THE FLORIDA BAR
v.
ELIZABETH HIDALGO
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A person who violates a prior court order enjoining unlicensed practice of law may be found guilty of indirect criminal contempt and subjected to probation, GPS monitoring, and a suspended jail sentence.
[1] A person may be found guilty of indirect criminal contempt for violating a prior court order enjoining unlicensed practice of law, subject to probation, GPS monitoring, a…
Previewing 1 of 1 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“This court's administrative authority extends only to the privilege being regulated. That means a person is subject to this court's regulatory authority at all only if he or she applies to be admitted to practice law or in fact has been admitted to practice law.”
Justice Tanenbaum's dissent arguing the Court lacks constitutional authority to regulate non-admitted persons
Elizabeth Hidalgo had been previously enjoined by Florida Supreme Court orders in 2004, 2014, and 2021 from engaging in the unlicensed practice of law…
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Supreme Court of Florida
THURSDAY, JULY 2, 2026
The Florida Bar, Petitioner(s)
v.
Elizabeth Hidalgo, Respondent(s)
SC2025-0636
Lower Tribunal No(s).: 20244074(11D)
The uncontested report of the referee and plea agreement are approved and Respondent Elizabeth Hidalgo is found guilty of indirect criminal contempt for violating previous orders of this Court. See Fla. Bar v. Hidalgo, 888 So. 2d 624 (Fla. 2004); Fla. Bar v. Hidalgo, 139 So. 3d 888 (Fla. 2014); Fla. Bar v. Hidalgo, No. SC2021-1264, 2021 WL 4317401 (Fla. Sep. 23, 2021). Respondent is placed on probation and GPS monitoring for five months subject to the probationary supervision of the Advocate Program or similar program and must pay the costs associated with the probation and GPS monitoring to the Advocate Program, under the terms and conditions set forth in the report and plea agreement.
As a condition of probation, Respondent is sentenced to five months in the Miami-Dade County Jail. However, the jail sentence
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shall be suspended pending completion of probation and GPS monitoring, including abiding by all of the conditions of probation as specified in the report and plea agreement.
Respondent shall not engage in the unlicensed practice of law and the orders dated October 28, 2004, April 15, 2014, and September 23, 2021, enjoining Respondent from engaging in the unlicensed practice of law in Florida shall continue in their present form. See Hidalgo, 888 So. 2d at 624; Hidalgo, 139 So. 3d at 888; Hidalgo, 2021 WL 4317401, at *1. Respondent is directed to comply with all other terms and conditions of the report and plea agreement.
Judgment is entered for The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2300, for recovery of costs from Elizabeth Hidalgo in the amount of $1,692.71, for which sum let execution issue.
COURIEL, C.J., and LABARGA, MUÑIZ, GROSSHANS, FRANCIS, and SASSO, JJ., concur.
TANENBAUM, J., dissents with an opinion.