The 2018-19 Bottom Ten Law Schools

The 2018 ABA 509 Required Disclosures are hot off the press and I couldn’t wait to delve into the numbers and see who has been naughty and who has been nice.

The title for the least selective law school in the country goes to:

1. 2017 Defending Champion - Western Michigan University Thomas Cooley! Once again, Cooley tops the bottom 10 list, but this year there is a twist. Last fall, the ABA found that Cooley was out of compliance with ABA Standard 501 on Admissions. Cooley sued the ABA, and in March 2018, the ABA essentially capitulated and found Cooley back in compliance with Standard 501(b), based on “concrete steps” that the school was making to improve its admissions policies. I analyzed those steps in this post, and predicted that they would barely make a difference in the credentials of the admitted students. Well, guess what?  Turns out I was right.

Let’s compare the credentials of the 2017 entering class with the credentials of the 2018 entering class:

 

	LSAT 75%	LSAT 50%	LSAT 25%	GPA 75%	GPA 50%	GPA 25%	% admits
2017	146	142	139	3.27	2.94	2.59	85.56%
2018	147	142	139	3.33	3.02	2.64	86.13%

 

So, did Western Michigan Cooley improve its admissions standards and get more selective, as it promised to the ABA?   Not so much. Although it is true that their 75% LSAT went up by one point, and GPAs overall are up by a miniscule .06, the all-important 50% and 25% LSAT are identical.  More tellingly, the percentage of students admitted actually increased from 2017 to 2018.   And the entering class size increased from 458 to 541.   What this means is that Cooley enrolled at least 135 students with LSATs at 139 or below, the bottom 12% of all LSAT takers.   Cooley actually had a chance to significantly raise standards because the number of applicants increased from 1295 to 1456 (call it the Michael Cohen bump), but of course Cooley chose to do what it always chooses to do – maximize profit.   Bottom line:  the ABA got suckered big time.  If the ABA wants to have any hope of preserving its credibility, it will immediately rescind its decision to find Cooley back in compliance and place the school on probation.  How can the least selective law school in the country, with the lowest 25% LSAT by 3 points compared to the next least selective school, be in compliance with Standard 501?

2.  Southern University (last year’s rank: tied for 3) 146/144/142  3.13/2.83/2.55.  The good news: Southern raised its LSAT 25% by one point.  The bad news:  Southern dropped its 25% GPA by .03.   Southern has miraculously escaped sanction by the ABA despite many years of abysmal admissions standards and poor and declining performance on the bar.   But hey, if Cooley is in compliance, then I guess everybody is in compliance, right?

3. (tie) Appalachian School of Law (last year – tied for 3).147/144/143  3.32/3.05/2.64 Holding steady at 3 is Appalachian. Currently out of compliance with Standard 501, Appalachian raised its 25% and 50% LSAT by 2 and 1 points respectively, but its 75% dropped 2 points, and the school only enrolled 50 1Ls, compared to 73 last year.  Appalachian is in trouble.   

3. (tie) Texas Southern (last year – tied for 2) 2018: 147/144/143  3.37/3.03/2.73   Texas Southern was found out of compliance with a bunch of Standards including 501(b) in June 2017 and ordered to take remedial action.  They were supposed to come up with a reliable plan to come into compliance.  LSATs are up from 146/143/141 and GPAs are also slightly up, while class size is down from 256 to 217. So Texas Southern (unlike Cooley) has taken concrete steps to improve, although, in my estimation, it still has a way to go before the ABA should relieve it from further remedial action.

5.  North Carolina Central University (last year: 7) NC Central was found out of compliance with Standard 501(b) last December, then promised to raise their standards and the ABA found them back in compliance in June after taking “concrete steps. . .with respect to its admission policy and practices”.  So, how much did NC Central improve?  Last year they were at 149/145/142  3.43/3.22/2.95.  This year: 150/146/144 3.50/3.26/3.07.  These are real, significant, improvements.  (Note to WMU Thomas Cooley – this is what “concrete steps” actually look like.)  Furthermore, NC Central pledged to admit no students with an LSAT below 142.  NC Central had to shrink its class from 166 to 103 to make this happen.  NCC is to be commended for the great strides it has taken. 

6.  Concordia (last year: 10) Concordia is at 151/148/144 3.52/3.05/2.80 with 59 students enrolled.  Their median is up one point and their bottom GPA is up from 2.59, so the school is going in the right direction.  But the school needs to stop admitting students below 145 if they ever want to gain respectability.

7.  (tie) Thomas Jefferson and Florida A&M (last year 5 and 8): TJ, currently on probation with the ABA, shrank to 59 students with a profile of 149/147/145 3.09/2.80/2.53. This is a significant improvement from last year’s 147/144/142  3.11/2.84/2.59, but is still too low, so long as California maintains its current tough cut score for bar passage.   FAMU has thus far evaded ABA action, despite very poor bar results.  FAMU is at 149/146/145 3.36/3.09/2.79, up one point at the 25% LSAT but otherwise unchanged.  FAMU did shrink its class size from 222 to 190 and admitted 49% of applicants, compared to 53% last year, so they appear to have made modest improvements to the bottom end of the class.  This will probably be enough to keep FAMU out of trouble with the ABA, especially since they are above NCCU, which has now been held back in compliance.

9.  Widener Commonwealth – New to the list this year, Widener shrank its class from 128 to 117 but still could not maintain its admission standards. Although it held firm at the 50% and 25%, its 75% dropped troublingly.  2017: 150/147/145  2018: 148/147/145.

10.  University of the District of Columbia – UDC had a similarly credentialed class this year as last year, but had to shrink the class from 93 students to just 64 to maintain their standards.               2017: 151/148/145  3.22/2.95/2.60  2018: 150/147/145  3.17/2.92/2.72.   There is probably one too many law schools in DC right now.   UDC is in trouble. 

Dishonorable Mention: There are several other law schools with 25% LSATs at 145: Ave Maria, Charleston, Mississippi College, North Dakota and Roger Williams.  These schools have apparently calibrated that 145 is good enough to stay out of trouble with the ABA, and they are probably right. 

More notes on Last Year’s Bottom 10:

Atlanta’s John Marshall was tied for 8 last year at 149/146/144. The school was found out of compliance with Standard 501.   This year they raised the incoming profile considerably to 152/149/147, up 3 points across the board.  The school shrank from 194 1Ls in 2017 to 108 this year and accepted only 46% of applicants compared to 52.5% last year.  Bafflingly, the ABA determined in November (announced just today) (see also here) that the school was still out of compliance with 501(a)  and (b) and placed the school on probation, imposing specific remedial actions.  The school also dramatically decreased its academic attrition rate from the previous year from 22% to 12%.  It is not at all clear what prompted the decision to place Atlanta’s John Marshall on probation. At least on the face of it, it appears grossly unfair.  Expect an appeal and possible lawsuit against the ABA for arbitrary and capricious action.

Speaking of unfair, there at least 30 schools (not counting Puerto Rican schools) with lower admissions standards than Florida Coastal School of Law in 2018.  Florida Coastal shrank to 60 students and raised its standards to 153/150/147   3.36/3/14/2.83 compared to last year’s class of 106 students at 151/148/145 3.10/2.83/2.59.  This is an enormous improvement, and places Florida Coastal above Barry, FAMU and St. Thomas in Florida, none of which have been found out of compliance with admissions standards, yet the ABA persists in finding Florida Coastal in continued non-compliance with 501(b). 

Overall, the news on the admission front is good. There are far fewer law schools exploiting unqualified students.  Sadly, the one law school that unquestionably is, Western Michigan Thomas Cooley, is getting away with it.

Disclaimer and note to prospective law students and other readers: This post is not intended to suggest that the law schools on the "Bottom 10" list are the "worst" law schools in the U.S., or even that any of the law schools in this post offer a sub-par legal education.  My focus is on whether law schools are exploiting students by admitting applicants who are at very high risk of failure.  Many law schools that are not particularly selective in their admissions requirements nevertheless offer a high quality legal education.  Prospective students should look at other measures such as bar passage rates, job placement rates, and average indebtedness to determine if a law school offers a good value proposition.  Look at Law School Transparency's Law School Reports for the best information. (Disclosure - I am the Chair of LST's National Advisory Council)  Be sure to ask the admissions office at law schools to which you are applying for specific data about how law students with similar LSATs and GPAs to yours have fared at that law school in recent years.  I recommend that students with LSAT scores at 146 or below take the LSAT again (after studying for the exam using Khan Academy's free prep course) or consider another profession.  Chances are you will struggle in law school and there is a very good chance that you will academically attrit or fail the bar. 

 

Comments

[The Law Offcies of Kavanaugh Thomas, LLC, PC, LTD, Chartered, AV Rated]

Don't knock these joints....if one grad gets lucky and scores a big PI matter (fractures, wrongful death, cancers...) its all worth it... The chance to score a client run over by a bus is a heck of a lot better that working at Ross as an assistant shoe manger or as an zone manager for Wendy's for 41K a year. Chasing three bill DUI's and getting to knock off by noon is a lot better than smelling like grease and having some boss yell at you cause you didn't "make the numbers." Just like General Motors; a car for every purse. A law school for every student.

[TruthFirst]

Great article! Law schools should take note of what David Frakt is writing; he really knows his stuff. It is _shameful_ that law schools - public and private alike these days - admit students who clearly have no chance of ever passing the bar or get a decent job, especially in times when AI is taking over the jobs formerly performed by law graduates in the lower quarters of their classes.

Hm... North Dakota, this time?! Something is going on (or not!) in the prairie states....

[The Law Offcies of Kavanaugh Thomas, LLC, PC, LTD, Chartered, AV Rated]

Synchronicity. But for Western Michigan Cookey School of Law, there would be no Michael Cohen. But for Michael Cohen, there would be no hush money payout to Stormy Daniels. But for Michael Cohen and his cooperation agreement we would not be witnessing the downfall of our mendacious, bigoted, self-serving Great Dear Leader. Thank you Cookey School of Law. Bless you. You are in my thoughts and prayers.

[Kevin Dennis]

A brief note to law school snobbery, JUST STOP. You must percieve some personal threat from a school like WMU Cooley to continue to make such raw-opinioned statements intended only to degrade its students and faculty. Then, you continue to insist that the behavior of an alumnus from ages ago is the sum of the law school's parts. It is ridiculous to think that a person so attenuated from the law school could be the embodiment of the more recent and current student body. You should be ashamed of your attempts to degrade the hard work and dedication of the many fine students at WMU Cooley, or the institution from which they will be graduating and joining the legal profession. These hard working and deserving individuals are your current and future colleagues. It should be the goal of all law schools to produce professionals, not elitists. Please, JUST STOP.

[Matt Larry]

You forgot to mention the diversity of these schools, so I'm going to assume you're racist.

[Berta]

David Frakt is attempting to built a campaign to support Florida Coastal School Of Law. As you will see, he is injecting FCSL into his arguments. Next thing you will find is FCSL citing his articles again within their lawsuit against ABA.

[David Frakt]

Kevin -
I understand that as a student at WMU Cooley that you would prefer that your law school not be criticized. But my criticism of WMU Cooley has nothing to do with snobbery. I am simply concerned with protecting consumers from exploitation. While there are undoubtedly many Cooley grads who are competent attorneys, Cooley has also admitted thousands of students over the years who had no demonstrated aptitude for the study of law. And they are continuing to do this year. While a few of these students outperform their predictors and succeed, most don't. These students end up flunking out of law school, or, if they manage to graduate, failing the bar, often repeatedly. There is a fine line between providing opportunity to people who want to be lawyers and taking advantage of people who want to be lawyers. Reasonable people can differ as to where that line should be drawn. But, in my opinion, Cooley is well below that line. And by admitting droves of students with far lower credentials than any other school, WMU Cooley hurts its current students and its alumni by destroying the reputation of the school.

[David Frakt]

Berta -

I have two goals in writing these columns. My first goal is to try to get law schools to act ethically and responsibly by not admitting students with no reasonable aptitude for the study of law and are therefore at extremely high risk of failure. Florida Coastal used to be one of these schools, along with its sister InfiLaw schools, Charlotte and Arizona Summit, and I regularly called for the ABA to take action against them. When law schools do not act ethically and responsibly, I use this forum to try to publicly shame them. When law schools mend their ways and start acting ethically and responsibly, I use this forum to give them credit for doing so. Based on the publicly available data, Florida Coastal has mended its ways, at least with respect to admission standards.

My second goal is to get the ABA to do its job as an accreditation agency to protect consumers by reasonably and consistently applying its standards. When the ABA does this, I praise the ABA. When the ABA acts unreasonably, and in what appears to be an arbitrary and capricious manner, I criticize the ABA. I am not "attempting to built (sic) a campaign to support Florida Coastal". Florida Coastal has sued the ABA and has quite capable attorneys representing it. I am simply identifying what appears to me to be disparate treatment by the ABA. The most exploitative law school in the country right now is WMU Cooley. Florida Coastal did not admit a single student with an LSAT below 145 in 2018. WMU Cooley admitted over 270 students with an LSAT of 142 or below. (142 was their median) I am baffled how the ABA could say one school is in compliance with the ABA's admission standard and the other is not. Similarly, I don't understand why the ABA says that Atlanta's John Marshall Law School is not complying with the Admissions Standards, when they appear to currently have reasonable and ethical admissions policies.

UPDATE: Since comments to this post are closed, I am going to add some thoughts into this comment related to the later comments. Some people have asked why I am focused on inputs and not outputs like bar passage. First of all, as those who read this blog regularly know, I write about bar passage all the time. But bar passage rates are no longer reported on the 509 Reports. They are reported separately in the spring. So I don't have current bar examination statistics to report on. Furthermore, what has been proven over and over is that schools that admit a high percentage of very high risk (145-146 LSAT) and extremely high risk (144 and below) students to their full and part-time programs ALWAYS have atrocious bar results 3 and 4 years later when those classes graduate. So I think it is important to identify those schools that continue to admit such classes. And I do not buy the argument that these are intelligent adults who can appropriately weigh the risks. Law schools only report results in the aggregate, so students don't have any way of knowing that the school's overall results may not be reflective of their individual chances of success. For example, if a school has a 60% first time pass rate, chances are the top quarter of the class (by admissions credentials) will have above an 80% pass rate and the bottom quarter will be below 40%, and also have a high attrition rate. At some schools, the real rate of success of students in the bottom quarter of the class is close to 10%. Few rational adults would willingly go $150,000 into debt for a 10% chance of becoming a practicing lawyer. So, I will continue to report on bar pass rates when new bar passage information becomes available. But until a school can demonstrate a reasonable success rate with very low aptitude students, I will continue to criticize those schools that continue to admit low aptitude students knowing that they have a very low probability of success, without informing those students of the true facts.

[David Frakt]

Matt - I'm not sure if you are being facetious here, but just in case you are serious, no , I am not a racist. There are many law schools in the United States that have extremely diverse student bodies and still maintain reasonable, ethical admission standards. I am a strong supporter of diversity. Diversity in the legal profession is not advanced by law schools that admit large numbers of unqualified minority students who are at extremely high risk of failure.

[Stein]

David Frakt with all due respect, i do not believe what you're trying to portray. Also ABA has not acted arbitrary and capricious. You're misrepresenting facts. What do you know about the financial status of Florida Coastal School of Law ? Are you aware that the owner of the campus is looking for a new tenant to lease the entire campus building to it ? Are you aware of the type of student services FCSL removed ?

For profit schools are shutting down due to borrowers defense claims (infilaw is dealing with quite few thousands claims) and close school discharges. Infilaw is no different from its remaining pack. They abused the system for the sake of profit with reckless disregard to students' lives.

Infilaw isn't different from other shattered for-profit institutions
https://www.insidehighered.com/quicktakes/2018/12/19/vatterott-educational-centers-close

Subject: Closed School Discharge Changes

https://ifap.ed.gov/eannouncements/121318ClosedSchoolDischargeChanges.html

If your goal is to try and prevent ABA from sending a fact finder to the school, then you won't find any public support because the entire lawsuit by FCSL is to prevent ABA from sending a fact finder to find out what exactly FCSL trying to hide.

[David Frakt]

Stein - You are free to believe or disbelieve what you like. My comments are based on the ABA Required Disclosures known as 509 reports, which report standardized information from all law schools regarding the credentials of admitted students. Based on that information, Florida Coastal admitted students of reasonable aptitude in 2018. I have no desire to prevent a fact-finder from going to FCSL. I have no specific knowledge of other things that may be going on at Florida Coastal that would warrant the ABA sending a fact-finder. I have no information about the financial status of FCSL. I assume that it is not very good because the size of the student body has shrunk very dramatically. If you have information that you believe would be of interest to our readers or to the ABA, I invited you to share it. If you believe that I have misrepresented facts, please identify the specific fact or facts that I misrepresented and provide the accurate information so that I may correct any misrepresentations that I may have inadvertently made. If you simply disagree with my opinion that the the ABA has acted arbitrarily and capriciously, you are welcome to offer a counter-opinion.

[anymouse]

Two things:

Cohen is a dope but that isn't because of his law school. For heaven's sake, Michael Avenatti went to George Washington Law School and he is also a pretty big dope who might end up disbarred or in prison.

Also, this post mentioned four HBCU (Florida A&M, Southern, South Texas, and North Carolina Central University). Hmmm?

Overall, I agree that these bottom dwelling schools are taking advantage of lower LSAT scoring students; however, I'd rather judge them by their bar passage rates. I'd wager that those are probably pretty low too; however, if we judged law schools by bar passage then TJ wouldn't be the only California law school on that list.

[anon]

Kevin

"These hard working and deserving individuals are your current and future colleagues."

No, actually, not. Law professors ( and wannabe law professors) are basically recruited from only a handful of law schools.

Moreover, they are likely to have come from privileged backgrounds: prep schools, vacations, resume building bs jobs, elite colleges, tutors, nannies: money. Not big money, but money. They know basically nothing about struggle or "opportunity" (as they have been sheltered and groomed since childhood to reap the rewards, and contrary to the "diversity" they claim, legal academia sticks to socio economic and social status attributes, not true opportunity for those who didn't share their privileges and advantages).

So, don't kid yourself. Those at the top of legal academia (including those who have captured the ABA) have no intention of ever considering graduates of substandard law schools to be "colleagues."

Instead, from their lofty perch, they consider inferior schools to be appropriate for inferior people (in their view, of course). Accordingly, nothing will be done to close substandard law schools that fleece their students, year after year, with bogus promises. (Whatever happened to the "best market for lawyers in history"?)

As for focusing solely on inputs, that debate has been engaged here in the FL. Spin it all day long, no matter: It is ridiculous to focus on inputs and not on attrition, bar passage and employment rates.

[The Law Offcies of Kavanaugh Thomas, LLC, PC, LTD, Chartered, AV Rated]

These bottom law joints are reminiscent of the ads found in any circa 50s-70s Popular Science and Popular Mechanics Blackstone College of Law and LaSalle Extension University. These magazines listed all sorts of Big Dollar promises for JOBS and Employment from bull dozer operator, carpet cleaner, lock smith, car crash investigator, knife sharpener, rubber stamp maker, cartoon artist, imported novelty seller...

[Roberto]

I think David Frakt is mommy's issue, Obama said it.

[TruthAboveAll]

Look, here's the deal: those of us who are law professors (or have been) know that many of our students are just not willing or able to believe that if they don't score well on their LSATs, they are very unlikely to "make it." Heck, they plead and cry and threaten suit to remain in law school even if they _also_ get very low grades in law school; another indicator of non-success, as it is typically measured, as attorneys. It sounds paternalistic, but Frakt has a point: since we all know that these potential or actual students are highly unlikely to make it past the bar or, if they do, to gain "meaningful" employment as measured against their previous expectations, it's better for them to not go to law school. Yes, they are in denial about that, but sometimes, you have to exercise some "tough love" in these cases. It truly is a consumer issue, as Frakt correctly says. What in the _world_ are you trying to obtain by calling him a racist and all sorts of things?! Please. That's nasty and below a mature, professional discussion.

Second, anon has a very good point: law schools are indeed - the vast majority of them, at least - hiring only from the top five law schools (if that). That's incredibly elitist and downright stupid. I'm sorry, no offense to those of you smart, nice, highly intelligent folks who, for very good reason, made it into those schools. We are proud of you! But I think we can all agree that it's ridiculous to think that only a handful of schools (actually, really only Harvard, Yale, and Stanford) can produce law professors that can teach students the law and how to think critically, etc. The same goes for the Supreme Court, incidentally (look where that got us recently!!!).

At bottom, I think law schools really ought to hold themselves way above what is currently going on: profit-making, snobbery, and self-serving procedures. Another example of the failure of the American educational system.

[Roberto]

Cry me a river - law schools scam.

https://www.theatlantic.com/magazine/archive/2014/09/the-law-school-scam/375069/

[Marty]

David Frakt, have you seen the recent ALT Article ?

https://abovethelaw.com/2017/12/which-law-school-has-been-put-up-for-rent/

[Marty]

"Imagine you’re a law student at a school that was recently on the receiving end of a letter from the American Bar Association which relayed the finding that the school was “significantly out of compliance” with accreditation requirements. Imagine that about one month later, you and your fellow classmates begin to see real estate listings for the very building your law school currently occupies. You’d, understandably, be quite worried about your law school’s fate.

This is what seems to be going on at Florida Coastal School of Law, where ads like this, from Foundry Commercial, offer prospective tenants the ability to “[l]ease full floors or entire building.” When listings like this are promising 44,000 to 220,000 rentable square feet, law students are absolutely right to question what’s happening"

https://abovethelaw.com/2017/12/which-law-school-has-been-put-up-for-rent/

Article notes:
How much is a law school going for these days? We tried to speak to an agent from Foundry Commercial, but were unable to get in touch with anyone prior to publication. We will update this post when we hear back.

If and when Florida Coastal is able to move out of its current location, we’re sure that students will have a lot to say about it. At the moment, some say that they’ve been misled, as they claim to have no recollection of being told about these plans in 2015.

[Stephen Roberts]

It seems to me that the most important stat is % of graduates who pass the bar. That seems to be a better measure of a law school than LSATs which is skewed by background and diversity. There are many trial lawyers who are gifted and succeed because they have the gift of persuasion no matter how well they did in law school. But they did have to pass the bar. Only 44.5 percent of its first-time test-takers at Texas Southern University Thurgood Marshall School of Law — 69 of 155 — passed the July 2018 exam and 86 did not pass.So why not include that in your analysis?