Inspectors with the U.S. Food and Drug Administration slapped St. Jude Medical with a warning letter accusing the medical device maker of failing to properly investigate problems with the batteries in its implantable defibrillators and the cybersecurity of its at-home monitoring equipment.

It had been three years since the U.S. Supreme Court held in Bates v. State Bar of Arizona that the traditional ban on lawyer advertising was unconstitutional. States were starting to carve out their own ethical rules that covered how attorneys could (and could not) market their services to the general public.