“If law schools could build their programs from scratch, without the ABA-imposed condition that training must consist of three years' worth of material, what would and should they look like?”
That’s the concluding sentence from this post. While it may have seemed rhetorical in context, it really wasn’t intended to be. I planned to write out a whole series of follow-up posts with an entire outline for a brand new law school program. A business plan, with a price tag and everything.
But the blogosphere and other things have that habit of pushing forward anyway, and in the meantime I came across two other stories and posts that let me frame this follow-up more precisely.
First is Paul Horwitz’s characteristically thoughtful Prawfsblawg post noting a post by Chai Feldblum at Concurring Opinions, part of a symposium on a new book by Robin West. Both of the posts concern the challenges of curricular reform at law schools. Chai Feldblum urges reformers to engage students in the tasks of understanding and advancing visions of justice beyond lawyers’ work for clients. Paul wrote: “[Feldblum’s post, along with one other, is] potentially indicative of a serious gap between the ways different law professors discuss things like law school reform, curricular or otherwise, and also of a gap between the ways that some legal academics discuss law school reform compared to the ways that students, lawyers, and recent graduates struggling to find actual jobs discuss it.”
I’ll offer my own take on what occupies that gap. I want to avoid any suggestion that I am interpreting Chai Feldblum or responding specifically to her post or to her work. The following is not in opposition to anything she has written. Rather, the exchange above prompts me to set out my own view of what usually drives students, lawyers, and recent graduates in their views of law school and legal education, and what is too often missing from faculty views. That is: Clients.
Changes in the client-side, demand-driven aspects of law practice and the legal profession are responsible for much of the turmoil in lawyers’ lives of the last five years. Anecdotally, talking to some of my colleagues at Pitt and at other schools, and reading law faculty blogs, this seems to surprise a lot of faculty, both in the sense that they didn't see this coming and in the sense that they don't really understand how it all works. (Bill Henderson's work is helping enormously on the faculty side.) That relative innocence has long spilled over into the classroom. Students and new graduates are rarely taught much if anything about just how much of the lawyer’s role revolves not around the lawyer’s identity, and not about the content of the law or the behavior of legal institutions, and not about their “skills,” but instead around the needs, wants, economic capabilities, and conflicting and often poorly-articulated goals of clients. Individual clients, yes (and therefore some law students get some exposure to all of this in law clinics), but also groups of clients and most importantly institutional clients – small and large. Clients are sometimes interested in abstract notions of justice, but clients are almost always more interested in justice *for themselves.* The hand that drives the common law, and most other law, isn’t so invisible – unless you’re a law student, absorbed in and directed to figuring out how to understand the role of precedent, and holdings, and how to reason through a new set of facts, and other such technical detail, important as it all is. “The client” too often becomes just a proxy for “interests” and “the facts” used to explore the sources and meanings of the law. Out there in the world of practicing lawyers, however, clients, in all of their complexity, come first.
No lawyer should be taught to abandon all concern other than fidelity to client. Law and lawyering are about justice. Lawyers no less than courts and legislatures and agencies are charged, in principle and in practice, with mediating between different visions of the good, and law students should be given the intellectual and practical skills that allow them to do just that. But the lawyer’s mediating role in that process typically does not occur in some distinct “law reform” space (except, perhaps, for some graduates of elite law schools) that is somehow distinct from client work. Justice is mediated precisely in the context of actual work for actual clients. That – the multiple accountabilities of lawyers, to client, court, and society -- is precisely why the relationship of law to justice is so challenging. That complexity is what I think law students need to see much more of, and should experience more of, and from a very early stage in their law school careers. Law and law school isn’t about them. It’s about other people and all of the weirdness and wonder that other people entail. As a partner I worked for many years put it, quietly and simply, “it’s a service business.” If you can’t handle that, then you should find some other line of work.
Bringing that home in terms of curricular design (if not necessarily “reform”) means, I think, bringing the client much more explicitly into the law school classroom – all law school classrooms, and not just clinics (where my point is often very well-understood), and not just classes in Professional Responsibility – than is the convention today. Bringing clients in means bringing lawyers' accountability to others to the forefront in law teaching, and in practice that might mean any number of things: everything from close reading of cases from the perspective the parties present and future, rather than that of the lawyers or the decisionmakers, to inviting clients (real clients or people playing clients in role) into class discussions, to grander re-alignment of course materials, team vs. solo teaching, group work by students, substantial changes in assessment methods, and putting students to the task of actually expressing judgment on behalf of clients, rather than the “one the one hand,” “on the other hand” sensibility that suits their comfort zones. Personally, when I run hypotheticals in my own classes, I like to put some students in the position of clients (note the plural – I’ll often have several clients in the hypo at one time), because I have learned from personal experience that few things taught me more about being a lawyer and about the legal system than being a client myself. Believe me, as a client, I neither wanted “justice” nor, as I observed the system grinding me down, did I always get it. And no amount of complaining to my lawyer, or close reasoning and careful advocacy by my lawyer, could change either of those things. Yet the lawyer quite reasonably and legitimately expected that I would pay him.
Second, the burden of doing all of this falls not on “law schools” or “legal educators” but actual living, breathing law professors. In a recent piece in the New York Law Journal, Luke Bierman eloquently and thoroughly made the case for experiential education in training law students. Luke is speaking from experience; his law school, Northeastern, is both a pioneer and a leader in this stuff. But in exhorting others to follow Northeastern’s lead, Luke fell back on calls to “law schools” and “legal educators.” Alas, this is unlikely to be effective. Here and there, a law faculty may, as a group, take a leap forward in this direction. Washington & Lee, for example. But most law faculties are blends of teaching traditionalists, fence-sitters, and a few innovators. Some in each group are older and more established; some in each group may be younger and/or newer to teaching. How are these people to be made to think and act different? (Awkward syntax courtesy of Apple.) Few deans have the formal or practical authority to order the school’s teachers to march to a different drummer in the classroom. “Incentives” to innovate, whether framed as carrots or as sticks, have their limits. Tenure cuts against innovation at both ends of the seniority spectrum. New law teachers want tenure, thus fear innovating. Tenured law teachers often justify teaching complacency as the price that students pay for freeing faculty to experiment with their scholarship. Tenure means, among other things, a stable teaching package, and no new course preparations. And tenure aside, law professors are above all else creatures of the legal system that they create and perpetuate: like all lawyers, they often honor tradition and history more for the sake of honoring tradition and history than because honoring history and tradition leads to the most sensible outcomes today. Subconsciously, we all have a little Kingsfield in each of us, or (if that reference and image is dated) at least a little Professor Stromwell (Holland Taylor in Legally Blonde).
We have met the enemy and he is us. Breaking the mold requires something else – some other kind of motivation and some other kind of execution among individual teachers, who are not indifferent to tenure or tradition but are not ruled by them, even if their own law schools are not innovating substantially at the institutional level. Despite the many structural barriers to innovation and improvement in teaching, at almost every American law school there are pockets of innovation – disruptive teachers – who are doing different things with their students and for a variety of reasons. Many of those things fall under the umbrella heading, “experiential education,” but the label may mislead. What these things have in common is that they are different, in some large and in some small ways, and the differences are in almost all cases, in my anecdotal experience, aimed at better alignment of law teaching and the experiences of lawyers in the contemporary legal profession. No one imagines giving up the core strengths and traditions of American legal education - the emphasis on rigorous analytic thinking, the injunction to think critically independently and to communicate effectively. Langdellian education and its derivatives are not, however, the only ways to get there.
My advice, then, is this: If you’re a Dean: Find these teachers, support them, and publicly and privately celebrate them and build around them. If you’re a teacher and you’re curious about this stuff, talk to these people and learn from them. If you’re a law student, enroll in their classes! If you’re an alum, press the Dean of your school to bring these people forward and engage with you and your colleagues in the legal profession. Build externship and internship pipelines that lead from their teaching to work with you and ultimately to full-time employment with you or elsewhere. Help the Dean amass the resources needed to support and celebrate these teachers and their students - tangibly, out of your own pocket, and intangibly, with political support and advocacy among your peers and colleagues. Or all of the above.
None of those things is as easy as I may have made it appear. Deans do not want to play favorites, or to appear to play favorites. Law teachers, especially veterans, often believe that they have no need to learn from peers, let alone from more junior colleagues. Students avoid things (teachers, subjects, styles) that don't look and act like things that they have already encountered and mastered. And alumni think that law schools should simply be doing this as part of the ordinary course of things. Land mines and risks, known and unknown, abound.
Luke Bierman quoted Hastings Dean Frank Wu, who has compared legal education to 1970s Detroit. I’ve written of a different and to my mind, more apt comparison: Legal education is the 20th century steel industry – massively successful up until the very end, and then, in a moment, it wasn’t. Not successful, and not much of an industry. American steel producers (including producers in Pittsburgh) have rebounded, and they still make lots of great steel – but the big integrated producers don’t make the huge quantities of the structural steel that made them rich and powerful, and in all that they produce today, they employ only a tiny fraction of the US workforce that they once did. In Pittsburgh, where I live and which has become something of a poster-child for the chic revival of post-industrial America, the scars of the dislocation, disruption, and loss wrought by the crash of steel are still visible, and full of meaning and economic impact, 30 years on.
The collapse of American steel may or may not have been avoidable, at least at the very end. But everyone at the top of the pyramid, on both management and labor sides, saw the end coming: the over-capacity, the flawed economic model, the changing demand. They saw it decades ahead of time. Everyone diagnosed the problems as the responsibility of other players. In macro and micro ways there were plenty of opportunities for management and labor collectively to take a balanced view of their futures and to avoid walking over the precipice together. Yet walk over the precipice together is what, in the end, happened. The parallel to legal education is imprecise. At the very least, this is not law schools’ 1981, the year that Steel's struggles really started to hit home in earnest.
Is it?
If the core problem is overcapacity, how will innovative teaching correct it?
Posted by: Kevin Outterson | October 26, 2012 at 12:55 AM
Within the scope of what I've posted above, you're right - it won't. The point about Steel is that the system of legal education needs to adopt modes of flexible thinking about just about all aspects of its program that we rarely see at the level of individual participants. Beyond that, there are other moving pieces that I haven't posted about. One is that current overcapacity exists relative to changing demand. Demand may be going down for traditional lawyers but going up for participants in the legal services industry, for example. (With Steel, the most dramatic changes took place in the economic model of the integrated producers, which exposed the fact not that they had excess capacity so much as it exposed the fact that their steel was too expensive; demand didn't change all that much.) I can't say that changing legal education will assure that all grads get full-time jobs (no one can say that, credibly), but changes can, in my view, improve the odds that all will grads will get full-time jobs. But not necessarily as lawyers. Two is that faculty should teach more than they do now, all things considered. More classes, and more students. I may add more in further comments.
Posted by: Mike Madison | October 26, 2012 at 07:35 AM
I believe that what you are saying is correct. On my midterm in Administrative Law, I asked the students a question with both a legal component and a pragmatic component. Essentially the question required students to consider whether to advise a client to pursue a strategy of delay in order to help the client achieve its goals, even though this strategy would be unlikely to succeed on the legal merits. Students almost universally ignored the prompt to give pragmatic advice. Perhaps it was a badly worded question (although a few did what I had wanted), but in reviewing the exam, students seemed almost exasperated that I'd asked them a question that required them to give "non-legal" advice.
Curious to hear any thoughts on how to get students into a client-centered mindset while they are in the classroom.
Posted by: Matthew Bruckner | October 26, 2012 at 01:23 PM
Reading the first half or so of your post reminded me of this:
1 California Law Review Circuit 33.
Posted by: anon | October 28, 2012 at 12:45 AM
The link is here
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1615955
Posted by: anon | October 28, 2012 at 12:49 AM
The real question is what law schools are assigned to play the role of the Bethlehem Steels?
Posted by: Bill Turnier | October 28, 2012 at 11:11 AM
Another insightful and eloquent essay on what is urgently needed in legal education. Thank you!
Posted by: Craig Boise | October 28, 2012 at 10:27 PM
I'm a recently graduated law student. In my experience, you have not even begun to grasp the differences "the ways that some legal academics discuss law school reform compared to the ways that students, lawyers, and recent graduates struggling to find actual jobs discuss it."
I read your post, then did a page search for the terms "debt," "loans," "cost," "size," "tuition." I wasn't shocked when I did not find a single instance of these words in your 2,000 word opus.
If there is a simple statement that can sum up the student and recent graduate position on law school reform it is this: "there are too many law students taking on too much debt to get law degrees." Every critique flows from this statement. Every proposed reform must be discussed with this as a central theme.
Curricular reform is a part of this discussion to the extent that a law school that must function with half as many students and on tuition of around $15,000 per year (or as a two-year program, or a 1 year program with a masters and 2 more years for the JD) will have to change its curriculum to deal with lower revenues. It is also important in order to consider how ABA accreditation standards will have to change to accommodate the new order. Otherwise, a discussion of curricular reform without even a mention of tuition reduction or cutting class size misses the point entirely.
If you want to figure out how to close the gap between academia and students/graduates on law school reform, you must start asking different questions. If you refuse to address the cost of law school or the oversupply of students, than you are not really engaging with the opposing position or do not understand what the opposing position is.
Posted by: BoredJD | October 29, 2012 at 03:01 PM
Let us be clear: in a rational system designed from the ground up today, there would be no law schools. None! What is the point of them? People get by basically without them in several advanced societies. The only reason we think they should exist is because they currently do.
If the goal of a legal education system is to produce prepared practicing attorneys, then the law school system should give way to an apprentice system. College or high school students interested in the law would take a half-dozen or so courses related to the law and then begin to practice in a firm as an apprentice or a government internship program upon graduation. Legal scholars would hold Ph.D.'s and do their work from various university departments. Teachers of the undergrad legal courses would be practitioners or retired practitioners.
What does law school add, besides unbelievable expense, to the legal practice enterprise? As someone who graduated from law school in the past few years and currently practices, I fail to see any (any!) value-add from my supposedly top-rate legal education, which lasted an unbelievable three(!)years and cost an unbelievable six-figure sum. If I had the choice I would not have paid even 10,000 and one year of my life for this education. It's not that I didn't learn anything. It's that I didn't learn anything *useful* - most of that "education" was really just intellectual entertainment, at enormous expense.
The answer to why law schools are necessary cannot be "well, you learn X and Y in law school that you wouldn't learn as an apprentice". The answer would have to be at least something like, "well, you learn X and Y in law school that you wouldn't learn as an apprentice, which is worth the tradeoff of whatever time and expense because [fill in blank]". Law schools exist only because of institutional inertia. It's time to push back.
Posted by: Big Cow | October 29, 2012 at 03:09 PM
Anyone looking, like BoredJD, for parts of my thinking about legal education that did not make it into this post may find supplemental comments on my principal blog, madisonian.net. Words like "cost" and "tuition" do show up; I plead not guilty to the charge of not getting how all of the relevant moving pieces fit together. This particular post is long enough, however.
A non-exhaustive catalog of relevant posts includes:
Innovation, Lawyers, and Legal Education
http://madisonian.net/2011/12/18/innovation-lawyers-and-legal-education/
Public Legal Education
http://madisonian.net/2011/05/25/public-legal-education/
Too Many Law Schools? (from pre-crash 2008, no less!)
http://madisonian.net/2008/04/08/too-many-law-schools/
Posted by: Mike Madison | October 29, 2012 at 04:55 PM
I'm a 2011 graduate of your school, and I had two questions for you.
Has a decision been made to withhold salary information as reported to NALP at the dean's level? Either way, has it been discussed among faculty or administrators that the University of Pittsburgh School of Law might publish this information in the minimally informative Employment Data section of its website?
Without any discounts, a Pennsylvania-domiciled graduate of the class of 2016 will face an estimated cost of $168,483. It's unfair to pretend that the University of Pittsburgh is alone in refusing to acknowledge the hilarious mismatch between the cost of legal education and its pecuniary benefit, but I promise that innovation will come much sooner if law schools become honest about how little the JD is worth to any law graduates who can't find a place in the law (and many of those who actually do).
Posted by: John Thompson | October 29, 2012 at 06:21 PM
In 2011, you asked what the vision of a tuition-driven public law school should be.
A public law school should provide a cheap legal education for students from their state, as it historically has done. There was nothing wrong with that vision. The problem is that public law schools abandoned that vision in favor of something else. Depending on who you ask, they chased the US News rankings dragon, used the federal student loan system to enrich the deans and tenured professors, or bowed to student pressure for fluffier classes, shinier buildings, and less challenging work.
What very few legal academics are willing to address is the feasibility of a return to that original premise- that a public law school guarantees a very cheap education for its students. Perhaps students should favor client centric pedagogical model. But as law professors, you need to be looking out for your students and for the profession as a whole. And what your students desperately need is cheap law schools and less competition for jobs, and what the profession desperately needs is for law schools to stop graduating twice as many entry-level lawyers as there are jobs.
What might be beneficial to students/graduates is a frank assessment of the reality of the situation. What is responsible for such a dramatic shift away from the traditional mission of a public law school? Can we go back to the ancient days of 2001, when tuition/fees at Pitt Law was less than half of what it is today? Have circumstances changed so much that a return to this historical norm is impossible, or is it merely undesirable for tenured faculty members?
Posted by: BoredJD | October 29, 2012 at 06:57 PM
We produce close to twice as many lawyers each year as there are legal jobs. And we saddle them with, at last count, around $125,000 in debt. Any discussion about reform that doesn't take these two facts into consideration isn't all that helpful.
Schools need to be closed, tuition needs to come down. Everything else is just window dressing.
Posted by: Dean | October 29, 2012 at 08:04 PM
Mike: "Anyone looking, like BoredJD, for parts of my thinking about legal education that did not make it into this post may find supplemental comments on my principal blog, madisonian.net. Words like "cost" and "tuition" do show up; I plead not guilty to the charge of not getting how all of the relevant moving pieces fit together. This particular post is long enough, however."
Mike, cost is not 'supplemental', cost is core. If students are paying $150-250K for a law degree, and law schools are producing twice as many lawyers as needed, then a large number of students will both not have jobs in their profession, and be facing ruinous debt.
Posted by: Barry | October 29, 2012 at 08:24 PM
This comment likely will not preempt others that complain that I did not post about issues of crucial interest to them. But my aim is to head a few of those off at the pass. And I will say it even though the original point of the post was not a general discussion of the specifics of law school reform.
Law school costs too much. It costs a shocking amount. It costs a shocking amount even after discounts are taken into account. It costs too much more or less regardless of one's views of whether society has the "right" amount of legal jobs (irony quotation marks there, because there are different views of what that number is). It costs too much relative to most assessments of the value that law school currently provides. It costs too much at local and regional levels, it costs too much at both private and public law schools, and it costs too much even (or perhaps especially) given the claim that tuition doesn't reflect the "real" cost of educating a given student.
There are, of course, many other moving pieces in the economies (plural) of the legal profession. The number of legal jobs might grow (that's extremely unlikely, if "legal jobs" means "full-time jobs practicing law in a traditional sense"). The value of a legal education might increase (that also strikes me as unlikely, but recognize that the character of a legal education is not fixed, in principle, just as the economic structure of the employment market is not fixed). Law schools did not cause these cost problems all by themselves, and they likely cannot solve them all by themselves. It is certainly true that no amount of pedagogical tinkering will solve the cost problem all by itself.
Right now, however, pedagogical tinkering is almost all that many law schools have going for them -- and the process of pedagogical tinkering is, in many respects, almost hopelessly constipated by law schools' and individual faculty members' historical commitments. The point of the original post -- muddied, perhaps, by the assumption that the Steel analogy could be read back, metaphorically, across the part about pedagogy -- was this: If law faculties can't handle needed pedagogical tinkering, then how will they manage bigger problems, like costs of attendance, and declining enrollments, and correcting the law school model to account for the fact that it is still grounded in 19th century and early 20th century thinking? Much of the time, I am pretty pessimistic about the odds that law schools and law faculties collectively will figure out a way forward. Thus the Steel analogy. Yet I am simultaneously if cautiously optimistic that some individual faculty members (including deans) can begin to make enough progress on their own that in broader ways the currently sclerotic system can be made more relevant, flexible, fluid, and affordable. Thus the exhortations.
Posted by: Mike Madison | October 29, 2012 at 08:35 PM
@Barry: I am pretty sure that you have mis-understood my comment. The phrase "supplemental comments" means "additional comments," or "comments in addition to my original comments, or to my original post." The phrase does not refer to costs, whether those costs might be supplemental or core or anything else.
Oh - and I found yet another earlier blog post of mine that talks about cost and legal education:
What Ails Lawyers and Law Schools, Pittsburgh Edition
http://pittsblog.blogspot.com/2011/01/what-ails-lawyers-and-law-schools.html
and read the comments there ....
Posted by: Mike Madison | October 29, 2012 at 08:47 PM
While I appreciate all of that, a client-focused legal education might best begin by schools meeting the same ethical standards of disclosure to which a client seeking counsel is entitled. If the University of Pittsburgh School of Law or any other knows something about the class of 2011's outcomes that a member of the class of 2015 might find material to his decision to continue his studies, it should be disclosed to all. I would think that might include salary information at the 25th, 50th and 75th percentiles, as well as the ratio of students reporting to those not reporting, but needless to say that information isn't published despite the school knowing it.
This post began with the question of what an ideal law school freed of the 3-year ABA requirement should look like. Whatever other elements one might incorporate, nobody would openly press for "fostering prospective and current students' ignorance of previous graduates' experience with employment outcomes." At least I hope nobody would.
Posted by: John Thompson | October 29, 2012 at 11:20 PM
Thanks for replying, Mike. The reason that I mentioned cost is that there's no getting around it. That's core.
Posted by: Barry | October 30, 2012 at 08:43 AM
I'd also like to thank you for taking the time to reply to us- very few law professors will acknowledge the perspectives of students or recent graduates on this issue. While I don't completely agree with the U.S. Steel analogy (I think a better analogy would be if U.S. steel decided to stop producing cheap structural grade steel and only focused on producing a lot of high-cost steel for space shuttles) I also don't believe you are using the pedagogy issue as a smokescreen to ignore the heady issues of cost and over enrollment.
That being said, I am a student who has encouraged others to take courses that are more "client-focused" although there were very few of those at my law school. I've given rave reviews to adjunct professors who use briefs or other research/writing assignments as the mode of evaluation instead of in-class open book issue spotters. I was also involved with a clinic at my school for three semesters and did several unpaid internships during the school year with non-profits and government organizations. So I'm a big fan of the experiential learning experience and wish it was "formalized" at more law schools.
However, after seeing a lot of my friends taking Law + Literature, Law + Religion classes, etc etc, and then going off to very prestigious positions in corporate or tax departments of large law firms, I'm also realistic to the possibility that top shelf legal employers are not particularly concerned with the content of the curriculum.
Posted by: BoredJD | October 30, 2012 at 03:34 PM
The Steel analogy has its limits, obviously. (I capitalize the word "Steel" because it's a metonym, and because that's how people here refer to it: "Steel.") Spending too much time talking about where the analogy works and where it doesn't work risks missing the important issues. But because I live in Pittsburgh and have learned an enormous amount about what happened in the steel industry in the 1970s and early 1980s, I hope that you'll indulge a further reply on that point. The history is revealing.
Back in the 1960s and 1970s, structural steel wasn't cheap, at least not the way that the big integrated producers were making it. To the contrary: the stuff was quite expensive. It had to be, because the cost structure of the steel industry was so big. The integrated producers had agreed to labor contracts that paid steelworkers extremely well. The huge rolling mills and coke plants required thousands and thousands of hands and backs to keep them operating. (Few people begrudge steelworkers the amount of money that they made; this was backbreaking work.) Management, of course, took a big cut of its own. Because there was, in effect, no industrial model that could produce structural steel the way that the integrated producers did, the producers could charge extremely profitable prices. Everyone made money. Then along came what Clay Christensen now calls "disruptive" innovation, in the form of mini-mills, which could produce competitive structural steel products for much, much less. That squeezed margins. The integrated producers responded by shifting production to ever more upmarket, high margin products. The cycle kept repeating, with the integrated producers continuing to move upmarket in order to protect their margins. Eventually, there was no place else to move. The markets for the high-end stuff got competitive, too. And that's when the whole thing fell apart.
To me, the question isn't whether the analogy works. The question is timing. Law schools are probably not looking at 1981 - the edge of the abyss. Are they looking at a metaphorical 1975? 1971? Earlier?
Other people who have tried to apply Christensen's analysis to legal education have wondered about the identity of the so-called "disruptive" innovators. (I have heard fellow law faculty say, in effect, that law schools don't need to worry about competition, because everyone who wants to go to law school has to go to law school. Yikes.) I don't think that it's so difficult to see what's happening: The marektplace disruption is happening downstream, in the world of law practice itself. Law schools have yet to fully appreciate its effects. But eventually, I think, they will.
Posted by: Mike Madison | October 30, 2012 at 03:59 PM