Thursday, July 6, 2017

A Treasury of Idiotic Quotes by Law Professors, Vol. VI: "[S]eriously underprepared law students occupy a role as "other" just as students from vastly different cultures do." (CUNY Law Prof. Deborah Zalesne)

ABA Standard 501(b) states that "A law school shall not admit an applicant who does not appear capable of satisfactorily completing its program of legal education and being admitted to the bar." 

On the basis of LSAT scores alone, it should be glaringly obvious that most law schools are recruiting a significant and increasing contingent of law students whose presence violates Standard 501. However, law school admissions officers can always claim that, regardless of the general statistical correlation between low LSAT scores and bar exam disaster, they saw the requisite appearance of capability in each and every one of the particular weak-credentialed students they did admit. All appeared destined to beat the odds, glittering like juris diamonds in the very, very rough. 

Therefore, it is refreshing when a law professor (along with a law school academic support specialist)  admits that her classroom includes students who are so "seriously underprepared" and so lacking in "academic intelligence" and "cognitive skills" as to be beyond the reach of "traditional law school pedagogy." In other words, students who do not appear capable of satisfactorily completing a doctoral-level program of legal education and then passing the bar. Even if the law professor only make the admission in the context of trying to normalize the presence of unqualified law students via highly creative forms of obfuscation. 

Consider the following synopsis of a forthcoming conference presentation by CUNY Law Prof Deborah Zalesne and CUNY Law Director of Academic Support Programs David Nadvorney, entitled "Learning Outcomes, Cultural Competency, and the Underprepared Law Student as "Other."" (The conference itself is entitled "Teaching Cultural Competency and Other Professional Skills Suggested by ABA Standard 302" and will be held from July 7-8 at the University of Arkansas School of Law (Little Rock)).
"We believe a student’s academic intelligence is about more than simply cognitive skills; it’s akin to culture, including not only cognitive, but also affective and social skills, all of which contribute to a student’s level of success. Our workshop posits that for many faculty, seriously underprepared law students occupy a role as "other" just as students from vastly different cultures do. The workshop will emphasize the responsibility of the teacher to understand and bridge the gap that exists between students’ level of preparation and the goals of the course. In doing so, we will highlight the failure of traditional law school pedagogy to reach the underprepared student, and suggest a framework and materials for teaching the cognitive component of academic intelligence."
It would be problematic for law faculty to explicitly recommend dumbing down law school classes in order to reach "seriously underprepared law students" because, under ABA Standard 501, students in need of such remedial-skills spoonfeeding probably should not have been admitted in the first place. So Zalesne and Nadvorney make that recommendation implicitly via some very delicate wording and by misusing the fashionable concept of cultural competence teaching. That way, they can talk piously about the diligent efforts that law schools must make in order to satisfy ABA Standard 302 (learning outcomes) while conveniently overlooking the fact that poor learning outcomes are the foreseeable result of law school disregard for Standard 501 (standards for admissions).

Zalesne and Nadvorney’s novel little trick is to analogize, even equate, the needs and skills of law students who are "seriously underprepared" due to cognitive deficiency with the needs and skills of law students from "vastly different cultures."

By pretending that under-preparedness is simply another form of diversity, Zalesne and Nadvorney inadvertently recall the timeless statement by a right-wing U.S. senator from the 1960s named Hruska, who demanded opportunities for the marginalized Mediocre-American, including a Supreme Court seat, stating that "there are a lot of mediocre judges and people and lawyers. They are entitled to a little representation, aren't they, and a little chance?"

In case there is any sentient being who doesn't understand this distinction, membership in a cultural community, whether racial, ethnic, religious, or gendered, means belonging to a group with a distinctive history, values, norms, customs, and traditions. It makes sense for a law school to welcome students from "vastly different cultures" and try to provide them with whatever they reasonably need in terms of mentoring, counseling, accommodation, and protection against bigotry. By contrast, serious under-preparedness is a personal failing caused by lack of aptitude, poor training, laziness, or disinterest, and does not deserve outreach, but rather exclusion.  

Identity politics may be on the rise, but I do not anticipate a Seriously Underprepared community coalescing within law schools to protest the cruel pedagogical othering of being expected to read and analyze complicated material in the traditional manner. I do not anticipate inspirational chants of communal affirmation such as "Say it loud, I am seriously underprepared and proud!" or "We’re here, we’re seriously underprepared, get used to it!" Though, come to think of it, these would make fine law school mottos, given the horrifying decline in the quality of incoming law students over the past several years, and could even be adopted as formal ABA interpretations of Standards 302 and 501.


Friday, June 30, 2017

Applicants up 1.5% for 2017, at least according to OTLSS

Well, we are at the 97% mark on another fun-filled year of law school applications, and the year turned out more-or-less as expected.  While there was an initial burst of applicants early in the 2017 cycle, everything seemed to level out again to around 55,000 total applicants.


 
For the sake of comparison, the applicant curve looks the most like 2014 as opposed to other years.  The "math error" described in the previous post on this subject continued to hold true, so while LSAC reports a decline of 0.5% applicants, we show that applicants went up 1.5%, and you can see it if you squint at the differences in the chart above.  
From a rate-of-change-of-applicants perspective, 2017 looked a lot like 2014 as well.  2016 continues to be an anomaly compared to past years, in that the applicant rate ramped up very slowly and then declined slowly late in cycle.  In contrast, 2017 was another quick ramp/quick decline in terms of applicant rate.  We still have yet to return to anything similar to 2012 levels, regardless.
 
All in all, applications have not bounced-back for five years now.  While there are still too many people applying to law school, the message appears to be taking hold and applicants are not coming in droves either, despite declining admission standards and efforts to increase the crop by the Cartel.  This is good news for the scamblog movement, so let's keep the message going!

Wednesday, June 7, 2017

LLM-Light: The Return of the Not-JDs



Hoo-boy.  From TFL:

The University of Maryland Francis King Carey School of Law now offers a Master of Science in Law aimed at non-lawyers.  The website states that the "degree [is] for professionals who want to know more about the intersection of law and regulation with the technical, scientific or administrative demands of their chosen fields."  The subject matter include Environmental Law, Health Care Law, and Patent Law... 

The MSL is a degree in law for professionals who do not wish to practice law, but have a job where a knowledge of the law is useful.  For example, there are quasi-legal positions such as Contracting Officer for the U.S. Government where a background in the cognizant statutes and regulations would be beneficial.  The same could be said for those in the securities industry...this could be a way to counter the decline in law school enrollment, which is currently flat.

A suggestion I have for UMD specifically is to consider offering an MSL in Dispute Resolution.  The Law School has a renowned Center for Dispute Resolution.  The field of alternative dispute resolution (ADR)  often has non-legal professionals practicing in a legal environment...


Here we go again.  The desire to render degrees of the of the not-JD-variety continues to proliferate, for the above-mentioned reasons:  law school enrollment has declined and remains flat currently, and a multitude of whiz-bang LT FT JD-required jobs continues to not appear. 

So why fight it, reasons the Cartel.  Go with the flow.  The market has spoken, so respond in kind with an alternate product.

As I stated in my related post some three years ago, this "go to law school specifically for JD-Advantage reasons" is too little, too late for many who are already burdened with the smokin' bucketfull of awesome that is otherwise known as the Juris Doctor degree.  While the Law School Cartel keeps trying to say "no, really, the scambloggers don't know anything, Law School is still a really great idea," they are clearly hedging their bets by offering these "non-JD" degrees at the same time.  Interestingly, there is not a lot of evidence that these programs were in high-demand previously, when the higher-priced Cadillac JD degree was the only game in town.

Actions speak louder than words.

One advantage, to be fair, is cost: the UM MSL degree is 30 credit hours at around $800 per hour - a mere $24,000.00 investment, possibly something one could do while working in their day job in environmental, health care, or patent matters (whatever that would be).  For those looking for a credential, who are already working in regulated fields, perhaps an employer could be persuaded to pay for an employee's further education.

At the end of all, however, one still has to question the value, even at a reduced price.  There is no practicing law with these degrees, although perhaps that was a pipe-dream anyway for many so who cares.  Would employers rather have a MSL candidate over a JD candidate?  Possibly - the MSL does not appear to come with "Scarlett Letters," as we have often stated the JD does not offer the flexibility/transferability that the Cartel would have one believe.  Are that many employers in regulated industries really looking for an "LLM-Light," however?  That remains to be seen, yet it seems unlikely - many folks learn on the job, and there are whole industry-specific businesses that cater to, train and educate those who work in said fields, not unlike the CLE classes we all know and love.

On a personal note:  I am sick to death of ADR.  I, in my JD-Advantage capacity, have been to enough mediations, arbitrations, and trials to know one thing - give me my trial.  Most disputes where ADR comes into play involve money, plain and simple.  You are not going to get people to agree by splitting the baby (when it's no one's actual baby in the first instance), which is what happens 95% of the time.  ADR is not helping me, it hinders me and wastes my time, and prevents me from asserting the claims and defenses I want to assert in favor of someone else's "judicial efficiency."  So stop it with all the ADR concentration-MSL-LLM mamby-pamby crap, and let's get back down to the business of actually trying cases.  Thank you. 

One thing is for certain - whatever the Cartel tries to say, they are feeling the pinch of lack-of-demand.  JDs are not roaring back, schools are teetering, and another income stream is needed to help offset declining balance sheets.  The rise of the "MSL" indicates the decline of the JD, full stop.

The best bet for all concerned?  Avoid all this, in its entirety, unless someone else is paying for it.       


Friday, June 2, 2017

Requiem for a Hoosier toilet: Indiana Tech Law School RIP

Indiana Tech, which I have styled the glorious Harvard on the Wabash, has made good on last October's promise to shut up shop in June:

http://www.theindianalawyer.com/indiana-techs-closing-of-law-school-leaves-unanswered-questions/PARAMS/article/43828

The Web site is gone; links to it are redirected to the university's home page, presumably for the benefit of those whose erstwhile interest in a JD might become transmogrified into a thirst for a BS in Fashion Marketing & Management or a PhD in Global Leadership. Not one word is said about the plight of the jilted first- and second-year students, who have seen their barristerial fantasies dashed to bits against the porcelain of a toilet given its final flush.

Fortunately, however, Marilyn Odendahl took the initiative for the above-cited article to check such regional juridical behemoths as Toledo, Indiana University (both outlets of the franchise), Notre Dame (Indiana's fourth-tier trap school), Valpo, and of course Cooley. It turns out that all of these illustrious institutions are magnanimously collecting the jetsam of Indiana Tech, although at least one of the Global Leaders, unusually for a transfer student, will have to start the three-year program from scratch. I only wish that Ms. Odendahl had reported the number of centurions transferring to Harvard or Yale, as well as the number receiving free tuition in respect of the godlike excellence that they acquired at Indiana Tech.

How did the university honor its last graduating class? Not in the slightest. They got their degrees like everyone else but no other recognition, not even a mention of their status as the law school's final alumni. Indeed, only 5 of the 21 graduates even attended the ceremony; most or all of the others boycotted it so as not to have to confront the university's retiring president on the daïs. Apparently they had drunk the administrative Kool-Aid and believed that a mean official killed off their thriving gem of a law school. Instead, these worthies held their own ceremony at the Allen County Public Library (which, incidentally, houses one of the finest collections of genealogical information—something worth knowing the next time you pass through beautiful metropolitan Fort Wayne), where they paid homage to dean Charles Cercone and associate dean Charles MacLean. The twin Chucks richly deserved that inspiring accolade.

What will happen to the building erected specially for the law school? The university has not yet decided. It has, however, already sent workers in to measure the classrooms, although an examination of the blueprints should suffice. The fate of the curated art collection and the endowments for scholarships also remains unknown. As for the library's inventory, anyone wanting to bid on it should perhaps call Indiana Tech. This may be a rare opportunity to acquire rare volumes on the subject of Law & Hip-Hop.

And whither the distinguished faculty? What shall become of such superstars as André Douglas "Dougie Fresh" Pond Cummings, whose "reputation goes far beyond ... the nation, and is heard in every corner of the globe, wrestling with legacies of legal thinking on one hand and popular culture on the other"; Adam Lamparello, tell-all autobiographer and all-purpose tramp; and Aretha Green, noted for her refined palate (fried bologna with mayonnaise being her favorite delicacy), her sophisticated hobbies (snooping in houses), and her disdain for books? At the time of publication, I had not been able to verify the abundant rumors of deanships at the Sorbonne and sable-carpeted corner offices in New York's white-shoe law firms.

I'd like to conclude this eulogy with a musical tribute, written to the tune of "Back Home Again in Indiana". Pity that it's too late to hire Hoosier pride and joy Jim Nabors to intone it at a ceremony in honor of those valiant legal centurions with freshly issued JDs.

Back home again in Indiana,
Where it seems that I just saw
The Wabash Cannonball
Go to the wall:
Fort Wayne's toilet school of law.
Discordant strains of hip-hop echo
From the remnants of the wreck.
No more Global Leadership along the Wabash;
Turn the lights out at Indiana Tech.

Friday, May 26, 2017

Arizona Summit must post $1.5M against possible closure

The licensing board in Arizona has just required Arizona Summit (Arizona Scum Pit) to post a $1.5M bond with which to reimburse the students in the event of the toilet school's closure.

http://www.azcentral.com/story/news/local/arizona-education/2017/05/26/arizona-summit-law-school-ordered-create-surety-bond-in-case-closure/338048001/

Only 30% of Arizona Scum Pit's graduates who attempt the bar exam pass it on the first try. At 74%, the rate for the other two law schools in Arizona, both of which are Tier 4 institutions (https://outsidethelawschoolscam.blogspot.ca/2017/05/the-seven-tiers-of-law-schools.html), is still disgraceful.

Arizona Scum Pit and its fellow Tier 6 institutions Charlotte (Harlotte) and Florida Coastal (Horrida Coastal) make up the notorious InfiLaw scam-chain of profit-seeking law schools. All three are in trouble. Harlotte has lost access to federally guaranteed student loans, and Horrida Coastal may join it next year. Arizona Scum pit is on probation by the American Bar Association.

Arizona Scum Pit told the board "that the bond wasn’t necessary and would send a negative message to prospective students". Which negative message? That Arizona Scum Pit is at risk of closing before they complete their Mickey Mouse degrees? If lemmings present and prospective haven't noticed that by now, they won't catch on just because the toilet has to post a bond with the state. Nothing, evidently, would get their attention.

Saturday, May 13, 2017

"Blameless" Tone-Deaf Law Professors Ted Seto and Steve Diamond Whistle Past Grave Yards

What with the recent closures of Indiana Tech and Whittier, to say nothing of mergers and attempts by law schools to raise funds in order to keep operating, what do LawProfs have to say?  By chance, are they implicated in any way?  Let's get right to it:

Not clear that blaming senior faculty is constructive. Like Jack, I work hard. I’m currently on sabbatical, but for the preceding five years, I averaged 20 units of teaching per year, twice what our junior faculty members are asked to teach, while maintaining some of the best teaching evaluations at a school with excellent average evaluations. During that same period, I wrote a first and second edition of a casebook, with accompanying 500-page teacher’s manual, and published numerous articles. I also designed and implemented several new revenue-generating programs for the school, the net revenues of which pay for my salary many times over. When our school went on a faculty-slimming program with buy-out offers, no one offered me a buy-out. I wonder why. (I wouldn’t have accepted in any event; I love what I do.) Sorry to seem self-promoting, but we more experienced faculty members sometimes need to defend ourselves.
Posted by: Theodore Seto | Apr 25, 2017 12:06:16 AM


Well!  Let's count the Baby Boomer bromides: (1) I "work hard" notwithstanding sabbaticals, (2) everybody loves me, (3) I'm important because I'm published, (4) I pay for my cost by helping keep the gristmill going, and (5) I'm better that everyone else and those other (younger) lawprof louses should be fired instead.  Nothing about law school lax acceptance practices, outrageous tuition costs, the dissemination of false and misleading information, that too many law schools are pumping out too many graduates, or the non-recovery of the legal market.  Clearly, no one else works as hard as Seto and he deserves his position, so go looking elsewhere for your pound of flesh from the scam.  

Are things better for the class of 2016 as opposed to earlier?  There appears to be some minor improvement according to recent ABA numbers, but hardly what one would call a huge swing to the so-called "golden days" of legal education.  UPDATE:  For example, the percentage of students from, say, Loyola(LA), who obtained full-time, bar-passage required jobs went down 0.2% from a whopping 47% to 46.8% from 2015 to 2016.

http://witnesseth.typepad.com/blog/2012/12/bloated-is-better-for-law-school-rankings.html



MacK dismissed Seto's arguments in late 2013, and it appears that his predictions were more on point:

Seto's assessment - and for that matter Dan Filler's approving posting of it is remarkable in inherently admitting something that Dan and Seto had until now been desperately denying - that there was a substantial fall in the number of law school matriculations in progress - and that there is an oversupply of JDs.

At the same time, Seto makes a mess of things. The key hole in his analysis is the assumption that until recently supply (JDs awarded per year) was in fact in equilibrium with demand for new law graduates. As has now been relentlessly detailed by numerous careful studies (as well as the missing lawyer phenomenon) that has not been an accurate assessment since perhaps the 1990s. Only a small proportion of the demand-supply mismatch can be attributed to the recession. (The non-equilibrium in the JD supply is a function of the market distortion of a student loan system devoid of underwriting standards.)

Where Seto may be accurate is in his prediction that on current numbers matriculations will be of the order of 39,900 - though it could easily be lower (the impact of law schools' desperate efforts to get applications in the current cycle (waiving application fees, chasing marginally interested applicants) will likely be a lower yield of matriculants from the number of applications, especially if the recovery continues to strengthen through the summer. What does this mean for law schools? Well one good prediction is that in any given metro area with multiple law schools, the bottom ranked law school will be in trouble as students shuffle up to the higher ranked school(s), or the lower ranked school needs to offer very heavy discounts to attract students. It may also lead to competition for transfers in senior class ranks (as schools like Phoenix law are discovering) and further efforts to prevent the losses of 2Ls and 3Ls and tuition dollars. Remember a fall of 8,000 law students means the equivalent of around 20-40 law schools' first year classes (assuming 200-400 per entering class.) The assumption of the pollyanna's is that the fall in matriculations will be evenly distributed across all law schools - but it seems more reasonable to think that those with the perceived worst value offering will take the biggest hit.

The next couple of years are going to be a wild ride for law schools - and September will be very interesting.

Wednesday, May 3, 2017

The seven tiers of law schools

Four years have passed since Law School Truth Center sorted the law schools into seven tiers (http://outsidethelawschoolscam.blogspot.ca/2013/06/law-school-advisory-list-one-guys.html#more). I applaud the effort but disagree on some of the assignments: for example, I would not put Duke in with South Dakota.

For years I have said that only 13 or so law schools are worth attending even in principle (http://outsidethelawschoolscam.blogspot.ca/2014/12/guest-post-by-old-guy-which-law-schools.html). I stand by that claim. But a more detailed breakdown, with descriptions of the categories, may help. Like Law School Truth Center, I have opted to use seven tiers, although I have numbered them from 0 to 6. I have considered only the law schools outside Puerto Rico that are at least provisionally accredited by the ABA, on the assumption that anyone literate enough to read these lines would never consider attending a state-accredited or wholly unaccredited law school. (If you wish, add an eighth tier for those schools that pick up Cooley's rejects.)



TIER 0: Definitely worth attending. Leap at the chance to enroll at one of these schools, even if you have to borrow the full cost.

*** NONE ***

Comments: Formerly occupied by a handful of schools, this tier has been vacant for years and is likely to remain that way until the second half of the century. Not for nothing is it named Tier 0.



TIER 1: Excellent choices for trust-fund babies. Others should seriously consider them while bearing in mind the very real risk of a bad outcome. You cannot, after all, eat prestige for breakfast.

Harvard
Yale

Comments: No, Stanford, your jive ass is not in the same league as Harvard and Yale. Petulant Californian demands for representation in Tier 1 don't sway me one bit.



TIER 2: Rich kids should feel free to attend these. Others should not enroll without a substantial discount and should weigh the risk of a bad outcome carefully.

Chicago
Columbia
NYU
Stanford

Comments: Formerly this category also included Michigan and Penn.



TIER 3: Rich kids are likely to consider these insufficiently prestigious. Others should not even apply without a fee waiver and should not enroll without a large discount, probably at least 50% off; even then, the risk of a bad outcome would loom large.

California—Berkeley
Cornell
Duke
Michigan
Northwestern
Penn
Virginia

Comments: This category, which has shrunk considerably since 2010 or so, is the end of the group that, as of the last time that I checked (http://outsidethelawschoolscam.blogspot.ca/2014/12/guest-post-by-old-guy-which-law-schools.html), saw at least 50% of the graduating class get jobs in Big Law or federal clerkships. I advise against attending any school below Tier 3. Even Tier 1 is questionable nowadays.



TIER 4: Expect a disastrous outcome at these unless you get tuition waived, have local connections, and intend to build your career in the vicinity of the school (no farther away than, say, an adjacent state). As always, rich people can go here if they really want to.

Alabama
Arizona
Arizona State
Baylor
Boston College
Boston University
Brigham Young
California—Davis
California—Irvine
California—Los Angeles
California—Hastings
Cardozo
Case Western Reserve
Chicago—Kent
Cincinnati
Colorado
Connecticut
Denver
Drake
Emory
Florida
Florida State
Fordham
George Mason
Georgetown
George Washington
Georgia
Georgia State
Houston
Illinois
Indiana—Bloomington
Iowa
Kansas
Kentucky
Louisiana State
Loyola Marymount
Minnesota
Nevada
New Mexico
North Carolina
Notre Dame
Ohio State
Oklahoma
Rutgers
St. John's
Southern California
Southern Methodist
Temple
Tennessee
Texas
Texas A&M
Texas Tech
Tulane
Vanderbilt
Wake Forest
Washington
Washington and Lee
Washington University in St. Louis
West Virginia
William and Mary
Wisconsin

Comments: Many of these are what Paul Campos has called trap schools. Others are toilets with employment figures that are better than those of typical toilets. All are best avoided, from the faux-prestigious outskirts of Tier 3 to the toilety outskirts of Tier 5.



TIER 5: Don't go near these unless you are independently wealthy, crave a little wind-up-toy law degree, and are too dumb to get into a school in a higher tier even after exploiting your rich connections.

Akron
Albany
American
Arkansas—Fayetteville
Arkansas—Little Rock
Baltimore
Belmont
Brooklyn
Campbell
Catholic
Chapman
Cleveland-Marshall
Creighton
CUNY
DePaul
Drexel
Duquesne
Florida International
Gonzaga
Hawaii
Hofstra
Howard
Idaho
Indiana—Indianapolis
Lewis and Clark
Liberty
Lincoln Memorial
Louisville
Loyola—Chicago
Maine
Marquette
Maryland
Memphis
Mercer
Miami
Michigan State
Mississippi
Missouri—Columbia
Missouri—Kansas City
Montana
Nebraska
New Hampshire
New York Law School
Northeastern
Oregon
Pace
Pacific
Pennsylvania State—Dickinson
Pennsylvania State—University Park
Pepperdine
Pittsburgh
Quinnipiac
Regent
Richmond
St. Louis
St. Thomas—Minneapolis
Samford
San Diego
San Francisco
Santa Clara
Seattle
Seton Hall
South Carolina
South Texas
Southwestern
Stetson
Suffolk
SUNY Buffalo
Syracuse
Toledo
Tulsa
Vermont
Villanova
Washburn
Wayne State
Willamette
Wyoming

Comments: Many of these are only a hair's breadth from the bottom tier. Some are likely to close in the coming years. These schools typically feature a mediocre to lousy student body and dreadfully high unemployment and underemployment in the graduating classes of recent years. Unaccountably, a bit of prestige still attaches to a few of these schools. Don't believe the hype.



TIER 6: The survival of these into 2017 offers an argument against the existence of a just god. Anyone who enrolls at one of these should not be allowed to roam the streets unsupervised.

Appalachian
Arizona Summit
Ave Maria
Barry
California Western
Capital
Charleston
Charlotte
Concordia
Dayton
Detroit—Mercy
District of Columbia
Elon
Faulkner
Florida A&M
Florida Coastal
Golden Gate
Indiana Tech (soon to be closed)
John Marshall—Atlanta
John Marshall—Chicago
La Verne
Loyola—New Orleans
Massachusetts—Dartmouth
Mississippi College
Mitchell | Hamline
New England
North Carolina Central
North Dakota
Northern Illinois
Northern Kentucky
Nova Southeastern
Ohio Northern
Oklahoma City
Roger Williams
St. Mary's
St. Thomas—Florida
Savannah
South Dakota
Southern Illinois
Southern University
Texas Southern
Thomas Cooley
Thomas Jefferson
Touro
Valparaiso
Western New England
Western State
Whittier (soon to be closed)
Widener

Comments: These schools are mostly private. Several are unprofitable commercial ventures. All plumb the depths of the 140s, and even the 130s and perhaps the 120s, on the LSAT. The few people who pass the bar exams are unlikely to find real salaried work as lawyers. Fortunately, this tier is shrinking. Recent years have seen a couple of announced closures, some attempted and achieved mergers (effectively closures), an abandonment to the state, and a closure of a branch. Expansion will almost certainly come from above (Tier 5), not below (the unspeakable world of unaccredited upstarts).