“Mr. Webb struck the Dean with a chair; the Dean knocked Mr. Webb down and the cause of legal learning was once more vindicated.”
“Plus ça change, plus c’est la même chose,” or “The more things change the more they remain the same.” A pessimistic French epigram attributed to Jean-Baptiste Alphonse Karr,[1] this phrase is also a satirical statement that can be applied to the undesirable situations currently faced by a number of American law schools, especially in comparison to some of their predecessors. This is particularly true as the recent closure of a number of law schools has done much to contribute to the negative spotlight on legal education. Though law schools close for any number of reasons, the toxic combination of the admission of unfit students, low bar passage rates, poor job prospects, and high student loan debt are said to be fueling some of the latest closures.[2] At the same time, the most recent spate of law school failures, as well as numerous other closures throughout the years, also show that the reasons they close their doors can be quite varied.[3] Still, none of the aforementioned issues are shocking, or even new, as there have been problematic law schools dating back to the earliest days of structured legal education. One key example was the Benton College of Law.
In 1896 the Kent School of Law opened its doors in St. Louis, Missouri, though it was quickly renamed the Benton College of Law and legally incorporated in 1897.[4] From all outward appearances, Benton experienced the normal growth one would expect from a fledgling institution. Fewer than ten years after the school’s founding, George L. Corlis, who would occupy the position of Dean for all of Benton’s forty-year existence, initiated a fundraising campaign to build a new facility for the budding law school.[5] At the time, Benton held classes in the local Y.M.C.A. building, so Corlis aspired to raise $75,000 for a new building, which was quite an optimistic goal in 1907.[6] Despite his efforts, the new building never came to fruition and resulted in the school instead purchasing a sizeable house in 1917.[7] That house, now designated a historic St. Louis Landmark, would be the home of Benton until its demise in 1937.[8]
Notable for being the first law school in St. Louis to offer night classes,[9] Benton was also one of the few law schools offering that option at all during the late nineteenth century. In fact, during the academic year just six years prior to Benton’s establishment, there were only ten law schools offering evening law courses in the United States. That number would change considerably in the ensuing years as there were forty-one schools offering evening law courses during the 1909-10 academic year,[10] and seventy-three schools offering evening law courses during the 1926-27 academic year.[11] This was also a time of considerable growth both in terms of the number of law schools and the number of students, as the number of law schools doubled during the 1890s and the law student population quadrupled. The ensuing years would also see a marked shift in the way law students received their legal education. By 1925 the number of students enrolled in evening law schools had nearly quadrupled from the number attending in 1910, while the number of law students attending traditional law schools dropped twenty-nine percent during the same period.[12]
Benton opened its doors around the same time the quality of programs offered by law schools began to be called into question. As a result of those questions, the Association of American Law Schools (AALS) was formed by the American Bar Association in 1900. The conversation about the regulation of law schools was driven by lawyers concerned about the quality of education in night schools and other part-time programs. In addition, there were a growing number of discussions about a lack of ethics in the profession. As a result, discussions at AALS meetings throughout the early 1900s typically focused on the growing number of night schools.[13] To further complicate matters for evening law schools, AALS began refusing to accept as members any school that offered day and night programs of equal length. The reasoning behind this move was that AALS felt night programs inevitably led to lower educational standards, and based upon that reasoning they refused to offer membership to any night school after 1917.[14] And night law schools also suffered from rumors about things like low admission standards, being diploma mills, lack of faculty interaction, and substandard facilities.[15] As a result of the growing influence of AALS, by 1937 there was not a single accredited school providing evening only instruction.[16]
Benton, despite its longevity, was never accredited, though accreditation at that time was far different from today so this was actually a fairly normal practice.[17] Similarly, the bar exam was far different from the one in existence today. In the early 1900s, applicants to the Missouri Bar had to be at least twenty-one years of age, have good moral character, and be subject to a strict oral examination in open court.[18] However, graduates of the Benton College of Law, the University of Missouri Law School, Washington University Law School, and the Kansas City Law School were all admitted without having to sit for the oral examination.[19] By all accounts, graduates of Benton were well schooled in the law after having been educated by various members of the legal community, most of whom conducted their legal practices by day and taught at night. Additionally, a number of the faculty were judges, or “late judges”, from the St. Louis area, which gave additional credence to Benton as a law school.[20] In fact, by its twenty-second year, Benton claimed that “more than three thousand students have received advantages from this institution since the date of its organization.”[21]
As would be expected, Benton had a number of distinguished, and some not so distinguished, graduates throughout its existence. Probably the most famous was William McChesney Martin, who served as Chairman of the Federal Reserve Board of Governors from 1951 to 1970.[22] Martin was famously known as the “Boy Wonder of Wall Street” by the time he was thirty-one years old.[23] Perhaps the most impressive graduate was Amabel Anderson Arnold, who holds the distinction of simultaneously graduating from two law schools in 1912.[24] Additionally, Anderson was the only woman enrolled in either of her law schools, was at one time the only woman on the St. Louis University faculty, and she helped organize the Woman’s State Bar Association of Missouri, the first association of women lawyers in the world.[25] These were incredible feats considering the rampant misogyny during that time period. Another graduate of note, though in a negative way, was Steven F. Pinter, who served as a United States War Department Attorney looking into claims of mass extermination in German camps during World War II. Pinter gained notoriety after becoming a Holocaust denier during the late 1950s.[26]
In 1910 the Benton College of Law became the troubled law school of its day as allegations of internal woes were first made public.[27] The specific incidents that drew public attention to the school involved disputes between two faculty members and the Dean. One of the faculty members was Charles F. Krone, a one-time Republican Senator from Missouri who was the son of a rather famous theater actor of that era. Krone was a distinguished graduate of the University of Missouri and practiced law in St. Louis throughout his career. The other faculty member was Colonel James Avery Webb, a lawyer, lecturer, and prolific legal author.[28] Webb was notable for being the leading expert on elevators during the late 1800s and early 1900s.[29] Webb also held the distinction of having co-founded the Benton College of Law along with Dean Corlis.
For his part, the Dean of the Benton College of Law was something of a phenom as well. George L. Corlis graduated from high school at seventeen and immediately began studying law under the tutelage of former Illinois Supreme Court Chief Justice John H. Mulkey. After several years of study with Mulkey, Corlis began formally studying law at McKendree College and graduated in 1891 with a LL.B. degree. After graduation, he began practicing law in the town of Metropolis, “and his first case was one of murder, when the brilliant young lawyer had the delight of securing the acquittal of his client.” Corlis would go on to practice law with the Dean of the law department at McKendree College before moving to St. Louis to continue his law practice.[30] A mere six years after obtaining his law degree Corlis would co-found the Benton College of Law.
In September of 1910 a blistering twelve-page statement written by faculty member Charles F. Krone was released to the local press.[31] In it, Krone accused Dean Corlis of a host of irregularities including profiteering, admission and graduation of unfit students, running a diploma mill, cronyism, exorbitant executive salaries that were unwarranted, failure to provide transparency to the faculty, and inability to provide better facilities and educational opportunities to Benton students. He also detailed other alleged misdeeds by noting how one of the three members of the Board of Curators was an insurance agent with no interest in the school as a lecturer or educator; rather, he was merely a pawn for the Dean. Krone went on to describe that Board member as the Dean’s friend, someone who had received no compensation other than “perhaps the annual box of salve and certificate of good behavior which the Dean awards to all men who serve him meekly, pay him promptly, or wait indefinitely to be paid by him.”
Krone’s statement also provided particulars about fellow faculty member James A. Webb being forced out of the law school “through a series of manoeuvers that would raise the envy of General McClellan.” This was notable because Webb was also a Vice-Dean, a member of the Board of Curators, and, along with Corlis, a co-founder of Benton.[32] According to Krone, “Mr. Webb and the Dean engaged in a fisticuff in the Dean’s office at the time. Mr. Webb struck the Dean with a chair; the Dean knocked Mr. Webb down and the cause of legal learning was once more vindicated.”[33] Krone also alleged that Dean Corlis paid off Webb to get rid of him, stating, “Mr. Webb, however, compelled the Dean to ‘buy out his interest’ in the college.” Krone went on to say that “the Dean paid, or rather obligated himself to pay, which is quite another matter, threee [sic] thousand dollars” as the buyout of Webb.[34] In an effort to ensure the faculty of Benton would know the exact nature of the interest bought, Krone went on to demand that the Dean provide the faculty with a financial accounting.
Salary was another issue raised by Krone as he took umbrage with Dean Corlis giving himself a 37.5% pay increase the previous year, bringing his salary up to $5,500 annually. To put this in perspective, in 2018 dollars this raise translates into an annual salary of $139,415, assuming a historic inflation rate of 3.04%. Not content with the raise alone, Corlis also gave himself an annual stipend of $2,000, which translates into an additional $50,697. Krone also took issue with Corlis for paying his personal stenographer, Miss Huber, $75 per month. To further put Corlis’s salary in perspective, the Dean of nearby Washington University Law School, an endowed school of high regard, was only paid $4,000 annually during the same period. Krone pointed out how the Dean of WU was an accomplished educator and business manager who dedicated all of his time to the school, suggesting that Corlis devoted more time to his private practice than to his duties as Dean. Krone, in a separate letter dated August 20, 1910, also detailed a conversation he had with Dean Corlis about the raise: “In conversation, you told me some time past that you took fifty-five hundred dollars a year out of the school for yourself, as Dean. You said that you thought you were entitled to as much as a Circuit Judge. As I have since told you, I disagree with you.” Insisting that Dean Corlis reduce his salary to a reasonable amount, Krone also asked for a meeting to discuss his complaints, which the Dean agreed to but later backed out of via telephone.
At this point Krone used his statement to condemn the Dean for having enriched himself and his cronies at the expense of the faculty members. He said, “The members of the faculty gave their services to the school free of charge for nearly all the years that Mr. Corlis and Mr. Webb were drawing out for their personal use the whole surplus of the receipts over the expenditures.” Krone went on to say that during the previous three years the lecturers were given “varying and precarious compensation” that eventually amounted to $10.00 per lecture. Payment was sporadic at best, and Krone asserted, “In my own case, I have earned the stipend twice, first by lecturing and then by working as a collection agency to secure my money from the Dean.” Krone also scolded Dean Corlis for the fact that the law school was still renting space in the local Y.M.C.A. building, stating that “the school should build up a library, and indeed a part of its receipts should be set aside annually for the ultimate purchase of a proper building within which to house it.”
Frustrated that Dean Corlis would not call a faculty meeting to address his concerns, Krone sent a personal letter to each faculty member, along with a copy of his initial letter to the Dean. He also took the opportunity to invite the entire faculty and the Dean to a meeting.[35] Krone warned in his letter that, “if nothing is done I shall certainly proceed to take steps in the courts, and in the next session of the State Legislature to cure the abuses, which, in my opinion, have crept into the administration of the college.” Krone’s call for a meeting was ultimately futile as many of the faculty members claimed to be “out of the city” while others “could not come for one or another reason.” This spurred Krone to write Dean Corlis a third letter, telling him he was calling for yet another faculty meeting because he wanted to exhaust peaceful means out of deference to members of the faculty before going to court.
To add to the drama Krone’s statement and letters had already caused, Walter H. Rollman, a young lawyer and recent graduate of the Benton College of Law, who also happened to be Krone’s legal associate, asked him to file a claim for damages against Dean Corlis. The action in question related to the transfer of a property owned by Rollman’s parents. Corlis is alleged to have caused an issue with title to the property due to his deficient drafting of a deed of trust, “through your defective advertising and handling of the sale under that instrument.”[36] The defective notice and publication were alleged to have resulted in the family incurring additional expenses to quiet the title. Krone agreed to file the claim by Rollman but first sent Corlis a letter, dated September 9, 1910, which was the day before the faculty meeting Krone had called. In his letter, Krone offered to amicably settle the Rollman matter, but Corlis ignored his entreaty.
Wasting no time, Dean Corlis responded with his own letter delivered via messenger on the evening of September 10, a short time before the faculty meeting called by Krone was to begin, though that meeting would never take place. In his letter, Corlis told Krone that he was dismissing him due to his conduct when addressing the Dean, for his mailing of various letters to the faculty, and for his threat to involve the Benton College of Law in litigation. Corlis went on to describe Krone’s actions as being “without justification on your part, and evidently prompted by malice or sinister motive and designed to prejudice the faculty against the Dean.” Corlis also accused Krone of actions “to destroy the confidence and harmony existing between them, to impair his influence and success in the conduct of the college, and to destroy discipline and injure its standing.” Not one to back down from a fight, Krone replied on September 12, 1910, that he did not recognize the authority of the Dean and Curators to discharge him and that he stood ready to teach as a lecturer for the session of 1910-11. Additionally, Krone appears to have goaded Corlis by signing the letter, “I am, at your service.” The next day, September 13, Krone made good on his threat and filed suit against Dean Corlis on behalf of Mr. Rollman.[37] On September 15, Krone sent yet another letter to Corlis denying he had the authority either as Dean or President of the Board of Curators to discharge him and stated that all of the grounds for his firing were falsehoods anyway. He also threatened further litigation in the form of a suit for breach of contract regarding his discharge from the law school.
As a parting shot in his September 15 letter, Krone wrote the following paragraph prior to signing the document:
I am pained when I think of you as the Dean of a faculty composed of real lawyers, all serving you most supinely and pathetically to keep up your rather luxuriant mode of life. Nevertheless, I shall hold your institution to my contract with it and for the breach of that contract. In due course I shall bring my action against your college, and we will then test out the question whether or not you have a right to discharge me because I have endeavored to compel you to conduct your college lawfully. At any rate, we will get at an accounting, if you will only plead that my discharge is justified by lawful cause. What is more, the suit, in connection with the little events which have now been passing, will probably raise a general discussion on the character of our law schools at large, and lead perhaps to a much needed improvement. The law on the subject certainly seems to require amendment.
So ended the debacle at the Benton College of Law. There is no indication that the faculty backed Krone to any degree, nor is there any record that he followed through with a suit for breach of contract. What is known is that there are no records indicating Krone taught at Benton after September of 1910. Neither is there a record that Vice-Dean James A. Webb, his pugilistic fellow faculty member, taught there after 1910 either. Whether Webb received the money from Corlis “buying out his interest” in the college is another mystery, though if Krone is to be believed it would be highly unlikely. However, even if the allegations made by Krone were only partially accurate, he certainly seems to have been correct about the need for a general discussion concerning the character of the Benton College of Law. He would have additionally been accurate about the need for improvement as a result of that discussion. In any event, the Benton College of Law went on to survive the drama of 1910 and would continue educating law students for another twenty-seven years. As such, one is left to wonder whether the school survived because Dean Corlis learned from the debacle, or whether it was simply a matter of luck.
The issues surrounding some of the law schools in existence today and in the intervening years are not much different than those experienced by the Benton College of Law. Questions about profiteering, acceptance of unfit students who can barely pass their classes let alone the bar, exorbitant administrative and faculty salaries, lack of transparency, profits not being used to provide a better education or to improve facilities, and students who are unable to obtain jobs in the legal field resonate exceptionally loudly in today’s environment.[38] Additionally, with plummeting bar passage rates in recent years,[39] one wonders if law schools that accept students with low GPAs and LSAT scores are the main factor. It also makes one wonder whether those students are truly prepared to practice law once they do graduate. This is an especially sensitive issue when the cost of attending law school is completely out of proportion to the actual salary the average attorney can realistically expect to make. To make matters worse for any poorly performing law school, the American Bar Association has begun to cast aside its paper tiger image and is sanctioning a greater number of institutions.[40]
Plus ça change, plus c’est la même chose.
Notes:
[1] Jean-Baptiste Alphonse Karr, Les Guêpes (Paris: Calmann-Lévy Publishing, January, 1849).
[2] See generally Brian Z. Tamanaha, Failing Law Schools (Chicago: University of Chicago Press, 2012).
[3] Thomas Cooley Law School closed its Ann Arbor campus in 2014, citing enrollment and profit issues; Indiana Tech Law School closed in 2016 after racking up $20 million in losses after only four years in existence, not to mention the lowest bar passage rate in the state; Whittier Law School is currently winding down operations due to low enrollment, bar passage, and employment rates; Charlotte Law School closed in August, 2017, after failing to meet regulatory requirements; Valparaiso University School of Law has not officially closed but has stopped enrolling new students beginning fall 2018; Savannah Law School became the first school to announce a closure in 2018 and Arizona Summit Law School announced a teach-out plan shortly afterward. Still other schools have sought mergers to stave off closings, such as William Mitchell College of Law merging with Hamline University School of Law.
[4] George L. Corlis, The Benton College of Law of Saint Louis, Missouri: What it is. What it has done. Its aims. Its needs. Why it is an object of public interest (St. Louis: Benton College of Law, 1907).
[5] Records from the Missouri Secretary of State indicate the Benton College of Law was incorporated October 8, 1897, and was voluntarily dissolved October 8, 1947, making it exactly fifty years old upon its dissolution. Mo. Sec. of State, https://www.sos.mo.gov/ (last visited October 10, 2018). However, the St. Louis Post-Dispatch ran a story on August 26, 1937, stating Benton would cease operations in September of that year. Another article in the Post-Dispatch, dated May 14, 1941, reported that Benton did indeed close in 1937. It should also be noted that the Post-Dispatch began referring to the school as the, “old Benton College of Law” around the same time. School records from 1897-1937 indicate Corlis was indeed the Dean throughout the entire forty years Benton was in operation. Associated Press, “City Law College To Close,” St. Louis Post-Dispatch, May 14, 1941, at 5B.
[6] Corlis, The Benton College of Law of Saint Louis, Missouri, 3. Additional information can be found in the 1907 Benton College of Law Catalog, which states the law school is located at, “Fifth floor, Association Building, northeast cor. Grand and Franklin Aves.” Assuming the building was fully funded in 1907, the goal of $75,000 would translate into $1.9 million assuming a historic inflation rate of 3.04%.
[7] The 14-room Lionberger House was purchased for $23,000 sometime during 1916 according to Landmarks Association of St. Louis, http://www.landmarks-stl.org/enhanced_and_endangered/2006_most_enhanced (last visited Dec. 10, 2018); however, the St. Louis Post-Dispatch reported the purchase the following year, making it unclear when the sale actually took place. “Delmar Boulevard Residence To Be Home of Law College,” St. Louis Post-Dispatch, Sept. 23, 1917, at 20B.
[8] According to Landmarks Association of St. Louis, the Benton College of Law sold the building to the Cooks & Pastry Cooks Local #26 Union in 1945; however, the St. Louis Post-Dispatch reported the transfer of the property from Benton to the Hotel Employees & Restaurant Employees Local No. 74. Charlene Prost, “Lionberger House will roar again as Grand Center offices, apartments,” St. Louis Post-Dispatch, Nov. 13, 2003, at B1. It is unclear whether Dean Corlis sold the property prior to his death on June 16, 1945, or whether his family sold it afterward.
[9] “Benton College of Law in Second Quarter Century,” St. Louis Star, Aug. 14, 1921, at 6B. While some American law schools offered night classes as an option, Benton only offered an evening program.
[10] Dorothy E. Finnegan, “Raising and Leveling the Bar: Standards, Access, and the YMCA Evening Law Schools, 1890-1940,” Journal of Legal Education 55 (2005): 209.
[11] Alfred Z. Reed, Review of Legal Education in the United States and Canada for the Years 1926 and 1927 (Boston: Merrymount Press, 1928): 40. Reed was the author of multiple legal education reviews between 1928 and 1935.
[12] Mark E. Steiner, “The Secret History of Proprietary Legal Education: The Case of the Houston Law School, 1919-1945”, Journal of Legal Education 47 (1997): 341.
[13] Susan K. Boyd, The ABA’s First Section: Assuring a Qualified Bar (Chicago: American Bar Association, 1993), 16.
[14] Steven C. Bahls & David S. Jackson, “The Legacy of the YMCA Night Law Schools,” Capital University Law Review 26 (1997): 237.
[15] See generally Dorothy E. Finnegan, “Raising and Leveling the Bar: Standards, Access, and the YMCA Evening Law Schools, 1890-1940,” Journal of Legal Education 55 (2005): 208-33.; James G. Rogers, The Standard American Law School (Chicago: American Bar Association, 1936); Will Shafroth, Annual Review of Education (Chicago: American Bar Association, 1937).
[16] Shafroth, Annual Review of Education, 10.
[17] Albert P. Blaustein, “College and Law School Education of the American Lawyer – A Preliminary Report (Part II: Law Schools),” Journal of Legal Education 4 (1951-52): 294.
[18] The oral examination tested the applicant’s knowledge of pleading, evidence, criminal law, equity, commercial law, property, contracts, Missouri statutes, the United States Constitution, and the Missouri Constitution. Missouri Revised Statutes, Chapter 73, §4937 (1899); see also Joseph F. Benson, “A History of the St. Louis Court of Appeals, The Early Years – 1875-1910,” St. Louis Bar Journal 30 (1983): 57.
[19] Missouri Revised Statutes, Chapter 73, §4937 (1899).
[20] Benton College of Law Catalogues from 1899-1900, 1901-02, and other years frequently used the term “late judges” to tout the experience of their faculty members.
[21] Benton College of Law Catalogue 1919-1920.
[22] Andrew F. Brimmer, “William McChesney Martin, Jr., 17 December 1906-27 July 1998,” American Philosophical Society 144 (2000): 232-35; see also Federal Reserve History at https://www.federalreservehistory.org/people/william_mcchesney_martin_jr (last visited Dec. 10, 2018).
[23] Harry Levins, “Great Fed chairman Martin dies at 91,” St. Louis Post-Dispatch, July 29, 1998, at C1; see also http://biography.yourdictionary.com/william-mcchesney-martin-jr. (last visited Dec. 10, 2018).
[24] Anne André Johnson, Notable Women of St. Louis (St. Louis: Woodward Publishing, 1914): 14-15. “She entered the City College of Law and Finance, taking a night course, September, 1910, successfully completing two years of law that year. The following year she attended the third-year lectures at the City College of Law and Finance, and the same year the fourth-year law work at the Benton College of Law. As a consequence, she graduated from two law schools about the same time, receiving the degree of LL.B., June 11, 1912, from the City College of Law and Finance, being the only woman in the class, having received the degree of LL.M. from the Benton College of Law, five days earlier, June 6, 1912 – again the only woman.”
[25] Women’s Role in Missouri History, 1821-1971, from the Official Manual of the State of Missouri, 1971-1972. Available at https://law.wustl.edu/Staff/Taylor/WOMEN/MOOFFMAN/mooff2/1stlib.htm. (Last visited Dec. 10, 2018).
[26] A good example is the letter written by Pinter in the Catholic weekly Our Sunday Visitor, June 14, 1959, p. 15.
[27] The St. Louis Post-Dispatch first reported the issues surrounding Benton in its September 30th, 1910 edition. “Krone, Discharged From Law School, Tells of Fight,” St. Louis Post-Dispatch, Sept. 30, 1910, at 1.
[28] Krone is listed as having served as a Senator from 1908-1910 according to the Historical Listing of the Missouri Legislature, published by Roy D. Blount, Secretary of State (1988): 69. Webb was the editor of Pollock on Torts as well as the last edition of Burrill on Assignments. He was also the author of Webb and Meigs’ Digest of the Court Decisions of Tennessee; Webb on Interest and Usury; Webb on Passenger and Freight Elevators; and four legal treatises. E.g. James A. Webb, Webb on Interest and Usury (1899). Additionally, Webb wrote multiple law journal articles throughout the years. E.g. James A. Webb, “Woman’s Right to Hold Office,” Century Law Journal 46 (1898).
[29] James A. Webb, The Law of Passenger and Freight Elevators (St. Louis: F.H. Thomas Law Book Co., 1896).
[30] Portrait and Biographical Record of St. Clair County Illinois (Chicago: Chapman Bros., 1892): 208.
[31] The Post-Dispatch did not print the entire twelve-page statement released by Krone, titled “George L. Corlis and the Benton College of Law: A Statement by Chas. F. Krone” (hereafter Krone Statement), but it did heavily quote from the Krone Statement in its reporting. Krone’s statement describes communications with Corlis and the faculty, and are the source for the summary of events, except where another source is indicated. The author obtained a copy of the Krone Statement from the Library & Research Center at the Missouri Historical Society.
[32] Webb is listed as the Vice-Dean and Lecturer on the Law of Torts, Negotiable Instruments, and Conflict of Laws in the 1907 Benton College of Law Catalog.
[33] Krone, “Krone Statement,” 1.
[34] In 2018 dollars this would amount to $76,000 assuming a historic inflation rate of 3.04%.
[35] This letter, dated August 24, 1910, asks for “[A] meeting of the faculty to be held at 8 o’clock in the evening of Monday, August 29, in order to discuss the whole situation.” The letter he included was the one he previously threatened to give each member of the faculty but had not.
[36] This letter, reprinted in full in the Krone Statement, is dated September 9, 1910.
[37] Rollman v. Corlis (Case No. 67326 of the October Term, 1910) was filed in the Circuit Court of the City of St. Louis on September 13, 1910. The case would ultimately be dismissed by the plaintiff without resolution on March 8, 1912.
[38] See generally Paul Campos, “The Law-School Scam,” The Atlantic (September, 2014); Brian Z. Tamanaha, Failing Law Schools (Chicago: University of Chicago Press, 2012); Bernard A. Burk, “What’s New About the New Normal: The Evolving Market for New Lawyers in the 21st Century,” Florida State University Law Review 41 (2014): 541-608.
[39] See generally Karen Sloan, “Multistate Bar Exam Scores Sink to 34-Year Low, Pass Rates Sag,” https://www.law.com/2018/09/17/multistate-bar-exam-scores-sink-to-34-year-low-pass-rates-sag/ (last visited Dec. 10, 2018); Debra Cassens Weiss, “Multistate bar exam scores drop to lowest point ever; is there a link to low-end LSAT scores?,” http://www.abajournal.com/news/article/multistate_bar_exam_scores_drop_to_lowest_point_ever_are_low_end_lsat_score/, (last visited Dec. 10, 2018).
[40] Joe Patrice, “10 Law Schools Sanctioned By The ABA – More to Come?,” https://abovethelaw.com/2017/11/10-law-schools-sanctioned-by-the-aba-more-to-come/ (last visited Dec. 10, 2018).