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The Role of Clinic in Linking Law and Justice
Keynote Address - Australian Clinical Legal Education Conference 11
July 2003, Caloundra Queensland
| Author: |
Judith Dickson BA, LLB, LLM
Clinical Supervisor, La Trobe University School of Law and Legal Studies
|
| Issue: |
Volume 11, Number 1 (March 2004)
|
Contents
Law teachers are teachers like professors in other disciplines. But unlike
their colleagues in some other disciplines . . . the products of their
intellectual processes need not and should not be measured solely by
so-called scholarly research and writing. Law Teachers must go beyond this
and assume the responsibility of being judged for improving the quality of
the legal process. They must be judged not by articles and books alone; but
also by what they are doing to promote dignity, humanity, and justice for
individuals through the legal process; and by what they are doing to this
end in the process of providing legal education to future lawyers.[1]
- William Pincus threw out this challenge 35 years ago as he was encouraging
law schools in the United States of America to develop clinical programs with
the help of Ford Foundation funding and CLEPR (The Council for Legal Education
and Professional Responsibility). He was very clear that lawyers, including
law teachers had a professional obligation to use their legal skills and
experience for the benefit of all members of their society - not just those
who could afford to pay for them. In fact, his dismay at the absence of
awareness of such an obligation in the numerous research grant applications he
reviewed at the Ford Foundation was the catalyst for his work in the clinical
field.
- I like William Pincus. I like the determination and passion for his
educational adventure that comes through his writings and I like his apparent
ability to persuade and lobby those in power by focussing on clinical legal
education as a necessary and obvious part of legal education.
- Yesterday, Simon spoke to us about a 'reconceptualising of legal education
in the clinical model'. Today I want to take up some of his threads as well as
those of William Pincus in the quote I have shown.
- One of those threads is the idea of reflection on our practice. If, as
William Pincus suggests, we, as law teachers are to be judged on how well we
are 'improving the quality of the legal process' through our educational
programs, then we certainly need to look hard and closely at what we are doing
and ask some perhaps uncomfortable questions.
- I begin with some questions about the meaning of 'law' 'justice' and
'clinic' and then some more questions about our ideas and practices within
clinical legal education. What are our goals and what are the assumptions
leading to formulation of these goals? This leads me to wonder how we see
ourselves within the law school environment. My tentative answers to these
questions leads me to some ideas about the role that clinical legal education
might play in linking or integrating law and justice and some practical
suggestions for how that role might be played out.
- Underlying my ideas are two concepts that have interested me and my
teaching and research partner Mary Anne Noone for quite some time. These are
first, the concept of the law teacher and specifically the clinical law
teacher as role model; and secondly the nature of ethical practice.
- What do we mean by these words? The first two in particular are bandied
about by lawyers, legal educators, commentators and the general public in
different circumstances and for different purposes. What are some of the ways
in which they are used? I want to spend some time on these usages because I
think they influence the way in which clinical legal educators approach their
work.
- Being a practical person, my starting point is a dictionary. The Oxford
English Dictionary 1989 2nd edition defines law first as "A rule of conduct
imposed by authority" and under that heading as:
"The body of rules, whether proceeding from formal enactment or from
custom, which a particular state or community recognizes as binding on its
members or subjects. (In this sense usually the law)."
-
The Macquarie Dictionary Federation edition 2001 defines 'law' as:
"the principles and regulations emanating from a government and
applicable to a people, whether in the form of legislation or of custom and
policies recognised and enforced by judicial decision"
- The Collins Thesaurus (1995) lists as primary synonyms "charter, code,
constitution, jurisprudence" and as secondary synonyms includes " act, canon,
code, command, ...edict, rule, statute".
- This all seems as we expect and know in our daily life. There is the idea
of imposition and the idea that the rules and regulations constituting the law
reflect the norms of the society. As citizens, how we respond to the laws that
bind us might depend on how energetic we are individually and what our
personal political views are. In any event, I agree with Margaret Davies in
her book Asking the Law Question when she says that : . . .law defines,
categorises, and sets conditions for communication. . . It may at times be
necessary or desirable to question or transgress the definitions and order(s)
which law establishes, but this does not mean that we can do without it in
some form or another.[2]
- I can't see how, as citizens, lawyers and legal educators, we can disagree
with this.
- Perhaps to the surprise of no-one here, the dictionaries give a clear
moral foundation to 'justice'. Both the Macquarie Dictionary and the Random
House Dictionary of the English Language (2nd ed 1987) define the word first
as " the quality of being just; righteousness, equitableness, or moral
rightness". The Oxford Dictionary similarly defines it first as "the quality
of being just" and then " the quality of being (morally) just or righteous;
the principle of just dealing. . . " The Macquarie Dictionary goes on to
define justice as "the moral principle determining just conduct" and
"conformity to this principle as manifested in conduct; just conduct, dealing,
or treatment".
- When we look at the definitions of "just" we see them as "actuated by
truth, justice, and lack of bias/ in accordance with true principles"
(Macquarie); "upright and impartial in one's dealings; rendering every one his
due; equitable" (Oxford). We see synonyms for 'justice' as "equity, fairness,
honesty, impartiality, integrity, . . ." (Collins).
- Justice also means vindication of a right, exercise of authority or power
to enforce a right and then it has the vengeful sense of infliction of
punishment on an offender (Oxford). There is another strand, however, to the
definition with which we are also familiar in our daily work. This defines
justice as the 'maintenance and administration of law as by judicial or other
proceedings" (Macquarie).
- It is this latter meaning which seems to appear most frequently in legal
and political language. Justice is frequently used as part of the term
'justice system'. For example, 'criminal justice system'; 'civil justice
system'; 'juvenile justice system.' It really seems to be interchangeable with
the term 'legal system' which we understand more easily to be the law(s) and
the system of courts and tribunals set up to administer and enforce it. I
always feel a little uneasy at this usage. Somehow it seems at odds with the
primary meanings of justice.
- We are also used to the term 'access to justice'. This was used in the
1990s by governments in their inquiries into the operation of the law and the
legal system in Australia. We had the Access to Justice Advisory Committee,
chaired by Ronald Sackville, with its Report Access to Justice : An Action
Plan. We then had the Justice Statement of the then federal government
implementing the Sackville Committee report. And there have been other
inquiries by both government and the legal profession using the terms. Law
Societies have their 'Access to Justice' committees. In these reports
'justice' or 'access to justice' seems to refer to the treatment of citizens
within the legal system.
- The Sackville Committee thought that there were three essential elements
to the concept of access to justice. These were:
* Equality of access to
legal services
* National equity
* Equality before the law[3]
- This approach to justice seems in keeping with the ideas of equity,
fairness, impartiality and integrity contained in the primary definitions.
This is not surprising given Ronald Sackville's history. I have wondered
whether he felt a sense of déjà vu in 1994. After all, 19 years earlier, he
had written the report Law and Poverty in Australia[4] as part of the Commission of Inquiry in Poverty. In it he had
argued that absence of substantive equality before the law was the critical
failure of the legal system at that time.
- Recently, the Victorian Attorney-General made a ministerial statement
entitled 'A fair, accessible and understandable justice system'. In it he
described 'justice' as :
[being] about openness, transparency and accountability. It is about
protecting the rights of citizens and ensuring that people are treated
fairly. It is about ensuring equality of access before the law, regardless
of financial resources, gender, ethnicity, age or sexual orientation. It is
about ensuring that our legal profession, our judiciary and our juries are
representative of the rich, diverse community in which we live. It is about
creating courts that are modern and accessible, not only in terms or our
court buildings but in the way that they dispense justice. . .
- The echoes of the Law and Poverty Report and of the 1994 Access to
Justice: An Action Plan are clear in this description. To achieve justice,
that is, to achieve equity, fairness, honesty, impartiality and integrity in
our legal system requires attention to structures and systems and to the
substantive law. In 1975 the Law and Poverty Report pointed out that many
areas of the law including tenancy law and criminal law positively
discriminated against poor people. In 1994 the Access to Justice: An Action
Plan stated clearly that:
Indeed the law has been more than inaccessible and unfair to some
groups, but has been an active agent of oppression and discrimination [5]
- It seems clear from a glance at any of the definitions of justice that I
have outlined and at the usages I have described, that law and justice are
inextricably linked. How can anyone say otherwise? Nevertheless, they do, and
frequently, and in my experience 'they' are usually found within law schools.
Practising lawyers, whatever their area of practice, have an experience based
knowledge of the connection. Just to finish my definitional section I'll pass
on to:
- There have been attempts at definition. Both Simon Rice and myself have
defined clinical legal education as a legal practice based method of legal
education in which law students assume the role of a lawyer and are required
to take on the responsibility, under supervision, for providing legal services
to real clients. 'Clinic' in Australia now includes not only the community
legal centre based university programs but also field placements or
externships in a variety of agencies and even private law firms. The
definition is perhaps too narrow now as some programs move away from the
direct provision of legal services to individuals or groups and focus on
involving students in legal policy or campaign work - real law in practice but
perhaps not with an individual client sitting in front of the student. We are
all familiar with the origins of clinical legal education in Australia. At our
last conference in 2000, Jeff Giddings from Griffith University thoroughly
surveyed the history and development of clinic in Australia- its growth out of
the free legal services movement in the early 1970s, which had a substantial
involvement of students and legal academics. The consequent ongoing connection
of clinic with the community by the situating of programs within community
legal centres - the university - community legal centre connection- has been
traced by Mary Anne Noone,[6] and remains a distinctive characteristic of clinic in
Australia.
- If we are to advocate the proposition that clinic is the model on which
legal education should be based shouldn't we spend some time reflecting on
what it is we do and why we do it? Perhaps we believe the verandah is the best
place for clinic. After all, in traditional Australian domestic architecture,
the verandah serves many useful purposes. Not the least of these is to bring a
breath of fresh air into the house. But verandahs need cleaning from time to
time. Reflection is in order.
- So why do we do whatever it is we do? What are the goals of clinical legal
education? And what are the assumptions giving rise to them? Is it foolish to
attempt a statement of generic goals? If we look back to our origins we might
say that the goals came first and the method developed to achieve them. Are
there therefore goals common to all programs? I am going to attempt the task.
- Clinic in Australia has traditionally had both educational and service
goals. I would describe the educational goal as multi-faceted, that is to:
* Through the practice of law to introduce law students to the ways in
which legal rules and processes (law/ the legal system) impact upon ordinary
people
* Encourage students to reflect upon their experience of the law in
practice and as part of this to critically analyse the social and legal impact
(the justice) of existing legal rules and procedures.
* Guide students to consider alternatives to the existing legal rules and
procedures
* Foster the acquisition of practical legal skills
The service goal is I think one of community service. That is the
provision of legal services to poor and disadvantaged people in the community.
- I put these forward as suggested general goals. I could expand on each and
I recognise that specific programs might have additional specific goals. I
also recognise that over the nearly thirty year history of clinical legal
education in Australia, the balance between the educational and service goals
has tilted at various times.
- Underlying these goals is and was a set of assumptions about the law,
justice, law school, law students and lawyers. Here are some examples:
- Law students are desperate for practical legal experience. Of course not
all are committed to legal activism. Some are in it just for the cv value
- Most law students come from sheltered if not privileged backgrounds
- Many law students are desperate to feel they are going into a career
which has value and in which they can help people
- Large numbers of people and groups of people in the community have no or
little access to legal services. Barriers for them include language, cost,
isolation, transport etc
- Often there is no legal remedy where there should be.
- Being a lawyer means having a professional responsibility to work for
justice yet so many lawyers seem to be working with powerful interests
against justice
- Law school curriculum is totally removed from the reality of life in
legal practice
- Most law academics haven't a clue about how the law they teach (which is
all rules and cases) operates on ordinary people nor express a view about
right or wrong
- Supervised clinical experience opens students' minds to the deficiencies
in the legal system and gives them skills to work for change
- The best way to change lawyers' values and conduct is to change legal
education. Over time, clinical legal education will have this effect
- If you accept this list as a fair representation of the range of
assumptions underpinning the clinical method, then it certainly portrays a
view that law and justice go hand in hand.
- My research into supervision practices conducted over the last two years
(and still in the 'draft' publication stage - the 'too busy' excuse) revealed
a profile of clinical teachers as lawyers coming into education from a legal
aid or community law practice. This was not exclusively so but mostly so. For
some time after becoming clinical teachers and supervisors, we still thought
of ourselves as community lawyers first and teachers/academics second. Mostly,
this changed over time. The self- description became closer to 'clinical
supervisor and practitioner'. We continue to value and give a high priority to
our role as legal practitioners but there was a recognition that we were in
the clinic to educate our students. Consider the goals again.
- I have some other suggestions about our self- image. Not all of them, when
I see them in print, make me feel very comfortable. Some of them come out of
my research and others are my own ideas - thrown up perhaps when I was feeling
particularly self- lacerating.
- We see ourselves as working for justice and as having a commitment to
achieving access to justice for our clients
- We sometimes see ourselves as activists with a mission to address every
legal injustice we are confronted with
- We believe we are good teachers and generally more skilled and certainly
more caring than our other academic colleagues in the law school
- We know we are innovative in our program development
- Our view of our outstanding teaching is bolstered by the fact that three
clinical teachers/programs have won Teaching Awards in the past few years
- We think we work much harder than regular academics. After all we have
12 or so students to supervise, their client work to oversee, the class work
to design and teach and the assignments to mark. Then we have all the
administration and program development, maybe fund raising etc. Our
colleagues only have to teach classes of 250 and mark the assignments. They
have lots of time for esoteric research.
- We know we are much better lawyers than they are. After all we do it
every day
- We think we have a better understanding of the workings of the local
legal profession and of the issues it faces than do our non -clinical
colleagues. We also actually know practising lawyers, judges etc unlike most
of them
- We sometimes feel inadequate in the law school environment because we
know we don't write scholarly articles as much as we should
- Is the self- image based on reality and knowledge or is some of it at
least, based on prejudice and insecurity?
- Does our practice bear out our beliefs about ourselves? I come back to a
point made by yesterday's speaker about the irony of clinical teachers urging
students to reflect on their practice but failing to do so themselves.
- Have we designed our program to leave space for discussion with students
of the justice of the legal system as played out in their case work?
- Does our classroom component address systemic issues? Are the readings
relevant to the clinical experience or have we just cobbled together a grab
bag of Alternative Law Journal articles on the basis they do the job?
- What approach do we take to our teaching of interviewing and
communication skills?
- Have we designed our assessment to meet our goals, ie to reinforce the
'talk' about injustice and action?
- Have we consulted our academic colleagues both inside and outside the
law school on any teaching issues?
- Have we organised the clinical staff to have regular meetings - to
debrief, to work out difficult students/clients? Ie the peer supervision
model of the counselling professions
- Do we use the OZ clinic list to raise issues for discussion?
- Are we locked into the view that the case work experience is rich enough
for our purposes? Have we talked to other clinical people or even other
academic colleagues or other non lawyers about introducing other components?
- Do we keep notes of recurring issues in the casework to base a law
reform submission on? Do we talk to our law school colleagues about the
issues?
- How do we handle the litigation process? Do we use every rule of
procedure at our disposal to win the case? Do we make sure the student never
asks the criminal client 'what really happened'? Or do we work towards a
different model of ethical practice?
- I have asked these questions and tried to confront us with some perhaps
uncomfortable ideas about how we see ourselves as clinical teachers because I
think, clinical teachers - even more so than other law teachers - have to meet
William Pincus' challenge. In other words, if we set clinical legal education
up as the most appropriate method of legal education and ourselves as
extraordinary teachers and academics, then we have to work hard to meet the
expectations.
- This leads me to the core of my talk - the role of clinic in linking law
and justice.
- My response to this topic - essentially a question - comes out of the
preceding discussion. My strongly held view is that the only legitimate
purpose for the continuance of clinical legal education programs in Australian
law schools is the integration of law and justice into the legal education
curriculum. The role of clinic in legal education therefore is to be the means
by which students and academics make the link between law and justice in
practice. I have only recently realised that this is what I think but it is a
view that has been bubbling away and directing a variety of my activities for
some time. It should follow that if the link is continuously made the
community will be served by more ethical lawyers and experience access to
justice more effectively. High hopes indeed!
- Before I go on to talk about how clinic can play out this role, I make the
probably obvious point that while it is useful for directors of clinical
programs to focus on the practical skills aspect when recruiting students and
persuading Deans and governments to put up more money, there is strictly
speaking no need in the Australian legal training system for universities to
fund a clinical program to teach practical legal skills. That supposedly
happens in the Practical Legal Training post degree stage of legal education.
In any case, skills are embedded in law courses these days and simulation is a
wonderful opportunity for skills training. Skills training might be better
with a real client and a critical approach but it doesn't need poor clients.
It is in the practical
development of the role that the two concepts I mentioned at the outset,
clinical teacher as role model and the nature of ethical practice, have most
importance. Carrie Menkel-Meadow echoed William Pincus when she asked 'Can a
Law teacher avoid teaching Legal Ethics?'[7] Her argument was that everything we do and say in teaching the
law gives a message to our students "This is how the law works. This is how
lawyers work". How much more is this the case in the clinical environment
where we carry the added influence of practitioners.[8]
- The nature of ethical practice influences the way we approach this assumed
role. It must include a belief that lawyers have a positive obligation to work
to improve access to justice and conversely that they do not encourage the use
of law to bring about injustice, oppression or discrimination.
- I refer back to some of my earlier questions about specific practices in
working with clients.
- I can hear a collective but politely silent groan around the room. What is
this woman on about I hear you ask? She mustn't have enough to do in her
clinic if she is dreaming up more projects! I can assure you I'm pretty busy
but - on reflection - maybe I could organise my work better and maybe I should
rethink what and how I do what I do.
- It is in this spirit of reflection and self-analysis that I make some
practical suggestions. I hope that they might make our lives as clinical
teachers more fun, lead those of us who want to, onto the scholarship path and
certainly not simply add to our work -load.
- A final point before I begin my list. As I said a little while ago, it is
implicit in what I say that the clinical goal of community service is central
to this project.
- First step: If your clinical program and you, are based off campus, pay
regular visits to the law school. If that's too hard - although I strongly
urge you to make the effort - at least visit the website and visit your
academic colleagues via cyber space. Why?
- Let's value our own work but let's not be prejudiced. Let's not be
dismissive of the pressures on our non-clinical colleagues. A narrow and
self-absorbed attitude might simply marginalise clinic even more and emphasise
the distance (intellectual and physical) between clinical and mainstream legal
education.
- Second step leading on from the first: Look at the programs we run. I know
that much if not all of the work done in clinical programs around Australia
could be described as educating clinical students to draw connections between
law and justice (making the link). BUT I THINK IT IS MOSTLY DONE IN ISOLATION FROM OUR ACADEMIC
COLLEAGUES AND THE VAST MAJORITY OF LAW STUDENTS.
- Take a close look at the work you are doing in the clinic. If it's a
generalist clinic, are there recurring problems, eg, credit, mobile phone
debt, employment abuses, etc. In a specialist clinic are there legal issues
that need research. Does the work raise wider issues of public policy?
- Identify the research strengths of your colleagues - use the web page.
Work out who seems to be working in areas related to the issues you have
identified.
- Wearing your innovative teacher hat, imagine yourself as a contracts
teacher or an employment law teacher or a teacher of international human
rights. Would your casework issues present interesting class problems?
- Wearing your clinical teacher on the scholarship trail hat could the
legal issues you have identified form the basis for a research grant
application?
- Ring up your colleague, suggest you have an idea for a research proposal
and thought they might be interested in working together. Flatter them,
suggest a coffee - on campus at first - and then invite them to the clinic.
You may be astonished at their knowledge of the area and interest in a
collaboration. Don't be dismissive of them just because they don't know
anything about legal practice and might not want to know. You might end up
with a valuable piece of research with practical use. At the very least you
have made a connection with a colleague for the future and they might, with
your encouragement, use your examples in their teaching.
- Talk to the Director of the law degree honours stream. Suggest they
refer students who are looking for topics, to you. Suggest some topics to
the director. Talk to your clinical students about an honours thesis.
- Get to know the first year teachers. The direct clinical experience is
only open to a few usually advanced students. The first year teachers have
enormous influence over hundreds of students. Suggest you could come and
talk to the group.
- Continue to do as many of us already do. That is, occasionally
organise seminars around topics relevant to the clinical work. Play the game
and word the title in a way to appeal to an academic audience (but don't get
carried away by post-modern language)
- Examine your assessment in the clinical subject. Perhaps that written
assignment could be redesigned as a team project and a law reform
submission. I know at least one Australian clinical program where this has
happened with much resultant publicity and potential for student
publication. While this might be restricted to a few students it spreads
the message to the community and to the law school [9]
- Continue to be a publicist for clinic and its work. Most of us are
quite good at this. It is important to ensure that we don't appear to
denigrate our law school colleagues in the process
- Offer to give a staff seminar. Most law schools have these on a
regular basis as a way of staff presenting ongoing research. It need not be
too threatening although assessment by one's peers is always nerve wracking.
Go back through the semester's work and find a case that raised difficult
legal or procedural issues or some other issue of law and justice. You might
present it as a teaching issue or you might be able to present it as ongoing
research into the particular issue and an opportunity for further research.
Think of the seminar as one of your classes and you'll be fine.
- Even better and probably less work, explore them with visiting lecturers.
This is an opportunity to share your knowledge of a different experience of
the law by introducing eg, a public interest lawyer, an activist, a partner of
a law firm who does pro bono work. You might find that your colleague is delighted. Two colleagues of mine
from University of Sydney Law School, Les McCrimmen and Graeme Coss, and I
were fortunate to be able to take this approach at our respective law schools
this year by taking advantage of the Commonwealth Law Conference in Melbourne.
We persuaded our law schools and our student associations to put up a small
amount of money and we brought a wonderful Ugandan human rights lawyer and
parliamentarian (Dora Byamukama) to Sydney and Melbourne early to speak to our
first year classes and give other seminars. At La Trobe University, the law
students association rapidly organised a public lecture and publicised it
widely. The feedback from the first year teachers at both places was that the
students were buzzing after the talks. They were certainly full of questions.
That was probably close to 500 students in total. Personally, I had approached the first year coordinator in the belief that
they were rigid and narrow in outlook. I discovered that they were excited by
the idea and want to do something similar next year.
- Some of this might appear to require more work and we already think we
work harder than our colleagues. The answer might be, once again, to reflect
on how we run the clinic, to focus on our goals and to readjust our
priorities. This might mean making hard decisions such as the decision not to
take on a new area of work. It might mean 'letting go'. By this I mean
accepting that we can't control every aspect of clinical work. We might have
to allow others in the law school who are not clinical academics to develop a
program, write the curriculum and take the credit.
- The key to clinical legal education's role in linking law and justice - in
integrating the two within the law school mentality - is, in my opinion,
collaboration with our law school colleagues. Unfortunately, it is probably up
to us to make the overtures and make the case that it is in their interests.
It's also up to us to make the case that, as Gary Blasi said at the 1996 APLEC
conference: Law is about problem-solving, but it is also about justice, about
moral judgments and ethical decisions, about the intersection of how things
are and how they ought to be [10]
- There are no doubt lots of other ways in which we might proceed than my
short list of suggestions. However, given the state of university education in
this country and the challenges facing the legal profession as lawyers try to
find a new vision of lawyering in an uncertain regulatory environment, who
better than clinical law teachers to set the example of the value of justice
in law.
[1] William Pincus, 'Lawyers' Professional Responsibility'
(1969)22 Journal of Legal Education, reprinted in Clinical Education for Law
Students: Essays by William Pincus CLEPR 1980, 37-68
[2] Margaret Davies Asking the Law Question LBC 1994, 2
[3] Access to Justice Advisory Committee, Access to Justice: An
Action Plan (1994)
[4] Ronald Sackville, Law and Poverty in Australia Second Main
Report of the Commission of Inquiry into Poverty, October 1975
[5] Access to Justice Advisory Committee, Access to Justice: An
Action Plan 1994 para 2.4
[6] Mary Anne Noone, 'Australian Community Legal Centres - The
University Connection' in Jeremy Cooper & Louise Trubek (eds) Educating
for Justice: Social Values and Legal Education Dartmouth Press 1997
[7] Carrie Menkel-Meadow, "Can a Law Teacher Avoid Teaching Legal
Ethics?" (1991) 41 Journal of Legal Education 3.
[8] M.A. Noone & J.A. Dickson, 'Teaching Towards a New
Professionalism: challenging law students to become ethical lawyers' (2001)
Legal Ethics
[9] At La Trobe University, the program 'Clinical Legal Education'
based at West Heidelberg Community Legal Service and taught by Liz Curran. See
also, for a US example, Elizabeth M. Schneider, 'Building Bridges between
Theory and Practice, Scholarship and Activism' (1992) 40 Cleveland State Law
Review 493
[10] Gary Blasi, 'Teaching/Lawyering as an Intellectual Project'
(1996) 14(1) Journal of Professional Legal Education 65,72
