In the case of Silvia S. Ibanez v. Florida Department of Business and Professional Regulation, Board of Accountancy (1993), attorney and certified public accountant (CPA) Silvia Ibanez was reprimanded by the Florida Board of Accountancy for using her CPA designation in her law practice advertisements without a disclaimer stating that this certification did not indicate state approval or endorsement. The board argued that such usage could potentially mislead the public into believing she had special qualifications beyond those necessary to be licensed as an attorney. Ibanez filed suit against the board, arguing that its actions violated her First Amendment rights to free speech. The Supreme Court ruled in favor of Ibanez, finding that there was no substantial government interest being served by restricting truthful commercial speech about lawful activities simply because it might potentially be misleading. The court held that if any potential confusion existed among members of the public regarding professional certifications, it should be addressed through disclaimers or explanations rather than outright bans on certain types of advertising content.

In the dissenting opinion for Silvia S. Ibanez v. Florida Department of Business and Professional Regulation, Board of Accountancy, it was argued that the state had a legitimate interest in regulating professional advertising to prevent deception or confusion among consumers. The dissenting justices believed that Ms. Ibanez's use of her CPA and CFP credentials on her law firm advertisements could mislead consumers into thinking she has special qualifications in areas where she does not necessarily have them, such as tax law or financial planning related to legal services. They also pointed out that while truthful commercial speech is protected by the First Amendment, states can regulate potentially misleading information if they believe there is substantial government interest involved.