Presently North Carolina, like many other states, regulates many of the advertising activities of professionals. Friedman v. Rogers has increased the burden of proof on the states in justifying their regulation of commercial speech; and the FTC decision has removed most ethical restrictions on physician advertising, which is very significant to North Carolina, given the extensive prior regulation. With the recent trends in the application of the first amendment to commercial speech, evidenced by Friedman and the FTC's entry into the field, state regulation and ethical restrictions on professional advertising must be liberalized if they are to survive these challenges.
Lex Allen Watson II, Constitutional Law - Health Care Professionals Seek to Advertise, 2 Campbell L. Rev. 173 (1980).