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As Charlotte Closes, a Plea for Data Integrity

The ABA Journal heralds the closure of Charlotte Law School. I have no editorial beyond, well, it was an honestly dishonest student loan funnel, struggling since January, and Betsy DeVos couldn’t save it. If we’re unlucky, it’ll bounce back.

As a tie-back to last week’s post on the ABA’s Council of the Section of Legal Education and Admissions to the Bar’s decision to simplify law-school employment data, which it’s walked back, I write to express worries about how the ABA manages data for closed or merged law schools.

As of now, users of the Standard 509 Reports page can merrily explore information on bygone law schools such as Hamline, but anyone interested in the adventures of post-merger schools such as Rutgers-Camden will find no separate information on it. It has no 509 reports, it doesn’t appear in the spreadsheets for past years, and in some years the “Rutgers” (merged) entry contains no information at all.

This poses a problem for researchers because the 509 reports reflect law schools as they exist today and not how they existed in the past. I guess it would take more effort to maintain information on old law schools, but doing so anachronistically raises the question of why the ABA bothers keeping reports for past years up.

I try to download a set of the 509 information reports annually as a backup (yes, it’s tedious) and because it’s partly how this blog found its footing. I don’t do so for the employment summary reports (because, yes, it’s tedious). I would prefer not to change my habits.

Thus, I ask that the ABA maintain it’s information reports on law schools consistently for the sake of researchers. Indiana Tech, Charlotte, Whittier, and the schools that have merged may not rise again, but I’m sure someone might want to know more about their existences, even for trivial information like application deadlines.

Will Law-School Employment Outcomes Be Politicized Under Trump?

Today’s headline spoofs a February 2, 2017, Atlantic article by Gene Sperling about what might happen when the U.S. government’s statistical agencies produce data that His Emolumence doesn’t like. It may still be a legitimate fear, but before anyone could neuter GDP aggregates, another statistical agency has unexpectedly taken the lead in the race to deprecate data: the American Bar Association’s Council of the Section of Legal Education and Admissions to the Bar. As you’ve likely read elsewhere—I strongly recommend Jerry Organ’s post on TaxProf Blog—the council has chosen to greatly reduce the data it requires law schools to report and present in their respective employment-outcomes tables and spreadsheets.

I won’t recapitulate Organ’s arguments, but I will try to highlight how the changes would affect specific topics I’ve reported on and opinions I’ve developed.

One, in his memo to the council (pdf), University of Virginia School of Law professor Paul Mahoney discusses my data mishap in my post, Class of 2016 Employment Report (Corrected), as evidence of “confusion” caused by the employment data. Unsurprisingly, neither Mahoney nor anyone at the council asked me for a response, so I must start there.

The issue was the ABA’s earlier decision to separately account for school-funded positions in the above-the-line employment “statuses” (“Employed-bar-passage required,” “employed-professional position,” etc.), which collectively add up to the total number of graduates. I had forgotten the ABA made this change, so I subtracted the school-funded positions from the number of bar-passage-required jobs. I don’t relish drawing attention to my mistakes, especially when my rebuttal makes me look sloppier than the accusation: I wasn’t “confused”; I plumb forgot the ABA changed the employment table. I work with these data once a year, so I slipped into the old habit. (In fact, just last week I added a note to myself to avoid that mistake again next year.) That’s an illogical reason to revert to the previous practice. Subtracting out funded jobs is a tedious process, and I don’t want to start doing that again. For these reasons, eliminating the employment status category for school-funded positions is a bad idea.

On to other aspects of the changes.

Two, eliminating the total number of graduates from the reports makes them more difficult to use. I regularly derive the percentages of graduate employment outcomes by various categories, and now calculating the total number of graduates at a given school or at all of the schools will be a chore. Another benefit of including the number of graduates in the reports is that it gives data users an opportunity to double-check the ABA’s and law schools’ numbers—an especially important process because I do not believe the ABA does so itself. If the number of graduates in the employment status section do not add up to the total, then I know there’s a problem. It’s something I’ve tracked behind the scenes, but it’s still useful. Now, everyone will need to do more math to arrive at what should be a foundational number.

Three, the new “Employed-Other” category is absurd. A law graduate working in a professional, non-law job like at a hedge fund is not the same as flipping burgers. If anything, the ABA should put more effort into fairly defining “Employed-JD advantage” and less into consolidating categories that make law schools look bad.

Four, the new “Unemployed or status unknown” category is also absurd. Again, it’s consolidating categories that may make law schools look bad rather than carefully specifying which ones make them look good. Moreover, I detest disjunctive definitions, e.g., “Social Security/Medicare/Medicaid,” as though they’re a unified program. Disjunctive definitions encourage composition fallacies and false dilemmas, something lawyers should avoid.

Five, I have used the broad “employment type” categories (e.g., “solo,” “2-10 lawyers,” etc.) to draw conclusions about how graduates’ jobs change from year to year. For example, in the post, “Change in Graduate Outcomes Driven by Small Jobs,” which analyzes the class of 2015, discussed how most of the decline in graduates that year was felt in 2-10-lawyer jobs. I also noted how jobs were distributed among law schools in, “Law Grad Jobs Unequal Like Income in Corrupt Countries.” The new changes hamper these detailed analyses—and in a way that masks underperforming law schools. Thus, the new 10-100-lawyer-practice category is overbroad.

Six, I recognize that some school-funded positions are more durable than others as Mahoney argues and even that applicants might prefer to attend schools that reemploy their own grads as an insurance policy against unemployment. Part of the problem is that “long-term” means at least one year, which includes positions lasting only one year, but until that term is replaced by a concept that cannot be manipulated by law schools, there’s every reason to see long-term school-funded jobs as dubious attempts at padding employment outcomes. Prospective applicants actually want to know their opportunities for indefinite employment, not one- or two-year gigs, before applying. (And yes, for this reason, I somewhat discount the value of clerkships too.) Moreover, separating law-school-funded positions based on income ($40,000) is simply arbitrary. Fixed dollar amounts eventually need to be updated according to inflation, they do not necessarily reflect the cost of living for a particular location, and they do not speak to the value of legal education. The median bachelor’s-degree holder in the 25-34 age bracket earned $46,099 in 2015.

Of Organ’s other criticisms, longitudinal data and consistency with NALP data stand out. I won’t repeat them.

It’s amazing that the council is so easily swayed by the proposal of one law-school professor without much deliberation. It’s an entire level worse than if the council had secretly produced the changes on its own because then at least there may have been some give and take in the process. Now it just looks as though the council is uninterested in its responsibilities and merely beholden to individual professors’ whims. I thought the ABA wanted to improve its image as a more transparent, responsive organization, but by rubber-stamping a  professor’s (and only a professor’s) wish list, it further tarnishes its credibility.

As for my opinions on the employment questionnaire—which the council would scrutinize as I’m not a law prof—although there may be reasons to simplify the employment survey, I would very much prefer to let it rest for several years. The fact that it’s adjusted so frequently indicates lack of seriousness about its purpose.

I recommend joining Organ’s petition in his post.

Office of Management and Budget: +$725 Billion in Direct Loans by 2027

Every year in July the Office of Management and Budget (OMB) publishes its Mid-Session Review of the federal budget, which normally includes the Federal Direct Loan Program and projects its future. This year, the MSR (pdf) was only 22 pages because Director Mick Mulvaney said there were only “limited budget developments” since the administration released its misopauperous budget on May 23, 2016. So let’s take a look at that instead…

It’s titled, “A New Foundation for American Greatness.” My favorite part reading it thus far is the entry, “Invest in Cybersecurity,” which features an unspecified commitment.

Anyway, the budget has the Federal Direct Loan Program information we’re looking for, so back to that. The federal government’s direct loans consist primarily of student loans, but there are a few other programs in there as well. However, federal direct loans do not include private student loans, but these are a small percentage of all student loans. Thus, the OMB’s measure is both over- and under-inclusive of all student debt, but it covers most of it.

The OMB classifies direct loan accounts as financial assets net of liabilities totaling $1.227 trillion in 2016. According to the office’s projections, by 2027 this figure will grow to $1.952 trillion—59 percent.

(Source: Budget of the U.S. Government Fiscal Year 2018 (pdf))

As with previous years, the current (2016) direct loan balance is below the OMB’s past projections, but not by much. For example, in FY2012, it predicted the balance would be $1.486 trillion by 2016, $259 billion (21 percent) higher than what actually occurred. Here are the OMB’s direct loan projections going back to FY2010.

Indeed, the most notable difference between His Emolumence’s OMB and Barack Obama’s is that it is now predicting far less student lending going forward. Total direct loans won’t even exceed $2 trillion. This, I think, is a more realistic assessment of where federal student lending is going. Whether this has something to do with the new administration or is standard practice for the OMB is outside of my knowledge base.

The OMB’s measure of direct loans is the net amount owed to the government, and the annual changes to that amount are not the same as the amount lent out each year to students. The Department of Education tracks its lending, which I discuss on the Student Deb Data page.

UK Media: Adam Smith Was a Marxist

Before the UK parliamentary election a few weeks ago, the Internet kept directing me to what I surmise was mostly conservative media reporting on the Labour Party’s proposed *horrors* land-value tax, aka “garden tax.” I’m not sure if “garden” here is the Anglo version of what I would think of as a grassy backyard, but it’s very surprising that collecting location rents for public finance was both a significant issue in the days before the election and didn’t result in a loss for for the party advocating it. That’s probably the best news I’ll report on all year.

Labour’s platform included a position in favor of “considering” replacing some taxes with a land-value tax. “We will initiate a review into reforming council tax and business rates and consider new options such as a land value tax, to ensure local government has sustainable funding for the long term,” reported the Mirror.

Yet the Conservative opposition treated “consider new options” as though Labour had a bill in hand, and the sputtering from Boris Johnson and Chancellor of the Exchequer Philip Hammond was illuminating. Articles published by The Telegraph and the Daily Mail quoted these men as saying that the tax would:

  • “Bring misery to every single family in Britain”
  • “Wreck the economy”
  • “Devastate farmers”
  • “Increase food costs”
  • “Attack land on Marxist principles”

A good chunk of this is politicized anti-tax paranoia. “They talked about taxes in their manifesto. That must mean they’re coming for you!” It’s interesting in itself, however, that the Tories’ audience must be yeomen landowners as opposed to renters or condo dwellers. Then there’s the Marxism stuff, which just demonstrates their ignorance. If they were familiar with capitalism’s talisman, Adam Smith’s Wealth of Nations, they would have come across book V, chapter 2, in which the author advocates taxes on the ground-rent of houses. So yes, Tories think Adam Smith was a Marxist.

More bizarre is the obsession with farmers. Supposing that a land tax did raise food-production costs, which it would not, why would it be somehow worse than the other taxes farmers pay? Is it because farmers are really connected to the land? Does that mean I work at a floating desk? Why don’t we hear about overtaxed urbanites who are really connected to commerce? Don’t taxes on their incomes raise their labor costs? (Hint: They do.)

Oh, and did I mention that Labour’s not advocating a tax on gardens but on the locational value of the space occupied by gardens?

Anyhow, the articles mistakenly cite 3 percent of the value of people’s property as the tax’s rate. Rather, the foundation for this statement originates with the Labour Land Campaign, which explicitly recommends beginning with a 0.85 percent rate on owner-occupied real estate—not 3 percent. (More here.) Neither of the articles’ factual errors have been corrected.

The Telegraph article also says, “Opponents of the tax say it would cause house prices to plummet, putting homeowners at risk of negative equity and forcing families to sell off their gardens to developers to lessen their tax burden.” First, it’s not a tax on houses—just where they happen to be. Second, why are housing shortages caused by undeveloped real estate a good thing? Third, why are the opponents against affordable housing? Notwithstanding the possibility of negative consequences to some homeowners, the Telegraph doesn’t find anyone to answer these questions.

And you thought American media was bad.

The good news is that Labour won (and no, I’m not a Corbynite), and the Labour Land Campaign’s thankless work resulted in positive coverage when anyone bothered to check their facts. It’s well earned.

Which Law Schools Are Like Whittier?

Whittier Law School announced it will no longer enroll 1L classes but will graduate the students it has. It is the first fully accredited law school that is straight up closing, i.e. it isn’t merging with another school or finding some other way out of its problems. It’s going for good.

Whittier is not the school I would’ve predicted to be the first to close. Certainly it was in a high-risk category, but I thought others were in direr straits, and Whittier isn’t even freestanding. Charlotte lost its federal loan funding. The ABA censured Valparaiso (pdf), put Arizona Summit on probation (pdf), and told Ave Maria it was out of compliance with its standards (pdf). La Verne lost its provisional accreditation once, and the fates of (un)merged Camden and Penn-State Dickinson appear sealed. Indiana Tech immolated on the launch pad. These days the ABA Section of Legal Education and Admissions to the Bar’s Web site looks more like an academic police blotter than an accrediting body’s homepage.

The question all this raises is: What law schools might be in situations similar to Whittier’s?

We can answer by comparing Whittier to other law schools on various dimensions, particularly debt, employment outcomes, and estimated revenue from full-time students paying full tuition. (Others have already done most of the work on bar-passage rates.)

This past year, U.S. News ranked Whittier as number two for average disbursed graduate debt, $179,056, but its figure was 20 percent higher than last year. It’s a volatile measure, but this year some of its notable nearest neighbors were Thomas Jefferson, San Francisco, American, Golden Gate, John Marshall (Chicago), and Florida Coastal. Most of these law schools featured prominently on debt rankings in previous years.

A couple years ago, I applied the Department of Education’s “gainful employment” rule to all law schools—not just for-profits—and found that Whittier’s 2014 graduates would need to earn more than $80,000 to avoid a failing grade. Four years of failing would mean losing access to federal funding, and nearly a quarter of Whittier’s graduates were totally unemployed after graduating. That figure hasn’t improved since (~23 percent for class of 2015 grads). We’ll soon learn how bad the class of 2016 is doing, but Whittier’s full-time, long-term, bar-passage-required employment rate has been so abysmal that it ranks near the three law schools in Puerto Rico. (Yes, bar-passage rates feed into this outcome.)

The one metric where Whittier wasn’t doing as badly as many other (private) law schools was its cumulative losses in tuition revenue from full-time students. In 2015-16, it took in nearly $6 million, but in 2011-12 it received $13.5 million. The 56 percent drop puts it at number 64 among private law schools (though the top schools, Vermont, Brooklyn, WMU Cooley, and California Western, reported more students receiving grants than they had full-time students, which would probably bump Whittier up a few notches). 56 percent is rough, but a bunch of private law schools lost even larger shares of money—and some took in only a few hundred thousand dollars in full-time tuition revenue last year.

Here’s what the situation looks like for all private law schools, sorted by the percent decline. Note that for once, I am including the two private law schools in Puerto Rico because I feel their performance is indicative of the worst. These figures are adjusted for inflation.

REVENUE FROM FULL-TIME STUDENTS PAYING FULL-TUITION
# SCHOOL 2011 2015 CUMULATIVE LOSS PERCENT CHANGE
1. Vermont 10,860,119 -5,422,079 -16,282,198 -149.9%
2. Brooklyn 10,782,779 -3,509,376 -14,292,155 -132.5%
3. WMU Cooley 1,557,772 -478,900 -2,036,672 -130.7%
4. California Western 25,045,967 -897,940 -25,943,907 -103.6%
5. St. Thomas (MN) 5,743,284 37,941 -5,705,343 -99.3%
6. Appalachian 9,093,131 125,300 -8,967,831 -98.6%
7. Washington and Lee 6,903,362 185,988 -6,717,374 -97.3%
8. Tulsa 4,599,211 142,116 -4,457,095 -96.9%
9. DePaul 14,469,813 681,750 -13,788,063 -95.3%
10. Albany 19,114,661 1,952,910 -17,161,751 -89.8%
11. Widener (Commonwealth) 9,036,506 965,862 -8,070,644 -89.3%
12. New York Law School 41,803,974 4,530,080 -37,273,894 -89.2%
13. Northeastern 4,283,568 511,720 -3,771,848 -88.1%
14. Syracuse 8,186,463 1,132,272 -7,054,191 -86.2%
15. Florida Coastal 33,851,726 4,908,200 -28,943,526 -85.5%
16. Duquesne 12,035,146 1,749,704 -10,285,442 -85.5%
17. Ohio Northern 8,637,468 1,301,500 -7,335,968 -84.9%
18. Pacific, McGeorge 11,571,986 1,786,138 -9,785,848 -84.6%
19. Campbell 15,454,205 2,407,975 -13,046,230 -84.4%
20. Regent 2,904,848 453,570 -2,451,278 -84.4%
21. Mercer 15,437,642 2,719,980 -12,717,662 -82.4%
22. Lewis and Clark 8,873,433 1,611,792 -7,261,641 -81.8%
23. Case Western Reserve 8,801,033 1,705,620 -7,095,413 -80.6%
24. St. Louis 18,241,963 3,605,940 -14,636,023 -80.2%
25. Southern California 15,531,071 3,075,166 -12,455,905 -80.2%
26. Charleston 10,513,451 2,206,380 -8,307,071 -79.0%
27. Faulkner 7,911,732 1,822,600 -6,089,132 -77.0%
28. Seton Hall 13,687,741 3,163,116 -10,524,625 -76.9%
29. Southern Methodist 6,211,571 1,448,898 -4,762,673 -76.7%
30. Charlotte 35,712,406 8,517,688 -27,194,718 -76.1%
31. Catholic 10,588,407 2,528,010 -8,060,397 -76.1%
32. Dayton 8,333,640 1,997,240 -6,336,400 -76.0%
33. Wake Forest 7,890,988 1,923,210 -5,967,778 -75.6%
34. Ave Maria 9,074,461 2,293,830 -6,780,631 -74.7%
35. Widener (Delaware) 15,458,193 3,989,430 -11,468,763 -74.2%
36. Western State 5,821,292 1,517,250 -4,304,042 -73.9%
37. Loyola (LA) 15,784,287 4,123,950 -11,660,337 -73.9%
38. Touro 11,489,969 3,078,650 -8,411,319 -73.2%
39. Quinnipiac 4,800,111 1,297,323 -3,502,788 -73.0%
40. Boston University 9,809,602 2,762,480 -7,047,122 -71.8%
41. Gonzaga 4,965,149 1,423,890 -3,541,259 -71.3%
42. Golden Gate 14,318,443 4,263,350 -10,055,093 -70.2%
43. Chicago-Kent, IIT 12,104,788 3,979,870 -8,124,918 -67.1%
44. Pace 11,888,268 3,993,088 -7,895,180 -66.4%
45. Atlanta’s John Marshall 16,084,711 5,613,700 -10,471,011 -65.1%
46. Mississippi College 12,823,594 4,506,420 -8,317,174 -64.9%
47. Washington University 11,705,942 4,181,706 -7,524,236 -64.3%
48. Stetson 22,598,743 8,212,224 -14,386,519 -63.7%
49. Valparaiso 15,710,039 5,732,824 -9,977,215 -63.5%
50. Northwestern 28,591,723 10,570,038 -18,021,685 -63.0%
51. Fordham 38,473,640 14,340,740 -24,132,900 -62.7%
52. Oklahoma City 10,178,065 3,810,630 -6,367,435 -62.6%
53. Elon 3,280,392 1,233,358 -2,047,034 -62.4%
54. Capital 7,447,505 2,820,480 -4,627,025 -62.1%
55. Cardozo, Yeshiva 21,942,175 8,838,095 -13,104,080 -59.7%
56. John Marshall (Chicago) 25,576,716 10,437,840 -15,138,876 -59.2%
57. Villanova 13,909,852 5,785,440 -8,124,412 -58.4%
58. Thomas Jefferson 17,301,310 7,207,200 -10,094,110 -58.3%
59. Samford 11,286,294 4,822,480 -6,463,814 -57.3%
60. Santa Clara 16,091,642 6,913,980 -9,177,662 -57.0%
61. San Diego 19,178,183 8,350,101 -10,828,082 -56.5%
62. Roger Williams 12,099,840 5,362,380 -6,737,460 -55.7%
63. St. John’s 18,866,076 8,366,530 -10,499,546 -55.7%
64. Whittier 13,502,174 5,989,950 -7,512,224 -55.6%
65. Seattle 15,747,526 7,248,700 -8,498,826 -54.0%
66. Creighton 7,850,075 3,625,800 -4,224,275 -53.8%
67. Hofstra 23,812,510 11,012,750 -12,799,760 -53.8%
68. Drexel 2,205,873 1,056,750 -1,149,123 -52.1%
69. Drake 6,852,106 3,342,476 -3,509,630 -51.2%
70. Vanderbilt 5,452,630 2,670,720 -2,781,910 -51.0%
71. Loyola (CA) 29,845,203 14,914,900 -14,930,303 -50.0%
72. Detroit Mercy 15,782,962 7,903,740 -7,879,222 -49.9%
73. Michigan State 12,439,389 6,453,892 -5,985,497 -48.1%
74. Tulane 13,779,350 7,311,590 -6,467,760 -46.9%
75. Barry 6,669,908 3,727,776 -2,942,132 -44.1%
76. Chicago 12,401,406 7,083,930 -5,317,476 -42.9%
77. Arizona Summit [Phoenix] 12,828,297 7,562,152 -5,266,145 -41.1%
78. St. Thomas (FL) 16,799,445 9,990,390 -6,809,055 -40.5%
79. South Texas 17,958,443 10,704,870 -7,253,573 -40.4%
80. Pontifical Catholic 8,442,917 5,132,426 -3,310,491 -39.2%
81. Nova Southeastern 24,168,295 14,852,135 -9,316,160 -38.5%
82. Marquette 11,533,718 7,312,710 -4,221,008 -36.6%
83. Miami 34,008,712 21,832,718 -12,175,994 -35.8%
84. San Francisco 15,483,541 10,028,040 -5,455,501 -35.2%
85. Western New England 3,630,743 2,375,332 -1,255,411 -34.6%
86. Chapman 13,208,102 8,859,600 -4,348,502 -32.9%
87. New England 12,668,264 8,665,140 -4,003,124 -31.6%
88. Suffolk 27,272,730 18,739,094 -8,533,636 -31.3%
89. Cornell 18,586,044 12,775,953 -5,810,091 -31.3%
90. Boston College 16,102,424 11,277,420 -4,825,004 -30.0%
91. Inter American 6,898,330 5,040,051 -1,858,279 -26.9%
92. Loyola (IL) 4,583,328 3,351,312 -1,232,016 -26.9%
93. Southwestern 20,968,555 15,449,600 -5,518,955 -26.3%
94. American 31,922,411 23,868,936 -8,053,475 -25.2%
95. Notre Dame 7,908,972 5,918,036 -1,990,936 -25.2%
96. Denver 17,465,736 14,026,950 -3,438,786 -19.7%
97. Emory 8,896,804 7,211,400 -1,685,404 -18.9%
98. Richmond 7,438,055 6,232,200 -1,205,855 -16.2%
99. Georgetown 52,209,277 43,872,470 -8,336,807 -16.0%
100. Baylor 5,148,380 4,777,042 -371,338 -7.2%
101. St. Mary’s 14,146,074 13,128,560 -1,017,514 -7.2%
102. Columbia 38,452,666 35,989,800 -2,462,866 -6.4%
103. Yale 15,515,266 14,918,850 -596,416 -3.8%
104. New York University 46,942,488 46,870,700 -71,788 -0.2%
105. Pennsylvania 22,739,776 23,802,872 1,063,096 4.7%
106. Willamette 3,947,758 4,251,625 303,867 7.7%
107. George Washington 32,385,362 35,444,670 3,059,308 9.4%
108. Pepperdine 11,117,822 12,539,100 1,421,278 12.8%
109. Harvard 41,997,217 51,660,654 9,663,437 23.0%
110. Duke 3,507,038 5,136,813 1,629,775 46.5%
111. Howard 5,501,024 8,221,176 2,720,152 49.4%
112. Stanford 11,569,636 17,613,762 6,044,126 52.2%
113. Liberty 96,858 189,372 92,514 95.5%
114. La Verne 171,882 3,369,344 3,197,462 1860.3%
115. Belmont 4,805,640 N/A N/A
116. Concordia 203,301 N/A N/A
118. Indiana Tech 94,080 N/A N/A
119. Lincoln Memorial 387,480 N/A N/A
TOTAL 1,672,895,574 849,546,398 -828,839,677 -49.2%
10TH PERCENTILE 4,583,328 203,301 -14,636,023 -89.3%
25TH PERCENTILE 7,890,988 1,822,600 -10,094,110 -76.9%
MEDIAN 12,253,097 4,518,250 -6,759,046 -58.4%
75TH PERCENTILE 17,465,736 8,517,688 -3,438,786 -32.9%
90TH PERCENTILE 29,845,203 14,918,850 -371,338 -3.8%
MEAN 14,674,523 7,199,546 -7,270,523 -36.3%

(Source: ABA, author’s calculations)

Obviously full-time, full-tuition revenue doesn’t tell all of the story—and not just for part-time-focused operations like WMU Cooley—but it definitely illustrates the kind of circumstances many private law schools find themselves in. The same must be true for public law schools. It’s in this context that we can ponder the solvency of other at-risk law schools. Whittier is the first big closure, but it won’t be the last. Universities whose law schools are losing lots of money and have poor employment and bar-passage outcomes are watching Whittier and its neighbors.