal rights of third parties. The decision established strict definitions for what constitutes the "practice of law" in Arizona, emphasizing that commercial entities cannot bypass the ethical obligations and court discipline required of licensed attorneys.

The Arizona Supreme Court affirmed the findings of the State Bar. The Court emphasized that an attorney's failure to promptly account for and pay over money collected for a client is a severe breach of professional duty. Taking into consideration the mitigating and aggravating circumstances of the case, the Supreme Court ordered that Holohan be officially censured for his misconduct.