How have courts interpreted the principles of the Virginia Pharmacy case in the context of a disciplinary rule forbidding attorney advertising?

Finally, we take note of the recent case of Bates v. State Bar of Arizona (1977) 433 U.S. 350, 97 S.Ct. 2691, 53 L.Ed.2d 810. There the high court held that the principles announced in the Virginia Pharmacy case precluded the application of a disciplinary rule forbidding attorney advertising to the particular advertisements before the court, ⁶ which it characterized as "truthful (newspaper) advertisement concerning the availability and terms of routine legal services." (Id., at p. 384, 97 S.Ct. at p. 2709.)

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