‘Shaping the Bar’ author says bar exam protects legal profession, not public

Episode Notes

Transcript

Julianne Hill:

Welcome to the Modern Law Library. I’m Julianne Hill, your guest host. I’m a legal affairs writer at the A BA Journal. Today I’m joined by Joan Howarth. She’s the distinguished visiting professor at the William S. Boyd School of Law at the University of Nevada Las Vegas, and she’s the Dean Emerita of the Michigan State University College of Law. She’s here with us today though because she’s also the author of Shaping theBar, the Future of Attorney Licensing. Hey, Joan,

Joan Howarth:

Good morning.

Julianne Hill:

Good morning. I enjoyed this very timely read. It couldn’t have come out at a more important moment, but before we go there, I want to talk about you and your career and your own path to theBar. When did you decide to become an attorney?

Joan Howarth:

I started law school in 1977, and I’m very lucky that I actually decided to put in the deposit and go to law school. I was worried that it was too expensive. I didn’t really have any money. I happened to be visiting my parents and my mother happened to tell me something I had no memory of, which was that apparently in fifth grade I had said that the chances of me becoming a lawyer like Perry Mason were a hundred percent, and my mother took me to talk with a family friend, Mr. Stickle, a really nice man, and he was the only lawyer that we knew and Mr. Stickle apparently told my mother and me that girls can’t become lawyers, and that was the end of that, and I forgot about it and had no memory until my mother happened to tell me that story. I, of course, was a guess that she left it at that, although it was an earlier era, but that’s really why I got off the fence and put in the deposit and went to law school hoping for the best.

Julianne Hill:

Wow. Even though you were a girl and everything.

Joan Howarth:

Exactly, exactly. Oh my God. I had been out of college for five years, which at that time counted as an older student, so some time had passed. So we’ve gone from the late fifties to the almost late seventies.

Julianne Hill:

Well, good for you. That sounds moms know the most amazing things. And then when did you decide that you wanted to be a professor?

Joan Howarth:

I thought about that actually early on for a variety of reasons. Unlike most of my friends and classmates, I actually loved law school. I didn’t, I don’t mean to say that it was fun and socially, I’m not sure how wonderful an experience it was, but I found it intellectually engaging and really it was the first time that I had found studying to be that engaging. So I actually in law school, chose to start as my first job teaching legal writing as a teaching fellow at Stanford Law School, and that was the purpose of that was to launch a career as a professor. Once I did that, I thought that I should not follow the path of my own professors. I should not inflict upon others what had been inflicted upon me, which was professors who really had no interest in or experience in practicing law. So I went out and practiced law and was very lucky in that part of my career and extended it longer. All my friends who were in legal education kept trying to get me to understand that the longer I spend in practice, the worse it was for a career as a law professor, which was and is true today still. But I was very lucky to have jobs with the public defender office that I loved. And then five years with the ACL U, American Civil Liberties Union in Southern California, which was a dream job also.

Julianne Hill:

And then you became a professor and the rest is history. Your book asserts that as gatekeepers of the legal profession, that law schools and licensers are failing the public and that the requirements to determine minimum competency are both too hard and too easy. That’s kind of a mouthful. What did you mean by that?

Joan Howarth:

The problem with licensing, and I say in the book that licensing has gotten to be a crisis. The problem is that we justify our habits and traditions in the name of public protection, but that rationale does not stand up to scrutiny. For example, if we really were going to be focused on protecting the public, our future clients, wouldn’t it make sense that any licensed attorney would’ve had to have done some sort of supervised practice prior to being licensed? We’re probably the only profession in the United States and we’re rare for lawyers around the world to license attorneys, new attorneys without ever having done any kind of supervised practice as a requirement. In fact, there’s no requirement under our current system that a new lawyer has ever even been in a law office, let alone practiced under supervision. That’s not how plumbers do it. That’s not how doctors do it.

That’s not how nurses do it. It’s not how anybody does it. It’s how we do it. And to me, that’s strikingly misguided in terms of public protection. And then on the other hand, what we do require is a set of hurdles that are not well tuned at bringing in future lawyers who can be competent and keeping out future lawyers who are not able to be competent. So for example, we are as a profession and as part of our culture in the United States, we are very comfortable for some reason with over-reliance on standardized tests. And we take them very seriously personally, we might hate them, we might love them, but we all sort of live in a society that believes in them. And so the test by the fact of the test’s existence, theBar exam somehow has credibility that researchers recently have shown it does not really deserve.

So we have bar exams that are outmoded, that are very much like bar exams that were taken many, many decades ago, and we have excessive memorization, which makes no sense. It made sense if we were in an era, say earlier in the 20th, early in the 20th century when even lawyers had a hard time getting access to law libraries and also there was a lot less law, and the law that existed was common law principles. So we still have bar exams that are about memorizing basic law, a thousand, maybe a thousand pages of rules of common law principles that have actually very little to do with what the law is that new lawyers use that requires memorization way beyond the appropriate cognitive load according to experts in memory and education. And we’re still doing that even though we know that that system is responsible for really glaring racial and ethnic disparities, and that system excludes on the basis of resources and money wealth. So we’re doing something that isn’t well suited and with an impact, which is the opposite of the diverse and inclusive profession that we say we want.

Julianne Hill:

I was really impressed with how light this book feels, and it’s an easy read for being such a scholarly topic, and I know you’ve written articles about this in the past, but it’s very clear and it’s very approachable, but somehow not dumbed down. And it made me wonder who’s your intended audience? I mean, it’s not in lawyerly language. Thank you. If you want to talk about who you want, who do you want to read this

Joan Howarth:

Book? I would say it’s in light lawyerly language. I didn’t want it to be scholarly. My main audience for this book is not law professors, it is lawyers, it’s judges, it’s bar examiners. I mean potentially it’s clients in the public, but really there are enough lawyers who I hope are the audience for this book. And what I understand from having worked on attorney licensing issues for decades is that it’s really challenging to get lawyers to want to think again about bar exams. Most of us, there are a few exceptions, but most of us have some personal experience. For some it’s harrowing. For others it’s not that bad, but it’s not exactly. Studying for theBar exam is rarely a highlight in anyone’s career. Achieving theBar results is a highlight. That’s a very important moment for lawyers.

Julianne Hill:

So people want to take it and never think about

Joan Howarth:

It again. They want to put it behind them that’s emotional and very real. Then the other part of it is people understand their own experiences. Lawyers understand and remember their own experiences related to bar exams, but we have in general, a hard time thinking about licensing and bar exams as policy issues. It’s very technical. No lawyers don’t have a clue how they’re scored, how theBar exam is scored, for example, or who makes those decisions. And in order to do the work it takes to pass a bar exam, you pretty much have to put your head down and believe in the whole enterprise to a certain extent, or you’d have a hard time motivating yourself. So it’s very technical, really the policy and it’s emotional. And so there are barriers for even thinking about the actual policy decisions. We sort of think of bar exams as sort of very unpleasant magic. It’s something that happens that we get a score and it’s yes or no, a thumbs up or a thumbs down at the end of it, but we don’t really understand what the decision making is, and we’d like to think of it as more valid maybe than it actually turns out to be.

Julianne Hill:

So when did you decide that this was not yet another article that you were going to write, and when did you start planning it and talk a little bit about your process of writing and pulling together your thoughts.

Joan Howarth:

I think that the book, which was published really at the end of 22, copyright 2023, I started seriously in 2019. And my original idea was that since I had published by that time five or six law review articles that I would do what many wise law professors do, which is sort of repackage what I’d already written into a book. And that didn’t seem that hard at the time. My foolishness was though thinking that that would work because as soon as I started that process, I realized that my law review articles were coming in sort of at the end of the story. I assumed in the sense that I would be able to build this book on other work about attorney licensing in the United States, and I found that nothing really existed, nothing existed that put together the legal education part of licensing and theBar examiner and court part of licensing. And I also found that I then had to kind of write, I had to learn and describe the history as the best way to explain what we need to do going forward, because the critiques that I am making are really grounded in the history of how we got here.

Julianne Hill:

And then how did you fit this into your teaching demands? I mean, and your professor demands and your dean at Demands, all of the things that you’ve been in charge of and doing, it’s a whole lot and writing takes a whole lot of focus and quiet time and not interruptions if you’re me, but wondering how you found that?

Joan Howarth:

This is my first book and it’s at the end of my career. And the answer of how I was able to do it really is, I think if I’m honest, the pandemic isolation helped because I was still working some of the time as associate Dean and as an administrator. I was still teaching, but I was doing everything remotely. So I really wrote the book at my dining room table, which is also where I taught and where I held meetings and where I’m sitting right this minute. In a way, it seems impossible to be able to get the resources and do this whole project in a sustained way from your dining room table, but I think the fact that I was at home made it in many ways more efficient for me to be able to do this.

Julianne Hill:

This seems like a natural place for us to take a quick break and hear a word from our sponsor when we return. I’ll ask Joan Howorth author and law professor how theBar Exam got to the state. It is now welcome back to the Modern Law Library, and I’m here with Joan Hallworth, the author of Shaping theBar. So Joan, we just were talking about theBar, which is in a state right now. It seems like there’s a whole lot of talk about it and a lot of people making changes in some parts suggestions that you’ve made. But as you mentioned just a moment ago, so much of where we are is where we’ve been and how did we get to the state that it is now?

Joan Howarth:

The story of attorney licensing in the United States is I think incredibly interesting actually, and it’s part of what I try to present in an easy, light, accessible, engaging way in this book. In the first couple chapters of this book, the issues about the lack of apprenticeships or the lack of actual lawyering experience under supervision prior to licensure, I think are mainly about the problems of legal education in the United States. And the history there is fascinating, and it goes back to Harvard in the late 18 hundreds and the very dynamic brilliant and extraordinarily influential Harvard Law School Dean Christopher Columbus lde, who purposefully set out to create a law school as a prestigious academic discipline in a university in part by separating from the profession, Langdell wanted professors who had studied law who were good students, but who had never practiced law. The practice of law would taint potential professors,

Julianne Hill:

Which is now like the opposite. It feels like the opposite of what you want as a student going in. Don’t you want somebody who’s out there and knows what the needs are

Joan Howarth:

As students who are going to be lawyers? We’re in law school in order to learn from people how to become great lawyers. And we are living today in the 21st century, still in the shadow of those values from langdell in the late 19th century, for example. I see that exactly now in the prevalence of hiring JD PhDs for law school faculties instead of jds who have practiced. Now, it’s true, we have more and more practicing lawyers on law faculties in the clinical programs that are so important for educating law students to become great lawyers. But the prestige and status issues within law schools still typically put professors who can actually and do actually practice law with their students at the bottom of the pyramid in terms of pay and benefits and opportunity to do scholarship and all of the perks of being a law professor. Many clinical law professors who are some of the best teachers and best lawyers that students can find in the law school are not even allowed to vote in faculty meetings. And some don’t even get to come to faculty meetings.

Julianne Hill:

So what happens in the law school is then reflected on what the type of questions that are on theBar, is that what the daisy chain of events are? It

Joan Howarth:

Is a chain of events. theBar examiners are used to giving tests, and so for the most part, they’re not used to requiring supervised practice or some sort of program related to apprenticeships. They are depending on the law schools. The law schools are depending on future employers to train about lawyering. That’s what Langdell believed in. And that worked for a while. That absolutely worked because the pressures of the business of practicing law were a lot different a hundred years ago. But what we know is that very, well, I won’t say very few, I’ll just say most new lawyers don’t get enough supervision and training when they start their practice. So we have a system where everybody is kind of counting on somebody else, either the employer or the law school or theBar examiners to take care of the readiness of new lawyers to represent clients effectively and competently.

Julianne Hill:

And some of the biggest problems with that thinking and theBar as it stands you say in your book, is that it discriminates against people who have to work and not take off time to study for this huge memorization task. And that leads to one type of lawyer who tends to have more money and have a history of lawyers in their family and things like that, which then kind of again, this daisy chain continues into creating legal deserts and not having lawyers that look like their clients. I found this really great background and really interesting to learn about.

Joan Howarth:

It’s true. We now have research that shows that even if you look for the compare people with the same academic credentials, having more resources makes you more likely to pass theBar exam. Having to work, having a paid job makes you less likely to pass theBar exam even if you had the same OSAT score for example. And that comes from a history where in an earlier era of our profession, we as lawyers were purposefully exclusionary, purposefully discriminatory. We created, and again, in different era historically, we wanted to elevate our profession in part by keeping out women, keeping out people of color, making sure that immigrants had a hard time becoming lawyers, making sure that people with resources were able to be attracted and able to be successful as lawyers. And the history demonstrates, not surprisingly that lawyers were purposefully discriminatory in our mechanisms because really when you think about it, a profession’s identity comes in great part from who is in and who is out, who gets to be a lawyer and who doesn’t get to be a lawyer.

And so the discriminatory, racist, anti-gay and lesbian anti inclusivity values of much of our profession controlled who got to be a lawyer purposefully. So being gay, for example, even up really through the time when I started in my career that being openly gay was potentially a character and fitness problem. For example, the accreditation, the history of a, a accreditation through the 20th century, especially in the first half of the 20th century, was a history of purposefully ratcheting up the requirements for law school accreditation in order to shut down the schools, the law schools that had been started precisely for African-Americans, precisely for immigrants, precisely for working people. We have records of antisemitism by bar examiners and courts. So the issue really is that we continue to use the methods that are a legacy from purposeful discrimination and then wonder why we are so unsuccessful in building the inclusive, diverse profession that we purport to want and that the public deserves.

Julianne Hill:

I know that in your book you suggest 12 steps of what can be done, and we don’t have time to go through all of ’em, but if you can pick one or two of what can be done, we will talk in a minute about what is being done, but what are the most urgently needed steps to be taken to change this historic bar exam?

Joan Howarth:

So there are important ways to reform theBar exams that are happening now, not necessarily as quickly and in all the ways that they could happen, but everybody understands that the current traditional bar exams have too much memorization. So theBar exam that is produced by the National Conference of Bar Examiners is being changed with the goal of less memorization and more orientation towards practice. That’s a work in progress that I am hopeful will turn into a better bar exam, but it’s a big project and an important project that we’re just at the beginning of seeing what’s going to happen. The other ways that bar exams can improve include more focus on the performance tests, which are part of current bar exams, but only a small part. And I believe that the performance tests are the most authentic, the most valid, and the most aligned with the actual practice of law.

And that the best bar exams are performance tests that ask law graduates to perform tasks that are the typical tasks that new lawyers are asked to do. And that’s a great improvement in bar exams. New lawyers are not asked to answer multiple choice questions, right? Not given four choices. New lawyers need to have habits of looking up the answers, and therefore bar exams should be as open book as possible. We’ve been able in Nevada to have open book, at least portions of our bar exam are open book since 2020 in Nevada. And I think that helps to make theBar exam more authentic and more aligned with actual practice. And then the other big thing that should happen is every new lawyer should have done some clinical work in law school, should have practiced law under supervision. That’s not just about the skills that are learned even more profoundly, it’s about accepting the responsibility to put someone else’s interests ahead of your own. And so the best way to learn ethics and professional responsibility is in the role as a lawyer surrounded by excellent lawyers, lawyers of the highest ethics lawyers who have the time and take the time to push student lawyers to understand and see the complexity of the ethical issues and often ethical dilemmas that surround us in the profession.

Julianne Hill:

This seems like a good place to take a break and hear a word from our sponsor when we return. I’ll be asking Joan about some new proposed changes in theBar around the country and about writing and law students. Welcome back to the Modern Law Library. I’m talking with Joan Howorth, author of Shaping theBar After years. It seems of people moaning about theBar and little changing. It seems like we’re in a moment. There’s a lot of talk and a lot stirring, I would say about theBar exam, about it being reconsidered, things that are actually changing, things that are at least on the table in front of various jurisdictions, including Nevada as you mentioned. Why is that? Why is it happening now and why does it feel like it’s all at once

Joan Howarth:

After not just years, but decades of stagnation in lawyer licensing? We are suddenly in a moment of change in all directions, liveliness engagement and new thinking that is long overdue and suddenly here in all directions. I think there are two reasons for the change and innovation that’s happening now. The first is that we finally got some better research about what minimum competence in a lawyer looks like in right around 2020. We have the Building a Better Bar study that Logan Cornett and Debbie Merritt directed from Isles that provided a framework and structure that is accessible based on research with 50 focus groups across the country. And that is by far the most sophisticated, the best work on minimum competence for lawyers that we have had by far. We also at about the same time had a practice study from the National Conference of Bar examiners and a practice study from the California State Bar, both of which were vast improvements over any prior practice studies or studies of competence in lawyers.

And even more importantly from my perspective than the practice studies that the NCBE in California did was the effort that the national conference and bar examiners undertook to rethink, re-examine what their bar exam products should look like. And the practice study was part of a larger project that included outreach. And the first stage of that study was talking with stakeholders, students, lawyers, judges, bar examiners about current licensing practices. And that told the National Conference of Bar Examiners. That study revealed to the National Conference of Bar Examiners the same complaints that people like me had been making for years about the excessive memorization and the lack of connection between the questions that were being asked and the work of new lawyers. So new research, important new studies, all of that was long overdue, incredibly welcome and is given us a platform of how to really think about what licensing should look like.

The other big thing that happened was the pandemic. The pandemic was a crisis for lawyer licensing and for so much else in our world that Bar Examiners had been renting convention centers years in advance, right? It was, it’s not easy to produce bar exams and to do all the work that bar exams traditionally require, but it is a routine. It is a well-oiled machine. It was a well-oiled machine, and suddenly in the summer of 2020, people couldn’t be brought into convention centers. The JT Center wasn’t available for theBar exam in Manhattan because it was an emergency medical facility and not to mention all the other issues. So we were in a different world and bar examiners had to confront the existential questions. But what are we doing here? What can we do? And what can we do now turned into very quickly, what must we do?

What does testing or assessing minimum competence really look like? And some states just carried on, waited for business as usual to return. Other states tried innovations. Nevada, for example, where I was a new bar examiner that year, delivered a computer based at home remote bar exam that did not include any multiple choice questions because they were not available to be given remotely. That included essays and included two instead of one performance tests. So we wanted to deliver a bar exam. Making those decisions required us to think more seriously about what we were getting from a multiple choice test. What were we getting from essays? What are we getting from performance tests? And that really started the process in Nevada of creating a new model. Other jurisdictions were able to consider and implement various versions of licensure based on law school graduation, diploma licensure, and that was a emergency stance that again, led theBar examiners and the Supreme Court in say Washington and in Utah to think about what they’re doing, long-term and the changing methods there.

Julianne Hill:

And the NCBE itself was working on the next gen exam, which every day I see some information about people’s thoughts about it. The idea being that it will be less memorization and more focused on what a young lawyer, or at least a new lawyer, let’s say, needs to do on day one. Do you think that this is going to rectify some of the ills of the current bar system?

Joan Howarth:

I think that any improvements, any increased alignment between bar exams and the actual competence to practice law is important. I also think that the efforts in several jurisdictions to think about licensure without any traditional bar exam are important. So we have, for example, New Hampshire has been doing that for a decade or more with their Webster Scholars program at the University of New Hampshire based on a curriculum that is designed to prepare law graduates to practice law well. So the two things that interest me the most about New Hampshire are, first of all, that the graduates of that program are sworn in to theBar in New Hampshire on the same day that they graduate from law school. The second thing that is interesting and important is that that whole program was initiated by the Supreme Court justices in New Hampshire in order to think about how to better prepare new lawyers.

So it’s not about anything different than public protection and protecting the public by having new lawyers be better prepared to take on the work of client representation. So New Hampshire was early in that we know that Wisconsin has diploma licensure, meaning that you take a certain curriculum, which most people do at the law school at Wisconsin and Marquette, then upon graduation you can be licensed in Wisconsin. That’s longstanding. Newer, however, is the portfolio of supervised practice pathway that has been adopted and is now being implemented in Oregon. So that’s extraordinarily exciting to see that the Oregon Bar Examiners really took the initiative in that state working with the court and with the law schools to think about providing new lawyers with choices about how to become licensed. One choice in Oregon is take theBar exam, whatever the version of theBar exam is that Oregon is offering.

Another choice now in Oregon is to take a pathway based on a certain number of hours and certain kinds of accomplishments in practice under supervision. That is an attractive alternative for lots of people, and it’s a benefit in terms of fairness and validity for students. It’s also potentially a great benefit for jurisdictions because the expense of the traditional bar exam has been a huge problem for jurisdictions. It’s a crisis in California right now. That’s right. And one of the reasons that the traditional bar exams are outmoded is that they are not easy to manage with appropriate accommodations for people with disabilities. On the other hand, a supervised practice pathway in a sense, can be a kind of universal design pathway to licensure. So that, I expect that the non-exam pathway based on work, it’s a little bit like going back to the history a little bit more like Abraham Lincoln’s way of becoming a lawyer. That pathway in Oregon and in the other states that are considering that which are several, will be particularly attractive to people who may be managing disabilities or who may have family responsibilities or may have other

Julianne Hill:

Financial responsibilities.

Joan Howarth:

They

Julianne Hill:

Don’t have to take three months off and another loan to take theBar Prep. They’re just, they’re working in it. They’re working, they’re working. They’re making money,

Joan Howarth:

Making money and learning in a different way. So the advantages in terms of inclusivity are enormous. And I think the advantages to the jurisdictions in terms of efficiency and cost are also going to turn out to be enormous. It’s a big change to start that, right? It’s a very big change and it takes a lot of work.

Julianne Hill:

Are the students reacting? How are they students, law students reacting to the potential changes in Nevada and the next gen? What are you hearing on the ground?

Joan Howarth:

There’s a lot of anxiety on the next gen front because the rollout has not had the timing that the national Conference originally envisioned. So some of the decisions have been slower to be made and some of the information has been slower to be shared. And there’s been uncertainty about even the content, which subjects are going to be covered. And there are very few practice questions that have been released. And so the students want to know what they’re expected to do and that it’s especially true for first generation students and students who don’t have the safety net or the security of a culture that was in some sense created for them and for their families. And so being knowledgeable about what is expected of you is important. The first students to will be taking the next gen are already in law school or about to start. So the faculties, particularly the academic success professors are working very, very diligently to prepare their students to take an exam, which is not as finalized, not as understood as many professors would prefer

Julianne Hill:

As these changes take place, we’re going back to the modern law library angle and the writing angle. Are demands on student writing going to change as these bar exams changed? Is writing going to be as essential or more essential?

Joan Howarth:

Writing will be essential in a different way. One of the hallmarks of legal education and of bar exams has been essays issue spotting essays in which you get a scenario and then you write an essay at breakneck speed trying to put in all the issues that you see and analyze those issues and come to sensible conclusions. The next gen bar exam will not have any essays. The Nevada plan that the Nevada Supreme Court is considering will not have any traditional essays either. In both cases, the writing will be in the context of performance tests in which the candidates are asked to write a legal memo or a demand letter or some work product that is a typical work product. theBar exam essays are not typical work products. Under the Uniform bar exam, you have 30 minutes to see a new problem and write everything you can think of to write that is relevant to that problem with multiple, many legal issues without any notes.

That’s not how lawyers work. And it results in slap dash pretty bad writing. Even good writers, even the best writers are not at their best under those conditions. The performance test gives us the opportunity potentially if the timing is correct, to see more advanced writing work from students. So the Nevada plan that we have proposed to the Nevada Supreme Court includes an early multiple choice test that can be taken during law school on foundational subjects. And then the only post-graduation bar exam would be one day of three performance tests with the idea that we want to see expert, not expert in the terms of a longstanding lawyer, but expert in the terms of lawyerly writing. We want to see minimally competent lawyerly writing. We want to see that you know how to organize a brief. We want to see that you know how to correctly caption a work product. And that with the, I don’t just mean the format, that’s nothing. I mean, understanding how to put the key ideas and legal principles into a caption of a brief, for example. So the opportunity that performance tests gives us is to see more advanced legal writing than what we have been able to see in essays.

Julianne Hill:

It’s really going to be interesting for the students. I’m betting that a lot of lawyers who listen to Modern Law Library have considered writing a book. Writing is so key to the lawyerly profession. What advice would you have for attorneys who have a book in them?

Joan Howarth:

My advice for any lawyer who wants to write a book is to write about something you care about. And we all have something. If you don’t have anything you care about, you shouldn’t be writing a book. But we all have a lot of things actually that we care about, and there’s a lot of tedium in writing a book. It gets boring at times. And the reason that you find, I found the motivation to keep going is that I really care about these issues. And so that makes a better book. I care not only about the substance, but I want to make reading my book easy and I want to make reading my book useful and keeping those goals in mind because I care about and I’m passionate about the content of the book, help me to be able to get from the beginning to the finish line.

Julianne Hill:

Great advice. And that is going to conclude our episode of Modern Law Library. I’m Julianne Hill for the A Journal filling in for Lee Rawles. Thanks for listening to today’s show. If you enjoyed it, please rate us on your favorite podcasting app. And if you’ve got a book that you’d like us to consider covering in this podcast, you can always reach us at books at ABA Journal dot com. Thanks for listening.