Does a state statute requiring an attorney to disclose certain terms under which his services can be advertised require that the attorney's advertising must contain a disclaimer?

Although we have concluded that a compelling state interest justifies the legislation at bar, where commercial speech is affected, the state need only show a reasonable relationship between the statute and the state's interest in preventing deception of consumers. (Zauderer v. Office of Disciplinary Counsel, supra, 471 U.S. at p. 651, 105 S.Ct. at p. 2281.) In Zauderer, the court examined a state statute which required that any advertising by an attorney contain certain disclosures about the terms under which the attorney's services would be available. The court's explication of the constitutional considerations is equally applicable in this case: "Because the extension of First Amendment protection to commercial speech is justified principally by the value to consumers of the information such speech provides, [citation], appellant's constitutionally protected interest in not providing any particular factual information in his advertising is minimal. Thus, in virtually all our commercial speech decisions to date, we have emphasized that because disclosure requirements trench much more narrowly on anadvertiser's [235 Cal.App.3d 592] interests than do flat prohibitions on speech, 'warning[s] or disclaimer[s] might be appropriately required ... in order to dissipate the possibility of consumer confusion or deception.' [Citations.]" (Id., at p. 651, 105 S.Ct. at p. 2282, emphasis in original.)

In resolving the constitutional challenge in Zauderer v. Office of Disciplinary Counsel, supra, 471 U.S. at page 652, footnote 14, 105 S.Ct. at page 2282, footnote 14, the court concluded: "The right of a commercial speaker not to divulge accurate information regarding his services is not ... a fundamental right."