The U.S. Supreme Court case Fred H. Edenfield, et al. v. Scott Fane (1992) centered around a First Amendment challenge to a Florida ban on solicitation by Certified Public Accountants (CPAs). The plaintiff, Scott Fane, was a CPA who wanted to directly solicit businesses in person or over the phone for accounting services but was prohibited from doing so by the Florida Board of Accountancy's rules against direct uninvited solicitation. He argued that this rule violated his First Amendment rights to free speech. The court ruled in favor of Fane with an opinion delivered by Justice Byron White stating that while states have power to regulate commercial activities and professions such as accountancy, they cannot infringe upon protected speech without showing how it advances state interests and why less restrictive alternatives would not achieve those same goals effectively. In this case, the court found no substantial government interest being advanced through banning CPAs' direct solicitation nor any real harm caused by allowing it; therefore ruling that the ban constituted an unconstitutional restriction on free speech.

In the dissenting opinion for Edenfield v. Fane, Justice Blackmun argued that the majority had misapplied Central Hudson's four-part test for commercial speech restrictions. He believed that Florida’s ban on direct solicitation by Certified Public Accountants (CPAs) served substantial state interests in maintaining professionalism and avoiding fraud or overreaching. The majority failed to appreciate these concerns, he said, because they misunderstood how CPAs operate differently from other professionals who were allowed to solicit business directly under previous rulings of the court. In his view, this misunderstanding led them to underestimate both the potential harm of CPA solicitation and the benefits of its prohibition. Furthermore, he contended that less restrictive alternatives suggested by Fane would not adequately serve these interests as effectively as a complete ban did.