Friday, February 01, 2013
The Brilliant Future of America's Law Schools
The conventional wisdom-served up one suspects with more than a soupcon of Schadenfreude by certain journalists-is that America's law schools are a declining industry.
Application for JD slots are down-we all know that. But even assuming that's a longer-term trend rather than a reflection of th economic anxieties and difficulties of the last years, there is no reason for panic or despair. The potential of America's law schools is only starting to be realized.
The global market for US legal education was traditionally regarded as composed of a relatively small group of foreign-educated lawyers seek advanced degrees. But this changing. Increasingly, a US JD degree is an attractive option for foreign students. And you have probably noticed more non-US JDs in your classes. In most countries law is the subject of a first degree after high school. The market could be expanded of US law schools were to offer a combination undergraduate degree in another discipline and a law degree-what about a 5 or 6 year program that leads to a BA in economics or political science or philosophy and a JD?
The fact is that American law schools have a competitive advantage. To be sure there is excellent legal education in some other countries. But my considerable global experience suggests to me that those countries are few. In most places, legal education is dominated by old-fashioned rote learning and by professors who spend much if not most of their time in private practice. Innovation is rare and slow. Class sizes are often huge.
If we are not distracted by US News rankings, we will observe that in all kinds of law schools all across the US there are world class intellectuals and leading specialists on the faculty. Of course national law schools abroad have a captive audience of students who can't study in English and/or whose first and immediate priority is to qualify for the local bar or who can't afford foreign study (though we can reach out to the last group through distance education and foreign campuses). But overall the number of students with global ambitions, and the prevalence of English as a global language of law, are growing, from what I can tell.
Another trend is that while there is perhaps an oversupply of practicing attorneys in America (how temporary hard to know), we live in an increasingly legalized world, where the practice of many professions (including journalism!), the advanced study of other disciplines such as political science or economics, and the management of a business require a more than trivial knowledge of law. Law schools need to be imaginative in designing and packaging legal education for non-lawyers. I have always enjoyed the opportunity to teach non-lawyers and non-aspiring lawyers. It is a different experience but a rewarding one in its own right.
Then there is executive education. In general business schools are way ahead of us there. Some of the winds of change imply the need for more legal education throughout an attorney's lifetime, not less-the need to be specialized and constantly renew and add knowledge based on changing markets. Executive education and continuing education can also have a global dimension for reasons I've already mentioned. Such programs can reinforce or even build international alumni networks, supporting law schools' student recruitment and development goals.
I started as a scholar writing about industrial policy. The stories about industries able to turn the winds of change to their advantage through restructuring and redefining their markets always interested me more than those about the failure to adjust. Given the collective intelligence, knowledge and imagination in our law schools I'm bullish and, as part of the legal academy myself, proud to be.
Posted by Rob Howse on February 1, 2013 at 05:26 PM | Permalink
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Some schools may indeed have a brilliant future, just as a tree might if a brush fire were to consume its nearest competitors for sunlight and water.
Not everybody gets to be a majestic redwood, though.
Posted by: Morse Code for J | Feb 1, 2013 6:43:35 PM
The cowardice and intellectual puniness of some of the anonymous comments simply astounds. I've deleted them. If you have an argument, make it, and use your name.
Posted by: Dan Markel | Feb 1, 2013 10:36:44 PM
"To be sure there is excellent legal education in some other countries. But my considerable global experience suggests to me that those countries are few. In most places, legal education is dominated by old-fashioned rote learning and by professors who spend much if not most of their time in private practice. Innovation is rare and slow."
This dismissive description of non-American legal education strikes me as remarkably overbroad. Care to name names? You are certainly not describing New Zealand or Australia, where (in addition to the US) I've held permanent positions. You aren't describing Canada (especially not your alma mater). You aren't describing most UK law schools. You certainly aren't describe the Netherlands or most Scandinavian countries. You may be describing some German law schools, but definitely not all. Are you describing Asia? Perhaps, though not the elite law schools like National University of Singapore. Traditional civilian countries like France? The fact that their legal systems are based on codes instead of cases hardly means that their legal education is simply "rote" and taught by practitioners who have no interest in larger intellectual issues.
Frankly, I'm not even sure how well you are describing American legal education. Your rosy view of innovative teaching orchestrated by full-time academics dedicated to legal scholarship clearly applies to elite American law schools, but does it really describe the situation at lower-ranked law schools -- even quite prestigious ones? It certainly doesn't describe the top-30 American law school at which I taught, whose approach to pedagogy is basically indistinguishable from most of the Australian and New Zealand law schools with which I'm familiar.
If you are going to uncritically assume the superiority of American legal education over the rest of the world, I think it behooves you to be a bit more specific.
Posted by: Kevin Jon Heller | Feb 1, 2013 11:58:12 PM
"Increasingly, a US JD degree is an attractive option for foreign students. And you have probably noticed more non-US JDs in your classes. In most countries law is the subject of a first degree after high school."
I agree with you about the greater value of a JD on the international market -- that is now the only practice-oriented degree we offer at Melbourne (in addition, of course, to the great JD/JD option we offer in conjunction with your law school!), and we made the change precisely to maximize the marketability of our law graduates. I also agree that a JD can be a significant draw for students in systems where law is an undergraduate subject; about 15% of our JD students are from outside Australia, including a number of Americans and Canadians.
I question, though, whether the US is particularly well-suited to attracting foreign law students who don't intend to practice in the US. To begin with, American legal education is absurdly insular -- far more so than legal education anywhere else I can think of. Outside of the elite American law schools, students receive almost no education in international law. Comparative law is almost non-existent. All, or nearly all, of the professors are American. Exchange options are limited -- and many foreign law schools are off the table, no matter how elite, because they don't offer graduate classes. How much do most non-elite American law students know about how law functions in the rest of the world when they graduate? I'd venture it is vastly less than law students who graduate from law schools almost anywhere else.
And then, of course, there is the expense of American legal education. Why would a large number of foreign students want to spend $200,000 on an American JD when they can get elite law degrees in their home countries for next to nothing and can attend elite non-American law schools for half the price (as is the case with Melbourne)? And why would they want to spend that much money on anything other than an elite American law school? Would it make any sense at all for the average European or Asian law student to pay American tuition at William Mitchell, which no one outside of the US will have ever heard of?
I think it is a pipe-dream to believe that non-elite American law schools will ever be able to attract a large number of foreign students who want to practice outside of the US. The teaching in the US may be slightly better, but the expense is vastly greater -- and the value of a JD compared to an LLB, though certainly far from zero, is simply not significant enough to justify the expense, especially in light of the lower salaries that characterize legal practice in most non-American legal markets.
Posted by: Kevin Jon Heller | Feb 2, 2013 12:24:53 AM
I agree with you about almost all of the countries you describe, though I do believe that France does, with some few exceptions, correspond to my description (and I am so impressed with the heroic efforts of French colleagues to try to change that). That is why I was very careful to note that I was making a generalization and that there are excellent institutions elsewhere. You have identified some of them, and there are others-in Brazil, Argentina, Switzerland, Holland,Israel,China, Hong Kong, Korea, South Africa, inter alia. Yet many of these very institutions are themselves open to approaches to legal education that are characteristically American, at least in origin. And that was the case with the law school where I started my studies, Toronto.
I'm Canadian and I am not simply uncritical of American legal education. It has it own problems and pathologies. But at the same time a great deal of promise in our current global environment. That was my point. One could refer to the distinction in trade theory between absolute and comparative advantage. Even where US legal education doesn't have anything like an absolute advantage it might have a comparative advantage. But this is consistent with thinking that there are institutions in Australia and the UK and Germany and Canada and Brazil and China and South Africa and elsewhere might also have their own comparative advantages in parts of the global market.
I think the ranking is a red herring. What matters is the practices and the norms and the people. When I arrived at Toronto the school was still in part mired in the older approach of rote learning that I refer to (so this is not a civilian vs. common law thing, contrary to what you suggest). The US model-albeit idealized-helped move beyond that at Toronto (but I was among the first to dissent when it was held up as a dogma rather than what made sense).
My point is not at all one of complacency and self-satisfaction. As I have suggested, US institutions will need to reach out and adapt themselves to attract the markets in question. And indeed this would involve in some cases serious self-examination. But I want that to happen with a spirit of confidence and hopefulness and a sense that we have something important to give to the world, not out of any arrogant notion of inherent superiority but from the felicitous confluence of our strengths with the demands of the times.
Posted by: Rob Howse | Feb 2, 2013 12:48:20 AM
Clay Christensen says that one of the precursors to disruptive innovation is that incumbents become committed to producing a product that is TOO GOOD for the existing market, thus providing an opportunity for new entrants to compete by providing a slightly inferior product at a substantially lower price. Domestically, the problem is not so much a lack of demand for legal services -- ask any legal aid attorney about that -- but the fact that the high cost of legal education has caused us to price ourselves out of much of the market.
Rob is right that much of legal education worldwide is rote, and that American law schools can help fill a market niche (especially, I think, if we retool a bit to teach a competency-based curriculum like Bill Henderson advocates in A Blueprint for Change, in addition to the analytical reasoning that we teach now). The challenge will be to do this in a way that doesn't price ourselves out of the global market in the way that we've already priced ourselves out of the non-elite segment of the domestic market.
Posted by: Rick Bales | Feb 2, 2013 3:19:06 AM
This article seems to show that law professors are now at the 3rd of the Kübler Ross stages of grief - which is good - I mean leaving the denial behind. So this one is "bargaining" the belief that some miraculous change will postpone the inevitable.
Law school capacity is 50,000 graduates or thereabouts a year for 22,000 jobs. Moreover, law schools have a serious productivity issues which means that their costs are about 2 times market ability to pay. A market correction therefore would involve a 50% reduction in capacity and a two-fold increase in productivity. That means that the market can support 1/4 of the current number of law professors, 3,000 instead of 12,000
The idea that this problem will be solved by recruiting twenty to forty thousand foreign law students per year, in indeed 3 times that many to make up for the fact that an LLM is a 1 year program is imaginative but unlikely. One additional issue - a J1 or F1 student visa holder is not entitled to federally insured student loans - so they would have to come up with the tuition and living expenses in cash. That is a lot of well-heeled LLM candidates.
Posted by: MacK | Feb 2, 2013 8:59:55 AM
As for executive education, the legal profession is awash in CLE programming. Various professional organizations such as the Defense Research Institute and specialized ABA groups offer programs that have business development potential for lawyers in addition to providing advanced education in specialties--something that law school executive education programs seem unlikely to duplicate in any meaningful fashion. As for training non-lawyers, the business law classes in most business schools do quite nicely for most folks. The unfortunate fact is that difficult change is coming to some law schools, and this sort of nibbling around the edge--assuming there is any nibbling to be done in actuality as compared to your speculation--is no answer.
Posted by: Doug Richmond | Feb 2, 2013 10:04:59 AM
One problem I see with this optimistic vision of US law schools is its reliance on 1) persons who do not intend to enter the legal industry and 2) wealthy foreign students.
Certainly there are law courses which would benefit (and, more importantly, can be sold to) the first group, but probably not a whole degree's worth of them. Law courses for non-law students are a stop-gap at best.
As for the second group, it seems to me that the more a country's would-be lawyers become able to pay for a US JD, the less they will need to as their local and regional institutions become increasingly good. I'm from Singapore and I'm not sure I know of a single lawyer here with a US JD--though there are plenty with English LLBs (or equivalents) and a smaller number with US LLMs. Which suggests another basic problem with this vision: foreign students who want an internationally recognised law degree taught in English can generally get it far more efficiently in the form of an LLB. In that light, the JD is a tough sell.
Posted by: Nicholas Liu | Feb 2, 2013 10:44:29 AM
I will add one additional point. I am an international lawyer and as such I spend a lot of time in Asia and Europe. The problem of overproduction of law graduates - and indeed of lawyers (law graduates licensed to practice) is worldwide. The UK alone produces somewhere around 20,000 law graduate a year for about 5-7,000 training places as solicitors and barristers; there is a similar excess in France, Spain, Italy, Ireland, etc. Japan too produces far too many law graduates, although only a small fraction take any sort of licensing exam - about 2% qualify as Bengoshi.
Moreover, most non-US legal systems are much less lawyer intensive than the US, with a large array of alternate professional suppliers of legal services, from the Japanese legal scrivener ("shihō shoshi"), civil notaries, etc. There are simply not armies of non-US applicants for law school in the US, certainly not the numbers that would need to come to the US to fix the demand issue. Indeed, I think the numbers of LLMS has probably plateaued.
Posted by: MacK | Feb 2, 2013 11:21:31 AM
I worry about the LLM situation. In my experience, many of them are early in their careers and hope that a US degree and bar admission will accelerate their career path back home. Again, in my experience, the quality of the students varies enormously, but far too many of them are not professionally proficient in spoken and written English. I worry that they will be treated as the new cash cows as the LLM gets monetized.
Posted by: John Steele | Feb 2, 2013 11:53:37 AM
I think not only do you overestimate the value of a lower tier US degree in the international market, but you also ignore the efforts in many foreign markets to reform and improve their legal educational offerings. The Peking University School of Transnational Law in Shenzhen (where I teach), HEAD in Paris, St. Gallen in Switzerland, National Law School of India University, IE in Spain, and many more are pursuing new models of legal education previously not found in those countries. Last year, every graduate in STL's first graduating class obtained at least one job offer requiring a law degree; that cannot be said for either the US or international graduates of most US law schools. (No data is available, but based on anecdotal evidence I believe the placement results for international students at lower ranked law schools will prove to be even more scandalous than the results for US based students).
In short, the US has no monopoly on offering a US style legal education. In a world where US style education can be replicated, the US schools are distinguishable by only one criterion - an ABA accreditation is needed for a school to qualify students for most American bar exams. To the extent eligibility for US practice matters for partner track hiring at US or UK based international firms, this, rather than educational quality, provides an advantage to the US schools. The ABA committee on legal education has decided - perhaps focusing on the parochial interests of lower ranked law schools rather than on aspirational values such as spreading the rule of law - that only US schools, no matter how lowly ranked and no matter how poor an investment, can be considered for accreditation. The bar and the legal academy will need to decide in coming years whether protecting the tuition income streams of lower ranked schools or promoting the rule of law worldwide are more closely related to their missions and core values. The goal should not be promoting US law schools, but promoting more basic values.
Posted by: Ray Campbell | Feb 2, 2013 3:07:37 PM
Since I am multi-country admitted and work with a good few of these LLM types it is a bit more complex. We are an international firm, heavy technology, and I was a GC of a NASDAQ, LSE, German Stock Exchange listed company. For someone like that knowing US law is important - and UK and Japanese. So there is a market for a small group of transnational lawyers. Most work in high end commercial law, IP law, some antitrust/competition and a small amount of litigation. However, the ones that find an LLM in that situation useful are already top-drawer in their home jurisdiction - or they are US trained trying to work in say Europe and taking a QLTT.
To really have value the LLM needs though to combined with 2+ years of actual practice in the US - and perhaps other jurisdictions. The subset of these jobs in say BigLaw is very small - so the idea that there is a huge desire for US LLM's is simply tosh. Moreover, the school the LLM is obtained from has to be recognisable in the non_US country. Thus it has to have name recognition outside the US - and the schools who have a recognised brand outside the US are limited, and mostly located in major US cities (not semi-rural schools.) So strongest name recognition outside the US seems to be Harvard, Columbia, Georgetown, Stanford, UCLA, maybe Chicago. Yale actually is not as well known outside the US as say Harvard, Columbia, Georgetown, which gets a huge fillip from being in DC.
Posted by: MacK | Feb 2, 2013 3:11:27 PM
As a recent graduate of a lower-ranked school, awash in the current stormy legal employment market, I have to agree with many of the commenters above. The simple truth is that the law schools, the more so the lower ranked they are, have swamped the employment market. If possible law school applicants get hip to this and continue to stay away, some schools will fold, AS THEY SHOULD. A business that can't provide a good that has real-world value to the buyer SHOULD go out of business.
As to the idea that international students will make up the gap: if there are so many transnational law positions available to these international students, why aren't U.S. graduates getting some of them? If there aren't, what use is a JD to foreign students as anything other than a prestige degree? I don't think we can expect foreign students to pay $1-200,000 for the privilege of a legal education with zero real-life benefit any more than we could expect U.S. students to do so. Never mind the idea that advanced legal professionals would look to academicians rather than their own experienced colleagues for continuing legal education.
Posted by: Ursula | Feb 3, 2013 4:06:14 PM
"As to the idea that international students will make up the gap: if there are so many transnational law positions available to these international students, why aren't U.S. graduates getting some of them?"
To be blunt, U.S. graduates are getting over half of these positions - maybe as much as 3/4 ... there are so few of these positions though...
One of the reasons I do not use my name is that a lot of people would say - "oh him!" - and I suspect "that asshole!" and "I don't know how ____ makes a living and why ____ , ____ and _____use them." The transnational legal space is a small one, we all have a Kevin Bacon like degree of separation of maybe 2, possibly 3 - but rarely 5 or 6, across 40+ jurisdictions.
Posted by: MacK | Feb 3, 2013 9:20:37 PM
I would like to chime in and bring forward my point of view - that of an Italian recent graduate. I am quite a frequent visitor in the US and seriously considered the idea of pursuing a JD there. I went as far as speaking with admission officers in a number of institutions. There are, however, several problems with this idea. I will try to summarize them as follows, also recycling a comment of mine I had already posted on OJ:
1) I take that in some cases a JD might be appealing to those who do not already hold a first degree in law. In my experience, the only people I have been interested in pursuing a JD were law graduates. In most European countries, however, law is not only taught at the graduate level. In Italy, for example (but the same applies, more or less, in France, Germany, and so on.) one has to study law for five years in order to get his first [usable] degree in law;
2) American law schools exercise a great fascination on many an Italian graduate: there are many reason for that, but almost everyone would like to go abroad for a while and enroll in a challenging program. However, those who eventually do that have to consider a number of aspects, among which it is worth mentioning:
2(a) Cost: few are able to afford an LLM degree there, let alone a JD. Eligibility for federal loans or equivalent forms of financial aid could be a game changer, but it is understandable that the US will maintain things as they currently are. Likewise, it would be a little far-fetched to expect European Countries to develop student loan schemes modeled after the American ones when education in here is exponentially cheaper;
2(b) Job opportunities: some choose to enroll in an LLM program anyways and then take the NY bar exam, but to what purpose? Of course, they cannot even begin to think about competing with someone with a JD for corporate law firms jobs. On the other hand,
2(c) the NY Court of Appeals rules prevent them from taking too many specialized courses. What do they do, then? They come back to Europe or other foreign legal markets where their qualifications are still something that matter. Corporate law firms here once sought to hire lawyers holding an LLM degree from an American law school, and the latter could then quickly repay their – still reasonable, compared to the cost of a JD – investment. However, competition has grown tighter as more graduates started going down this road, and an LLM has become the “conditio sine qua non”, rather than a substantial asset.
3) The "ones who don't really care about getting rich": some people are still able to do an LLM in the US (or even a JD, maybe) and eventually a highly-paid corporate job and be able to repay their dues. The same does not really apply to those wishing to work in [at least some areas of] the public sector. Sky-high tuition fees are at variance with low paid jobs. Furthermore, in some fields, such costs become hardly justifiable as top-notch schools in the United Kingdom (for example) offer top level graduate degree programs for a quarter of the cost or less (Oxbridge, again) and those offered by other great schools in Europe do not even come close to these figures;It seems that at least in some fields attending a law school in the US is simply not worth the cost, and sadly so, since there are some great schools with top level faculties.
4) This said, I would gladly spend three years studying law in the US, but I really cannot afford it. Our tuition fees are around 2,000 Euros per year (and lower if your income is not in the highest bracket). I can say I have received an overall good education. In some cases, a first class education, as I have also been lucky enough to learn PIL from a current ICJ judge and former ILC member. After five years of legal education here, however, I have decided to take the leap and enroll in an LLM program before I apply for a PhD, and I am going to do so in a top school in the UK. I have also applied to a few schools in the US, but I would never be able to go there without a scholarship. One of the reasons why I have made this decision is because I would prefer to pursue a PhD somewhere else than my own country, where research funding has been ruthlessly cut, and an LLM degree surely helps.
Re: PhDs, I also think it is interesting that American law schools do not generally offer PhD degree programs. True, Yale does, but the program is only open to American JDs, while foreign-educated lawyers can only consider an SJD – which, again, generally requires prior completion of an LLM degree there – as a viable option.
In conclusion, my best guess is that the insularity of American legal education is by no means the main hindrance to attracting foreign students. The overall cost, on the other hand, is. These are times in which making an investment of that kind is a really risky bet – even more so for people hailing form cultures where there is no such thing as student debt and most graduates are sincerely shocked when they hear how much their American counterparts still have to pay for their college level studies. (Funded) PhDs could be another story, but surely there is no question that few students are now willing (or able) to pay those sums, especially now that the immediate benefits are starting to fade even for those who did.
Posted by: N | Feb 4, 2013 7:15:58 AM
At least you guys are starting to admit that the purpose of law school isn't to train American lawyers, but to provide Ivy educated pseudo-scholars with gilded sinecures.
Posted by: SharkSandwich | Feb 4, 2013 3:17:52 PM
There is only one moral thing for you to do, and this is to resign your post. Unfortunately, the entire legal education industry is tainted. It's not necessarily your fault. There are structural defects in legal education (high price, governmentt subsidies, tournament-style rewards, admissions misrepresentations) which have combined in an unfortunate way with a set of cultural norms (get an education, law is flexible),the cumulative effects of which eticed millions of young men and women to destroy their econommic futures to attend law school. I know most of the graduates of NYU law have done all right. I'm sure that helps you sleep at night. But it doesn't change the fact that your living is intimately related to the ongoing tragedy. You are an accomplice to the crime of government-sponsored redistribution of wealth from impoverished twenty-somethings to professors of law. I know you don't see it that way, but it's because you are biased. Your arguments are absurd in part because your stake in the outcome is too high -- though also because there simply are no arguments in favor of the current American legal education model.
I say this all with hope and understanding. I have to. I am a recent graduate of a top law school. I work at a big law firm. I owe the government $200,000. I pay my $3,000 a month on time every month (for the next 15 years if I make it). You see, Rob, you and are two sides of the same twisted coin. We are both a "successful" product of the legal industry. The difference is that I pay for my success one month at a time, with interest. Your success is paid for by people who live in a world burdened with phrases like "default, wage garnishment, income-based repayment, and deferred-adulthood." I hope you will consider my suggestion. There is absolution on the other side.
Posted by: Recent Grad | Feb 4, 2013 6:42:01 PM
More B.S. from MacK on the basics of labor markets. The BLS data is net of retirees so in fact the market absorbs 50K people a year not 22K. In other words, there could easily be a shortage of lawyers by the time the current class graduates. Of course, the recovery could go off track and then aging lawyers will stick around longer but the point is MacK does not know and is ignorant of the basics of labor economics. He should have stuck around graduate school a little longer.
Posted by: btraven | Feb 4, 2013 8:12:00 PM
btraven, I'm sorry but you are incorrect. The BLS projections include replacement needs as well as new openings. See http://www.bls.gov/opub/hom/pdf/homch13.pdf (p. 5 in particular). Remember that those projections also include document reviewers, solo practitioners, and all other "lawyering" jobs. The economy is only supporting about 22,000 new lawyer careers a year, and many of those careers are more contingent and lower paid than in the past.
Posted by: Deborah J Merritt | Feb 4, 2013 10:21:22 PM
From Faculty Lounge:
"This discussion only considers half of the question -- the supply side. We don't really care how many new JDs are created each year, so much as whether the market can absorb them (i.e., whether supply and demand are in equilibrium).
So, I pulled up the BLS CPS series for the legal sector. (For those interested, I used series ids LNU02032459, LNU03034025, LNU04034025, LNU02038291, and LNU02038292.) These series give us the total number of folks employed and unemployed in the legal sector since 2000. That includes most JD-required jobs (lawyers, judges, law clerks), but also includes law-related non-JD jobs (paralegals, legal services); numbers for these latter jobs are only available since 2010.
The bottom line is that the legal sector has been adding an average of about 32,000 jobs per year since 2000. Based upon the data since 2010, about 65% (about 21,000) of these are JD-required jobs. The industry totals are copied at the bottom of this comment.
The average addition of 21,000 jobs per year is net of new JDs and retired JDs. If we (generously) assume the average lawyer's career is 40 years long, 2.5% of the industry retires per year -- or about 22,000 in 2000 and 29,000 in 2011.
This suggests that the market is absorbing about 50,000 new JDs per year today. Based on Dan's data, this means that we're actually producing near the market equilibrium for new JDs per year."
Posted by: btraven | Feb 4, 2013 11:40:03 PM
I am reasonably certain that the BLS' numbers exist independently of the employment status of the researcher.
Posted by: btraven | Feb 5, 2013 12:55:49 AM
dybbuk, I do not think ReallyJunior reached supply=demand conclusion using projections but rather actual historical numbers over the course of the last 13 years of record keeping by the BLS (see the series numbers indicated).
Those hard data series show several things:
1) average net new job growth over that 13 year period in legal occupations of 29K per year (reduced to 21K by subtracting non-JD legal sector employees)
2) because this is net new job growth it takes into account exits (estimated reasonably enough by ReallyJuniorLawProf to be 2.5% per year)
3) when one adds in new legal employees who replace the exits and adds the net new jobs one gets to the approximately 50K per year conclusion reached by ReallyJunior
4) BLS data also show exceptionally low unemployment in the legal sector over those same 13 years, even at the height of the financial collapse from 2008-2010, 3% or less over that entire period. This, of course, is far better than in the wider economy.
It seems likely that when the crash hit some sectors of legal employment were hit harder than others and so finer adjustments for JD-needed v. JD-not-needed or the impact of the retirement rate might show the impact of that. This may explain the anecdotal examples being used by the law school reform advocates.
But there is no evidence in the actual data that there is widespread unemployment across the legal field. This suggests that a conclusion that the legal education system is broken in some fundamental way may be well off the mark.
This same data suggests that, perhaps less of a surprise than you might think, that supply coming out of law schools matched demand in the labor market with the possible exception of the last two years when the bump up in students met the bump down in the retirement rate.
It seems possible that in certain visible sectors that are more easily monitored than other sectors, such as Big Law, there was a period of "oversupply." It might have been the case that because of the crash, the retirement rate slowed at the same point that college graduates went to law school to avoid unemployment at a higher rate. But the data do not show that this has caused significant unemployment.
I am sure there are problems with law schools as there are with many institutions in our society but I am not sure how we solve those problems if we do not agree to the facts. Perhaps there are some mistaken assumptions that have been missed here or by ReallyJunior but I have not been able to find them.
Posted by: btraven | Feb 5, 2013 4:04:38 AM
I did indeed look at reallyjuniorprofs numbers and they were just wrong. Moreover, I would point out that the BLS itself indicated that its employment projection took account of retirements as DJM set forth above. However, you have chosen to take the vague back of the envelope calculations of an anonymous law professor as reliable over the professional labor market economists and statisticians of the BLS and use that to accuse someone of "being ignorant of the basics of labor economics."
Lets me point out that you are allegedly a law professor. What part of teaching people to think like a lawyer encompasses taking cooked up data from an anonymous source as more credible than the work of of professional economists and statisticians? Since I regularly have to present economic analyses and take them apart - professionally - I can tell you that the sort of thinking you have displayed here would likely get a junior lawyer if not fired, not assigned to anything economic again.
BLS data combined with reliable estimates of sustainable debt levels for new lawyers leads to two conclusions. Legal education capacity needs to fall by 50% and cost/productivity needs to double for the law school industry to have a sustainable business model. That is a baseline (you know what those are) which leads to the conclusion that faculty payroll needs to drop ultimately by 75% or to 3000 from 12000 professors. Again that is a baseline. The usual way to analyse these issues is to construct a baseline and then justify departures from it. Foreign students is the departure that the post by Rob Howse suggests will save US legal education from decline a guarantee its brilliant future - frankly I think that is piffle and nonsense. You think - oh that's right - you never explained why you think this is a departure that can justify a significant departure from the baseline.
Instead of actually discussing the issue, you chose to attack me in a way that in fact demonstrated some pretty questionable economic understanding as well as raising to me at least serious questions as to whiter you should be involved in any form of pedagogy. I certainly have doubts as to whether you could teach someone to "think like a lawyer," since you seem incapable of doing so. I could cite your comments as a demonstration of the old cliché "those that can ...."
Posted by: MacK | Feb 5, 2013 6:59:23 AM
The only number that that professor used that was not straight out of BLS was the retirement rate so your "look" was apparently a bit too quick. So far no one here or at the other site has explained how the conclusion reached is wrong. Even Professor Tamanaha was stumped. If the numbers are wrong so be it but I gather you don't know either. Btw, I'm a licensed lawyer just like you and never professed to being a prof.
Posted by: btraven | Feb 5, 2013 7:49:05 AM
dybbuk @2:55 explained why the conclusion is wrong. It's made-up.
Posted by: SantosLHalper | Feb 5, 2013 8:01:51 AM
No dybbuk combined BLS projections with actual historical data from Bls series data so the only one making stuff up was dybbuk. You could even cut the retirement rate in half and still conclude that demand and supply are in rough equilibrium.
Posted by: btraven | Feb 5, 2013 8:25:45 AM
"You could even cut the retirement rate in half and still conclude that demand and supply are in rough equilibrium."
Someone should let the class of 2011 know. They seem to think supply exceeds demand by a factor of two.
I wonder how the NALP classifies school-funded positions and doc review.
Posted by: SantosLHalper | Feb 5, 2013 8:53:25 AM
"You could even cut the retirement rate in half and still conclude that demand and supply are in rough equilibrium."
Someone should let the class of 2011 know. They seem to think supply exceeds demand by a factor of two.
I wonder how the NALP classifies school-funded positions and doc review.
Posted by: SantosLHalper | Feb 5, 2013 8:53:45 AM
Just stop commenting. . . it's getting sad.
Your failure to accept that you are incorrect makes me a sad panda.
Posted by: terry malloy | Feb 5, 2013 8:59:47 AM
btraven, there is a very simple flaw in the analysis of veryjuniorprof - which was incidentally made to achieve a particular objective - showing demand for new law graduates to be at least 50,000 per annum - the correct capacity of US law schools. That flaw is that if veryjuniorprof was correct, there would not have been shortfalls in hiring that predate the recession. But indeed hiring has been poor for over a decade. Employment at 9 months has been according to NALP's very optimistic dataset:
2001 68.3 percent;
2002 67 percent;
2003 65.5 percent;
2004 65.1 percent;
2005 66.7 percent;
2006 68.3 percent;
2007 70.7 percent;
2008 67.2 percent;
2009 62.5 percent.
If veryjuniorprof had been right, those numbers would have been a long string of 90-98% His analysis does not pass the most basic of smell tests.
Your comment "BLS data also show exceptionally low unemployment in the legal sector over those same 13 years, even at the height of the financial collapse from 2008-2010, 3% or less over that entire period. This, of course, is far better than in the wider economy" is also problematic because it fails to take account of the missing lawyer phenomenon.
There were about 1,340,000 JDs awarded between 1974 and 2008 by ABA schools (hat tip to law school transparency.) Since then another roughy 170,000 have been awarded to take us to around 1.5 million - add in the unaccredited law schools for another 50-70,000. The BLS estimates the number of employed lawyers as 570,000. Allowing for deaths of around 33,000 (high) there are somewhere around one million JDs missing from the count of actual lawyers. Now you can try to argue that 2/3s of those who went to law school for 3 years did not plan to have a legal career, but it seems unlikely. A better question is how does the BLS define an unemployed lawyer - and here it is "Employed persons are classified by occupation (what kind of work they do) and industry (what kind of work their employer or business does). Unemployed persons are classified according to their last job."
So if someone never secured a job as a lawyer, or their last job was at Starbucks, or driving a cab ... they are not counted as an unemployed lawyer. To put it simply btraven - you seem rather ignorant about labor economics and how the BLS data actually works - very ignorant in fact. Off you go now and try to teach some law and economics and "how tho think like a lawyer"
Posted by: MacK | Feb 5, 2013 9:48:30 AM
with respect to asking btraven to stop commenting - I hate to suggest the term "think like a lawyer" but...
You know the old cliché (coined by Dennis Healey in the 60s or 70s in fact, and called Healey's law of holes by some), "when in a hole stop digging." The legal practice corollary taught to me by a somewhat grizzled partner (with respect to depositions) was "and when the other guy is in a hole, don't interrupt his digging...."
I actually want to hear more from btraven .. it's fun!
Posted by: MacK | Feb 5, 2013 10:18:40 AM
"very simple flaw in the analysis of veryjuniorprof - which was incidentally made to achieve a particular objective"
In finance we call that "goal-seek" after the excel function by the same name.
Posted by: terry malloy | Feb 5, 2013 11:00:08 AM
@terry malloy - or "confirmation bias" "expectation bias" and "Observer-expectancy effect"
veryjuniorprof's posting was on its face designed to come up with a number, 50,000 new lawyers demanded by the market - that equates almost exactly with the 50,000 JD per year capacity of the current law school establishment - whoopee, there are not to many law schools, to many JDs, it is all in balance.
However, people who understand economic analysis also understand that any economic model or hypothesis needs to be subject to a reality check. Veryjuniorprofs runs into a basic problem - the number of unemployed law graduates over the last decade (and indeed two decades) does not equate to a supply and demand equilibrium - and the missing lawyer problem demonstrates an even larger problem.
Now my argument that the proper academic establishment is 3,000 tenured professors rather than 12,000 is itself subject to a simple reality check "but there are 12,000 tenured law professors ... how can you be right in saying 3 out of 4 should not be there." Had btraven demonstrated the elemental economic knowledge to make that argument - well he would not have seemed to be a fool.
Of course that this the big issue - how can the legal academy have grown to 12,000 tenured law professors despite the shortfall in demand for JDs and the cost issues law schools have. Most commentators ascribe the problem to informational asymmetry and easy lending policies. My argument is that if one looks at the basic market issues, the baseline for law schools is around 3,000 and generally when bubbles burst, demand and capacity falls at least to the baseline, but generally actually below the baseline, before recovering (e.g., property prices tend to fall to below their long run average multiple of household income before a recovery starts, manufacturing capacity (for a given product) gets cut below long run demand (excess inventory tends to drive this.)) If this is a bursting bubble, the baseline matters, because at some point capacity will hit that baseline.
So the question becomes, what is the proper baseline and how can one justify upward or downward departures in calculating it. LLMs are not enough to fix the problem.
Posted by: MacK | Feb 5, 2013 12:08:37 PM
I guess you like BLS data when it helps but switch to NALP when it doesn't. I on the other hand am just trying to understand the problem. Since 2000 we have added 350k legal sector employees. That's 29k per year. Reduce that number by non JDs to get 21k then add in retiree replacement still and you get 40-50k per year. The number fluctuates every year and so mismatches in supply and demand will result. Certainly more likely post 08 due to delayed retires and college grads hiding out in law school. But this data does suggest that the system has worked over a relatively long time frame. I can see that the demand may be dropping now so some supply constraints will mandate some changes but not sure how a relatively stable system is flawed so badly so that it justifies the kinds of changes talked of here. Perhaps it's the old Wag the Dog adage that a manufactured crisis represents an opportunity.
Posted by: btraven | Feb 5, 2013 12:41:47 PM
btraven, I have two direct reports with JDs, and about 20 in a 60 person department. We are not lawyers in any sense. Are these people anomalies? Who will fill the legal demand that they are leaving unmet?
"But this data does suggest that the system has worked over a relatively long time frame."
Has worked for whom? Certainly not majority of the BLS missing lawyers.
"Perhaps it's the old Wag the Dog adage that a manufactured crisis represents an opportunity."
Again, an opportunity for whom?
I want this (scam) to end so that I can hear the silence of the lambs. It's too late for me, but if I can keep the law schools from grinding one 22 year old into a debt slave with no job prospects, I'll sleep easier.
Posted by: terry malloy | Feb 5, 2013 12:58:57 PM
btraven - the problem is cherry-picking the BLS data and misunderstanding how it is arrived at. Take the simple example of your trumpeting the legal unemployment rate but not understanding that it is, as the BLS says, bases on "Unemployed persons are classified according to their last job." This you don't address though it wholly destroys your argument about legal unemployment.
Similarly, the BLS states for 2011 the number of lawyers employed as 570,000 - how do you rationalise this datapoint with 350,000 legal sector employees. Are you saying that 12 years worth of law graduates - some 600,000 or thereabouts are employed when there are only 570,000 lawyers.
Of course if you were not cherrypicking BLS data you would realise that the "350k legal sector employees" includes everyone doing something remotely legal - that includes paralegals and law firm and law department bookkeepers, secretaries, receptionists, investigators, the guy in the copyroom, the IT support, etc., etc.
So you can find the number of lawyer here http://www.bls.gov/oes/current/oes231011.htm
But if you want to know how many people are employed in the legal sector, you get that here:
This group includes, inter alia,
Lawyers ; Judicial Law Clerks ; Administrative Law Judges, Adjudicators, and Hearing Officers ; Arbitrators, Mediators, and Conciliators ; Judges, Magistrate Judges, and Magistrates ; Paralegals and Legal Assistants* ; Court Reporters ; Title Examiners, Abstractors, and Searchers ; Legal Support Workers, All Other
Even assuming that the "Paralegals and Legal Assistants* ; Court Reporters ; Title Examiners, Abstractors, and Searchers ; Legal Support Workers, All Other" all had JDs (of course, head-slap, it never occurred to me), there are still half a million missing JDs.
Now frankly, almost every sensible observer, including me, has doubts about the NALP data - but those doubts are that NALP data has for a long time overstated employment outcomes - because many JDs don't report (or are ignored, I never received a NALP inquiry for example), schools gamed the data in a wide array of ways, etc. Thus we know that the NALP data actually over-reports employment outcomes.
However, I was raising the NALP data as a reality check to the somewhat asinine cherry picking of BLS numbers to reach a different conclusion from what the BLS itself has reached that you seem to endorse. Your response was to complain that I was now relying on NALP rather than BLS. Of course, if you allowed " Intellectual Honesty" to "Trump Partisanship" you would recognise that I did not say the BLS data was inaccurate, but rather that your gaming of the data had led to an absurd conclusion.
Posted by: MacK | Feb 5, 2013 1:09:49 PM
I appreciate veryjuniorprof's examination of the numbers; that's what lawyers should do. And I don't see any sign that he or she was trying to reach a preconceived result. But I think the calculation is flawed for these reasons:
1. In looking at an extensive time period, I would take numbers from the beginning and ending months--not the average annual figures (as veryjuniorprof apparently did). In January 2000, there were 1,470,000 people working in "legal occupations." In January 2013, there were 1,704,000, an increase of 234,000. Dividing by thirteen years, we get an average increase of 18,000 new positions in the legal industry, not the 32,000 that veryjuniorprof suggested. (The 32,000, I think, may itself have been a calculation error. If you take the annual numbers and do the math, you get an average of 29,167.)
2. So now we have to figure out how many of these positions were for lawyers rather than paralegals and other support workers. It's dangerous to extrapolate backwards from the most recent three years, but we can use veryjuniorprof's calculation that, in recent years, lawyers made up about 65% of the legal occupation growth. That gets us to an average of 11,700 new positions a year.
3. Even this is a little high because "legal occupations" also include hearing officers, mediators, and conciliators. Those positions do not require either a JD or bar admission--although some law grads fill them as JD advantage positions. To get a better number, we would have to exclude those categories as well as the paralegals and "other support."
4. The replacement rates assumed by veryjuniorprof are, for reasons pointed out here, too high. We can't assume that everyone who leaves a position is replaced. BLS has more sophisticated formulas for calculating replacement.
BLS itself does this work for us, incorporating still more variables, through its 10 year projections. http://www.bls.gov/emp/ep_table_102.htm. Those show that the economy will support about 228,400 new positions for lawyers, judicial law clerks, or judges/magistrates over the next ten years--or 22,840 per year. That figure includes all retirements.
Posted by: Deborah J Merritt | Feb 5, 2013 1:36:22 PM
Thank you DJM - I note some interesting variations in the BLS data in their website, but it seems to reflect who they count in legal occupations. In any event it is far from the 50,000 junior prof suggested. I have generally accepte the 22,800 number and the 50,000 JD capacity - though non-ABA accredited does add a hard to assess number to the law graduate output - some say as many as 10,000 a year though that seems high.
The 22,800 number is what leads to the conclusion that capacity has to fall by half - 6,000 tenured professors, before you then build in a substantial increase in productivity to cut costs. This is what leads me to the scary baseline of 3,000 tenured professors. Obviously the flaw in my calculation is that there are 12,000 now - can all of that be bubble and froth?
Posted by: MacK | Feb 5, 2013 2:00:08 PM
No one is switching between BLS and NALP when they like one over the other because they both show the same thing. The BLS projection of 21k job openings DOES include retirement. It shows there is a drastic over production of lawyers. The NALP report has less than half of 2011 graduates in full-time, long-term positions nine month after graduation. It shows there is a drastic over production of lawyers.
You’re trying to match the demand with the current supply of 45k JDs a year by pretending the 21k a year doesn’t include job openings from retirement and then pulling another 29k jobs a year out of thin air. You’re trying to claim there is no widespread unemployment across the legal field when the NALP data shows only half of the class of 2011 is working as lawyers and 12.1% of the class is straight up unemployed.
You implied you aren’t a law professor. I have a hard time believing that. Only a law professor could be this detached from reality. Only someone benefiting from the current system could defend something so deeply flawed. If you were a practicing attorney reality would have taken the form of unsolicited resumes, contacts from desperate students of your alma mater, and email after email requesting a “meeting over coffee” and slammed in to you.
Posted by: SantosLHalper | Feb 5, 2013 2:06:33 PM
DJM - your links are breaking because you put a period . at the end of the url
There are some odd discrepancies in BLS numbers so that at:
It shows the 728.2k figure for lawyers in 2010 - but at:
it gives a number of 570,000
Nonetheless, if one were to assume that all Lawyers, Judges, and Related Workers were JD holders, the number in that category on the breakdown you used, viz 820.7 thousand, still leaves somewhere around 700,000-800,000 missing lawyers (i.e., based on around 1.5 million JD's granted to persons under 65.) Where did they go? It means that between 45% and 50% of the JDs who one would expect to still be in legal practice have vanished.
Posted by: MacK | Feb 5, 2013 3:34:49 PM
MacK said: " you would realise that the "350k legal sector employees" includes everyone doing something remotely legal - that includes paralegals and law firm and law department bookkeepers, secretaries, receptionists, investigators, the guy in the copyroom, the IT support, etc., etc."
No that 350 gets you the 29K which was then adjusted by juniorprof to deduct for non-JDs to get the 21K. Then we add back in replacement hires for retirees and we see if that matches JD production overall. And JrP thinks it does more or less.
DJM shades the numbers down by altering the assumptions made by juniorprof which is a reasonable way to argue her case but it does not seem even if we are aggressive with those in her favor that we get to the kind of shortfalls that justify overhauling a system in place and developing over a century. No doubt some important changes will result from the impact of the last few years and that's important.
Posted by: btraven | Feb 5, 2013 4:14:07 PM
Dig, dig, dig
Posted by: MacK | Feb 5, 2013 4:21:00 PM
One of the biggest failures of BLS's statistics is how it calculates its figure for the number of unemployed lawyers. BLS derives its unemployment figures based on the number of people FILING FOR UNEMPLOYMENT BENEFITS. That is the measure they use to determine unemployment rates. The problem with using this as a measure is that not everyone is eligible to apply for unemployment benefits so it doesn't adequately depict the unemployment rate. If one is ineligible but still unemployed, he or she will not be counted in the unemployment statistics.
Does this matter? Yes, especially if a large segment of the population is inelible for unemployment benefits but is unemployed nevertheless. Recent law graduates fall into this category. In order to be eligible for unemployment benefits, one must have been previously employed at a paid job (internships don't count) and lost one's job through no fault of one's own. (Ie: laid off. Fired or leaving voluntarily disqualifies one for benefits.) Most recent graduates were not previously employed at a paid job prior to graduating from law school and therefore did not lose a job. Therefore, recent law graduates are not included as unemployed lawyers in BLS's statistics. In fact, the only way they can be included is if they are lucky enough to actually get a legal job and then lose it through no fault of their own. The problem as everyone knows, is that recent graduates aren't actually getting legal jobs.
This omission is huge when one realizes that legal unemployment is disproportionately affecting younger, newer, and inexperienced attorneys, and yet NONE of them are included in the statistics as an unemployed attorney. Not including them greatly distorts the true unemployment figure for attorneys.
What happens to all those lawyers who never are able to get a job in the legal field and go on to something else because of course, they need to eat? Never once is the individual included as an unemployed attorney in BLS's data, so the BLS data gives us no imput on this whatsoever. Where can we get such info? That's easy. If you really want to know how successful of an experience law school was for law graduates, ask them. You'll get plenty of information! I can give you some ideas because as a recent grad myself, most of my contacts and acquaintances are recent grads like myself.
Of the graduates that I keep in contact with or am familiar with their employment outcomes, about 30% got jobs as attorneys after passing the bar. (I graduated about 3 years ago.) Many of these attorney jobs are extremely low-paying, as many established attorneys in the field are taking advantage of the bad market to mark down new attorneys' salaries extensively. For example, 2 of my cohorts work 40-80 hours a week and earn less than $800 a month. When you figure their hourly wage based on how many hours a week they work, both make less than $3 an hour. Another attorney I know earned $18,000 a year.
What about the remaining 70% of graduates I know who didn't get legal jobs? 50% of the recent graduates I know ended up in retail jobs or jobs that pay less than $10 an hour. For example, one of the individuals on the school's national mock trial team ended up working for Home Depot (he had bills to pay.) Another individual I know works as a security guard. Another was offered a job as a paralegal for $10 an hour after being unable to obtain anything else. Another is a solo but makes his income from delivering pizzas. Two others work at colleges for about $8.50 an hour - one for the front desk and the other for the school's computer lab. Keep in mind that none of these individuals are included in BLS's data on unemployed attorneys, because they are currently working.
The remaining 20% of the recent graduates I know ended up doing extensive unpaid, volunteer legal positions and have been working for free for at least a year. They, too, are also not included as unemployed attorneys under BLS's formula, because they never lost a paid legal job through no fault of their own, because they were never able to obtain a paid legal job. When you do the calculations, that's 70% of my recent graduate acquaintances who could not obtain paid attorney work and not a single one of them has been included in BLS's data as an unemployed attorney. That's a lot to go missing from the statistics and means that BLS's data isn't actually capturing the true number of unemployed lawyers.
Then there's me: I worked unpaid in volunteer positions for a year and a half until I finally gave up and obtained a non-legal position for $13,000 a year, take home pay. Despite never having obtained legal work, being unemployed for almost a year since my graduation, and working in the legal field absolutely for free, with no pay, for a year and a half, I have never been counted as an unemployed lawyer according to BLS's data. That's a lot of people who will never be counted as unemployed attorneys!
If you want to know what's really going on out there, ask the people who know best - the recent graduates. They'll tell you what they are doing and if you really make an effort to ask, I imagine it won't take long to truly grasp the true situation out there. Of course, it's much easier to just stick your head in the sand and imagine than tons of unemployed grads aren't a problem. Of course, we all know how effective that solution is...
Posted by: M.M. | Feb 5, 2013 8:01:35 PM
I am not sure why, but my post did not properly break out into the paragraphs I had when originally writing this. If there was a way to correct it, I would. Hopefully, that will not deter people from reading it.
Posted by: M.M. | Feb 5, 2013 8:02:55 PM
M.M. thank you for that. I had missed the issue that law students who get marginal employment, or indeed lawyers, don't count as unemployed lawyers. Of course if that marginal employment was at something other than as being a "lawyer" they will not count thereafter as unemployed lawyers too.
Thus the unemployment statistics for lawyers (and maybe other occupations) are grossly understated.
Posted by: MacK | Feb 5, 2013 8:24:23 PM
And by the way, M.M., it is anger at the plight of so many like you that makes me post my comments, much as they may piss off so many pollyanna professors here. I do not share your situation, but I avoid saying what I do a lot, shamefully, because dealing with so many decent, smart, well qualified young people and their families, desperate for a job I cannot give them fills me with utter fury and contempt for the system and its supporters who left them in this mess.
Posted by: MacK | Feb 5, 2013 8:28:39 PM
Your mother would be proud MacK.
Posted by: Anon | Feb 5, 2013 9:57:45 PM
Thanks, MacK. And your time posting on this subject is greatly appreciated. Before practicing lawyers weighed in on this subject, every current grads' difficulties were dismissed and written off as coming from whiners who wouldn't work for less than $100,000 a year. This was particularly painful for me to see, because most of my fellow graduates and I just wanted a modest paying legal job (I would have been happy w/ $20,000 a year) that would give us a chance to do what we were trained to do.
By the way, if you have any time, I would love to know some tips on how to get into the International Field and how you got into it yourself. I speak several languages and have lived and interned for the American government abroad. My one major weakness is that I happen to be a new attorney, which seems to be the kiss of death these days. And the fact that I can no longer afford to do an unpaid internships - I have already done three and unfortunately can't afford to work for free anymore. But I have interned for a federal judge, the American government, and the District Attorneys' office. If there is any advice you can give a new grad about how you got into the field, it would be greatly welcomed...
Posted by: M.M. | Feb 5, 2013 10:53:21 PM
I did answer your question M.M. but as seems from time to time to be policy on this forum, my post was deleted.
Posted by: MacK | Feb 6, 2013 11:07:12 AM
I made $20,000 a year as a desk clerk. No law school required!
Posted by: katieEl | May 21, 2013 5:22:23 PM
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