At a March 1999 Colloquium on Clinical Legal Education, [1] a group of about 20 people, including a number of law faculty already teaching or planning to teach legal clinics in Central and Eastern Europe and the former Soviet Union, were asked, "What are the goals that you think are most important for a legal clinic?" [2] The most common answers were teaching about ethics and improving the ethical standards of law practice in participants' respective countries through this focus in legal education. Much of the two-hour session that followed concerned the following questions:
How are "legal ethics" different from "normal" ethics?
What are the problems of ethical norms among lawyers in the various
countries that one would seek to improve?
How would one effectively teach legal ethics in a clinic?
This article begins by outlining the framework of what the related concepts of legal ethics, professional responsibility, and the law regulating lawyers have come to mean in the United States. This framework is not presented because the substance of legal ethical rules in the United States are, or should be, the same as those in any other country. Instead the framework is offered as a starting point for consideration of topics on lawyer regulation and lawyer responsibility on which instruction usefully might be offered in law schools and legal clinics. The substance of the instruction on topics would be developed specific to the country in which the clinic functions. The first section's discussion of the three related concepts regarding lawyer conduct also addresses the Warsaw group's question about distinguishing role-defined "lawyers' ethics" from "normal ethics."
In 1997, Professor Lisa Lerman, and I taught a Comparative Legal Profession and Legal Ethics course to American and Polish law students in the summer program of The Catholic University of America conducted at Jagiellonian University in Cracow, Poland. Because the necessary materials were not already translated into English, nine teams, each comprising one Polish and one or two American students, worked together to find the Polish provisions on major aspects of professional responsibility law, to translate the pertinent materials into English, and to make a class presentation on the comparison of the Polish and the American rules on each topic. With the help of Dr. Fryderyk Zoll of Jagiellonian University, Polish students were able to identify and locate the pertinent materials. The list of topics outlined in this article was our starting point, and it proved effective for analysis of the law regulating lawyers in Poland.
As used in this article, "lawyers' ethics" encompass rules of conduct for all legal professions in a country. In the United States, lawyers are admitted to a single legal profession. [3] Poland, like many countries, has more than one legal profession with each profession having different functions. The Polish legal professions are advocate, legal counselor, prosecutor, and notary. As in other civil law countries, Polish law graduates also may enter training in the judicial profession after law school. did I leave anything out?
Each American state has a code of ethics applicable to all lawyers admitted to the bar of that state. Specialized tribunals, e.g., the United States Securities and Exchange Commission, have the authority to promulgate special rules for lawyers appearing before the body. The United States federal courts have the authority to prescribe their own codes of conduct for lawyers appearing before them just as they have the power to set their own admission standards. The federal courts, however, have chosen not to establish a federal bar exam and generally condition admission to practice before a federal court on admission to the bar of a state. [4] Similarly, the majority of federal district courts follow their local state ethics codes rather than promulgating their own standards. [5]
Each Polish profession has its own enabling legislation. Unlike the United States where the authority to regulate admission and conduct standards rests with the courts, [6] the authority for Polish legal professions rests in the legislature. Polish advocates, legal counselors, and notaries have developed internal codes of ethics. Is this a correct assessment? cite? As previously described, American state bar codes are promulgated by the courts, usually the highest court of the state in which they sit. Most are patterned on the American Bar Association (ABA) Model Rules of Professional Conduct. [7] The ABA is a voluntary, private organization to which American lawyers have no obligation to belong.
State codes of ethics generally are developed as a joint effort between the bar and lawyers. In most states, the highest court works with the state bar to establish committees of lawyers to review the ABA Models and make recommendations on what version of them should be adopted by the state. The court then reviews the work of such bodies, makes any changes it wishes, and promulgates the codes. Most state ethics codes are similar to the Model Rules, but no state is identical. In both the United States and in Poland, important rules regulating lawyers also are found in other bodies of law such as the civil procedure code and the evidentiary rules.
ABA accreditation standards for law schools have required instruction in professional responsibility since 1974. [8] Most law schools satisfy this requirement through a two or three-credit course in professional responsibility which means 30-42 class hours of instruction. [9] I have taught a three-credit classroom course in Professional Responsibility, to groups usually ranging from 55-70 students, since 1983. Some schools use clinical courses to satisfy the requirement. A few schools teach professional responsibility "pervasively," meaning they incorporate instruction into other courses in the curriculum.
All American clinics perceive a requirement to be concerned with professional responsibility issues. Clinics will vary in how much formal instruction is provided. One important determinant is how much instruction in the subject students have received elsewhere in the curriculum before they come to the clinic. Some clinics require a classroom course in professional responsibility to be taken previously or concurrently. I teach a seminar for students enrolled in clinical externships. In that course, some of my students have taken the required Professional Responsibility course, and some have not. I usually devote two of nine 90-minute sessions in the class to professional responsibility. [10]
To study codes of conduct, American classroom courses on legal ethics in the United States usually focus on the ABA Model Rules of Professional Conduct rather than state bar codes that actually govern lawyers. They focus on the "Model Rules" because most law graduates will go to a number of different states to take the bar examination and practice. The "Model Rules" are used as a common denominator for instruction just as the Uniform Commercial Code is used as the proxy for state codes in a commercial law class. This focus also prepares students for the Multistate Professional Responsibility Examination (MPRE), passage of which is required for admission to the bar of 47 states, the District of Columbia, and four U.S. territories. Because the MPRE is used in multiple states, it also focuses on the ABA Model Rules rather than particular state versions.
Professional responsibility textbooks and most classroom courses go beyond bar codes of ethics to encompass other important bodies of law that govern lawyer conduct, e.g., attorney-client privilege law, malpractice law. Beginning in 1999, the MPRE also will go beyond the ABA Model Rules to include these other aspects of the law governing lawyers. Just as with the Model Rules, some nuances and specifics of these areas of law vary from state to state, but students are taught basic principles that have considerable similarity across jurisdictions. In 1998, the prestigious American Law Institute approved the Final Draft of the Restatement of the Law Governing Lawyers, a comprehensive inventory on the subject.
An American law school clinical course more commonly will focus on the law of the particular state in which the clinic functions than on the general national models used in classroom courses, e.g., the state ethical code rather than the Model Rules, the attorney-client privilege law of the state rather than general concepts of privilege. The state ethical code is directly applicable to the American students' work. [11] For a clinic in a country where there are multiple legal professions, this article suggests that a clinical course focus on the legal rules that would apply to a legal practitioner doing the type of work in which the students are engaged. In a Polish clinic, students most often would function in roles analogous to those of advocates or legal counselors. There might be occasions, however, in which a clinical course also would wish to look at the ethical rules for professions with which the clinic interacts. For example, a clinic working with prisoners or criminal defendants in which the students were functioning similar to advocates might have reason to consider rules applicable to prosecutors and judges. [12]
The second section of this article asks why one would want to focus on legal ethics issues in legal clinics. This section argues first that clinics must offer instruction in professional responsibility to ensure student work conforms to professional standards. Second, it considers the ways that clinical instruction in professional responsibility could be useful to development of the practice standards of the profession in the country. Third, it discusses why the American experience suggests that one of the most effective ways to teach about professional responsibility is through a law school clinic.
The third section outlines steps a clinical teacher could take in developing instruction in legal ethics for clinical courses. The Appendix provides an inventory of questions for teachers to review to consider on which topics offering instruction in a clinic is necessary and desirable. [13]
I. What is encompassed in teaching professional responsibility?
In the United States, three terms are sometimes used interchangeably to describe a field of instruction for law students: legal ethics; professional responsibility; and the law governing (or regulating) lawyers. I accord the terms different meanings, but all three usages figure in the course titled Professional Responsibility that I have taught since 1983. The law governing lawyers refers to rules and doctrines concerning regulation of lawyers that exist in various bodies of law.
I see "professional responsibility" as a broader concept that implicates the multiple duties, responsibilities, and concerns of a lawyer-to a client, to the courts, to justice being done, to access to justice, to the public perception of the legal profession, to fellow lawyers, to parties and witnesses the lawyer encounters. Much of American rules of conduct for lawyers focus on how these responsibilities should be balanced when they tilt in differing directions as to what a lawyer should do in a particular circumstance.
"Legal ethics" properly describes professional codes of conduct developed for lawyers. As described later, I believe use of the term for the field of study about proper lawyer conduct, on the one hand, defines what students should study too narrowly. On the other hand, the term sometimes is used too broadly and confuses proper conduct in the role of lawyer with other conceptions of ethics.
A. The Law Governing Lawyers
I use the "law governing lawyers" or the "law regulating lawyers" as a foundation for all discussion in the class. This term refers to substantive rules governing lawyers, analysis of the authority under which such legal rules are created, and the mechanism by which norms are enforced. The initial question on any topic in professional responsibility is for me: What is the legal rule, and where is it found?
As described in Section Three on steps in organizing professional responsibility instruction, it also is important to consider how seriously various subparts of these rules are taken and where they present problems for lawyers. In what types of proceedings do various parts of the law come up? What are the consequences for violating different aspects of the law? Consider the American law of conflicts of interest as an example. Model Rules 1.7-1.11 and their state counterparts set out rules on conflict of interest. Conflicts of interest encompass how a lawyer's obligations to a client regarding confidentiality and undivided loyalty should be protected when there are conflicts among current clients of the lawyer, among potential clients and current clients, among potential clients and past clients, between a lawyer's personal interest and a client's interest, and between a lawyer's past role for the government and current or potential clients.
It is rare that conflict of interest allegations are the subject of disciplinary proceedings against lawyers. They, however, frequently are the subject of disqualification motions that have the potential consequence of forcing a lawyer to give up a client. Such disqualification can occur far into a representation when there are potentially serious financial consequences for lawyer and client. Accepting a conflicted representation also can be the basis of a suit against the lawyer for malpractice or breach of fiduciary duty. Hence, most large law firms, where many questions of potential conflict arise, designate a partner to be responsible for reviewing representations for conflicts, and there is considerable concern in this regard. Thus, although conflicts of interest problems are rarely the subject of bar discipline against American lawyers, the substantive rules are very important and have considerable potential consequence for lawyers.
In some instances, the "rule" in the law of professional responsibility is only an aspirational standard. Model Rule 6.1 says that a lawyer "should aspire to render at least (50) hours of pro bono publico legal services per year." (The parentheses indicate that states may choose to insert a different figure.) A number of bars have adopted civility standards that are not binding in discipline but provide standards on how lawyers should behave in a number of day-to-day matters. In other instances, legal rules provide guidance but provide that lawyers have discretion to act within stated bounds. Model Rule 1.6 says a lawyer "may reveal" confidential information of a client "to the extent the lawyer reasonably believes necessary: (1) to prevent the client from committing a criminal act that the lawyer believes is likely to result in imminent death or substantial bodily harm." Most states find this protection of confidentiality to tilt too far toward client protection as weighed against other concerns. Some states shift the "may" to a "shall" to require revelation of information for crimes that would result in serious physical harm. Other states add additional circumstances when the lawyer has discretion to reveal. [14]
In yet other instances, the Rules impose a mandatory duty although judgment usually is necessary to determine when the duty applies. Model Rule 8.3 requires that a lawyer "shall inform the appropriate professional authority" when the lawyer has "knowledge that another lawyer has committed a violation of the Rules of Professional Conduct that raises a substantial question as to that lawyer's honesty, trustworthiness or fitness as a lawyer ..." Although this is a mandatory duty, judgment still must be exercised to determine if the duty is invoked. In this case, the lawyer is required to report only if he has sufficient knowledge, the knowledge is of a violation of the Rules, and the violation raises the type of question specified.
Much important law governing lawyers is found outside state codes of conduct (which students study through the surrogate Model Rules). Again, consider the example of conflicts of interest. Model Rules 1.7-1.11 concern conflicts of interest, but many reported cases have resulted from rulings on disqualification motions and claims for malpractice or breach of fiduciary duty. The evidentiary law of attorney-client privilege is a very important body of law regulating lawyers, that lies alongside provisions of the ethical code on protection of client confidences.
B. Professional Responsibility
From the foundation in the "law governing lawyers," I see "professional responsibility" as a broader concept based in and emerging from the foundation of legal rules. For me, "professional responsibility" encompasses the notion of dealing not only with responsibility to client but also with reconciling responsibility to client with responsibilities to the court, to fellow lawyers, and to other parties in day-to-day dealings. In addition, the term implicates responsibility to the profession and the justice system. Public confidence in lawyers affects the confidence that people in the society have in the system of justice. The term "professional responsibility" implicates the philosophy underlying the legal rules and the constructs that the legal rules add up to form. American lawyers are instructed they are part of a "public profession," and that they are officers of the court. American law governing lawyers reflects a strong loyalty to the client, but there is constant debate about how loyalty to client should be balanced with responsibility to the court and respect for the rights of those who have disputes with one's client. A court's right to appoint lawyers to represent clients, even with inadequate or no compensation, has been upheld. One justification is that such responsibilities must flow from the lawyers' monopoly on access to justice.
C. Legal Ethics
Some law school courses are called Legal Ethics, our third term. The term also often is used to describe desirable professional conduct in the profession. For example, the body that advises lawyers on interpretation of the District of Columbia Rules of Professional Conduct is called the Legal Ethics Committee. [15]
I prefer to call a law school course "Professional Responsibility," rather than "Legal Ethics," for several reasons. The term "legal ethics" is properly used to describe the profession's ethical code, but such codes are only a part of the domain of the law governing lawyers. Definition of the subject matter as "legal ethics" may encourage students and others to conceive the domain of lawyer regulation too narrowly. Second, "ethics" commonly is used to describe people's personal codes of conduct, general ideas of right conduct, and notions of the morality flowing from philosophical and religious traditions. The word ethics for many people conjures this usage, and they do not differentiate it from the usage for ethics of a profession flowing from the role of the professional. Indeed, the difficulty in differentiating can become normative-if there are a "lawyers' ethics" that are different from "normal ethics," they must be bad. Hence we hear jokes like: "Lawyers' Ethics--the world's shortest book."
The Encyclopedia of Philosophy speaks of ethics as having three different but related meanings: "(1) a general pattern or 'way of life,' (2) a set of rules of conduct or 'moral code,' (3) inquiry about ways of life and rules of conduct." [16] As to the second definition, the Encyclopedia says we "speak of professional ethics and of unethical behavior." The Encyclopedic Dictionary of Religion defines ethics as referring to (1) "a code of conduct regulating a profession" or (2) "moral philosophy, the meaning of which has varied nearly infinitely in the course of history." [17] Within these definitions, it is appropriate to refer to a lawyer's code of conduct as "lawyers' ethics." The Encyclopedia of Philosophy's definition includes both role-defined professional codes and individual moral codes in its second option. Ethics as more general senses of morality also are implicated in the first definition that includes a usage like "Christian ethics."
In my course, I think of legal ethics as the third meaning from the Encyclopedia of Philosophy-inquiry about what lawyers should do. I encourage my students to consider the law governing lawyers and concepts of professional responsibility against their own "normal ethics" and ethical constructs from philosophy and religion. They must understand, however, that the codification of lawyers' ethics flowing from the role of lawyer may conflict with notions of ethics rooted in other premises.
As previously mentioned, American codes of conduct have become increasingly specific as they attempt to balance the conflicting directions among loyalty to client and obligations to the court or others. The 1969 ABA Model Code provides more detail than the 1908 Canons of Ethics. The 1983 Model Rules are more specific than the Code and some subsequent amendments have been in the direction of greater specificity. [18] The Rules of Conduct for the District of Columbia, the third largest bar in the United States with more than 70,000 members, are, in some respects, considerably more specific than the Model Rules.
I have reviewed several draft codes of conduct for the ABA Central and Eastern European Legal Initiative. Those I have reviewed typically articulate many laudable principles, but they usually do not provide much specific guidance on how those principles should be applied in practice situations, particularly when the principles might conflict with one another in application. The following example comes from a draft Rules of Professional Conduct for a Central European country that I reviewed. I have not identified the country. Rule 1 was translated as saying, "The role of a counsel is to assist in protecting rights and legal interests of physical and legal persons." Rule 2 provides: "When performing his/her professional duty in justice and other government, public and commercial institutions, he/she shall protect the interests of a client and the community and ensure enforcement of legal norms." Rule 4 introduces yet another interest for concern: "The counsel's duty is to protect his/her professional dignity. The professional dignity disgracing conduct is considered to be the one that makes the community to loose [sic] its reliance on the BAR and brings disgrace to a counsel's name." Rule 6 bans advertising, solicitation of clients or seeking "clients by ways, which violate friendly relations with his/her colleagues or hurt their dignity." The draft Rules acknowledge these appropriate concerns but provide little in specific guidance about how the obligations to clients, the community, law enforcement, protection of professional dignity, and relations to colleagues should be balanced when they conflict in practice.
The preceding section of the article addresses the question of our small group of law teachers in Warsaw: "How is legal ethics different from 'normal ethics'?" Much of a law school professional responsibility course concerns situations where "normal" ethical precepts conflict with each other. For example, it is a "normal" ethical norm to keep the secrets of people who confide in us. Lawyers have even a higher standard for confidentiality of their clients. But when there are dangers to other people (at least dangers of death or serious bodily harm) or possibilities of corruption of the justice system, "lawyers ethics" draw lines regarding when the ethical norm of confidentiality of client information should be overridden." [19] Lawyers' ethics concern how "normal" ethical rules should be applied to someone acting in the role as a lawyer given the function of that role in a legal system. Definition of proper conduct within that role often requires drawing of lines that balance competing ethical principles. Thus, I consider "professional responsibility" to be a better term for describing the required classroom course that I teach.
I also fear students being misled by the term "legal ethics" because much of what I teach is about lawyer self-protection. By this, I do not mean protection of lawyers from discipline or public scrutiny. I mean educating students to realize that loyalty to client has limits imposed by the law. Things that a lawyer might be tempted to do to help a person in need and things that a client might push a lawyer to do may cross those bounds and subject a lawyer to peril of the lawyer's license or worse.
A lawyer in the District of Columbia retired from the government to start a private practice. He took on many needy clients referred to him by his church and charged them nothing. One such client was a Pakistani woman who had fled an abusive husband and whom he helped to become a resident alien. When it was time for her to travel back to Pakistan for the official change of her immigration status, she panicked. She feared a bureaucratic obstacle could be raised to her returning to the United States, and she begged the lawyer to help her get an U.S. passport. Upon her entreaties, the lawyer assisted the client in obtaining an U.S. passport by signing a false statement indicating that the client was someone else whose passport birth certificate she had borrowed. For violation of the federal criminal statute involved, the lawyer was sentenced to 100 hours of community service with the sentencing magistrate saying he "let his heart carry his head." Because of the conduct resulting in this criminal conviction, the lawyer was disbarred in 1989. [20] After five years of appeals and rehearing, the lawyer's penalty finally was reduced to a one-year suspension effective in 1989, [21] but by that time, he had been out of practice for five years.
Another professional responsibility teacher makes the point with the story of a lawyer disbarred in Colorado for helping a client to flee the jurisdiction with her child in violation of a court order. "The client testified that 'the [lawyer] advised her as her attorney to stay, but as a mother to run.' After assisting the client in emptying bank accounts and placing her belongings in storage, the lawyer represented to the court that the child remained in the jurisdiction. She accepted an offer from the husband to continue child support payments even though the court had granted him custody of the child. The client later pleaded guilty to a felony charge for having violated the court order. The court held that the lawyer 'used her license to violate the core ethical and professional standards of her profession.'" [22]
Students should be prepared for practice with a thorough grounding of the legal rules governing lawyers and the consequences that can flow from violating them. They must consider that their personal instincts as to right and wrong may differ from legal rules on what lawyers are to do in particular circumstances. They must understand that a decision to follow a personal moral code, which counters the expectations regarding lawyer behavior, can have severe consequences. Both of these examples can prompt a rich class discussion on a lawyer's choices when he fears the law may not adequately protect people that he strongly believes should be protected.
The following section of the article describes the organization of the classroom course that I teach, which involves 42 class hours of instruction. All of my law school's students are required to take such a course. For students who take a clinic, ethical instruction offered in the clinical course is an addition to this required classroom course, but many students take a clinic before they take the required course. The following section describes the topics covered in the course. Students receive an outline of the topics encompassed in the subject with assignments for each. This includes some topics shown with a strikeover for material that I do not have time to cover in the fifteen weeks of my course. Students then can see that these topics are within the domain of the subject. As an Appendix to this article, I have turned the topics from my outline into questions that law teachers in other countries might consider to assess the law regulating lawyers for the country and to decide the topics to be included in clinical course instruction.
At the first class, I ask my students what they believe the public thinks about lawyers and what being a "professional" means. We then move to identification of the bodies of law governing lawyer conduct and where the authority for each body lies. We look at admission to the bar and the bar disciplinary process that ultimately can lead to losing one's license to practice law as well as to less serious sanctions including suspension from practice for a period of time, probation, monitored practice, a public reprimand, a private reprimand, or an informal admonition.
We briefly consider causes of action for civil damages against lawyers for the benefit of clients or other people who are found to have been aggrieved by lawyers. [23] We acknowledge the body of law that most often speaks to standards of conduct for lawyers in criminal cases: claims for relief based on ineffective assistance of counsel. [24]
We then leave this introductory framework on bodies of law governing lawyers, potential penalties for various types of misconduct, and the source of authority to make and enforce such laws and turn to the fundamental obligations of lawyer to client. I describe those fundamental duties as:
We also consider a lawyer's freedom to accept and reject clients and, once a client has been accepted, the circumstances in which a lawyer is permitted to terminate representation. With this section on obligations of lawyer to client, we start to concentrate on the standards found in the ABA Model Rules of Professional Conduct. The order of topics roughly corresponds to the organization of the Model Rules.
From the starting point of duties to client, we move to "the bounds of advocacy"--the lines that a lawyer may not cross in representing a client. This encompasses subjects including:
We also look at ways that standards for prosecutors differ from those of criminal defense attorneys and how some rules differ in criminal defense as opposed to civil representation.
The next section concerns issues that arise primarily in seeking to make a private law practice profitable and with respect to organization and management of a law firm. This includes rules on:
The final section of the course concerns special issues that arise in representing an entity client rather than an individual, e.g., representing a corporation or the government. This raises special issues on matters such as confidentiality and conflicts of interest.
Many courses devote some time to the Code of Judicial Conduct. I do not take the time to do this in our 42 class hours of instruction. I close the course by returning to the questions with which I began:
As previously mentioned, law school accreditation standards require instruction in professional responsibility. This requirement has spurred a considerable development in materials. Recently, I counted 38 textbooks and treatises on my bookshelf. Textbooks normally are supplemented with another book including the original text of the ABA Model Rules of Professional Conduct and other original sources of relevant rules. In the sixteen years I have been teaching the course, the number of texts, as well as the number of scholarly articles and books on the subject, has increased dramatically.
In the United States, professional responsibility teachers debate whether the primary goal should be to teach the body of law governing lawyers or to engage students in moral dialogue. [27] Teachers also debate breadth vs. depth: Should one cover the broad range of subjects in lawyer regulation or focus on discussion of a smaller number of problems and concentrate on the mode of ethical decision-making employed? I believe teachers are most successful at teaching what they believe to be important. Different clinical teachers likely will decide on different emphases in their courses. Regardless of the emphasis that a teacher ultimately chooses, assessment of the rules about lawyers and their enforcement is an important first step. When American teachers debate where emphasis in a course should lie, that debate rests on a common understanding of the domain of the field. That common understanding of the field of professional responsibility is a relatively new phenomenon, having developed primarily since the early 1970s. [28]
In addition to an inventory of the existing rules for lawyers in their country, teachers also need a sense of whether rules are enforced, if so where, and to what consequence. If some rules of conduct exist but are ignored, teachers and students may consider why. Once the teacher has an idea of the domain of the law regulating lawyers in the country and the state of its enforcement, the clinical teacher can make choices about what the teacher believes must be taught for the good of the clinic and its clients with regard to what the students are doing now. The teacher then can go on to consider what else should be taught for the education of the students and to further the dialogue about desirable standards for lawyers' ethics for the country. Like American teachers, teachers in the region probably would vary in their choice between breadth focusing on the range of law regulating lawyer and depth focusing on moral inquiry about particular problems. I believe, however, that all approaches should start from a platform of knowledge about the existing state of lawyer regulation.
II. Why teach professional responsibility in the clinic?
The previous section considers the domain of what might be meant by the law regulating lawyers, lawyers' professional responsibility, and legal ethics. It outlined the scope of material I seek to cover in a 42 class hour course on the subject. The following section argues why instruction in professional responsibility in a clinic is both necessary and desirable.
First, if students are providing legal service to clients, one must assure that appropriate professional standards are being observed. One concern is avoidance of liability for violation of disciplinary standards and malpractice. In American clinics, students often are given a form of special admission to practice and thus explicitly made responsible for lawyer standards of conduct. [29] Even without that "hook," students are performing lawyering tasks under the supervision of a licensed attorney. The clinic must be concerned that everything done in the supervising lawyer's name meets professional standards because an American supervisory lawyer is responsible in discipline for things done by non-lawyers acting as the lawyer's agent. The responsible lawyer and clinic also must be concerned with civil liability for malpractice or other civil remedies for violation of lawyer conduct standards. Of course, beyond these questions of liability in lawyer discipline or civil liability, clinical practitioners would want to observe high standards of lawyer conduct because it is the proper thing to do for clients and the appropriate behavior to model in an educational institution.
Second, our Warsaw group seemed to believe that consideration of ethical standards and modeling them in practice in a clinic could have a salutary effect on the practice standards in a country. I advocate planning clinical instruction by assembling the laws regulating lawyers that exist on paper whether they are enforced or not. By that I mean the statute establishing a legal profession, any code of conduct that exists, and rules of law in other bodies, e.g., evidentiary rules on confidentiality, civil remedies for clients who are wronged by lawyers.
Countries likely will vary on how specifically developed such codes of conduct and other rules of law are. Poland has well-developed law on most issues of lawyer conduct previously described although the topics have not been gathered into one comprehensive text. The advocates recently revised their code of conduct. The clinics of Warsaw University and Jagiellonian University used this new code as a draft code of conduct for clinic students. In Poland, a tort for legal malpractice similar to that in the United States exists, although cases apparently are rarely, if ever, brought. Poland has rules similar to American attorney-client confidentiality standards in their evidentiary, civil, and criminal codes.
University clinics' compilations of a country's rules of lawyer conduct, as described in the next section, could provide useful materials for education of legal apprentices and in continuing education for lawyers. [30] Compiling materials on the standards for lawyers within the university could encourage professors and students to look critically at the law governing lawyers in the country and the concepts of professional responsibility and legal ethics that it reflects. Thirty years ago there was very little academic literature in the United States on these topics. Today scholarship abounds. Scholarly focus on rules for lawyer conduct and actual lawyer conduct can be a valuable contribution growing from the clinic's work.
A third reason to teach about legal ethics in clinical courses is that it is such an effective place to do so. [31] Ethical issues inevitably arise in providing legal service. Just as the experiential education in clinics is effective for teaching skills in practice and about legal doctrine, concrete application is useful in motivating students to consider ethical questions and cement their learning about them. American law teachers often express frustration about how best to motivate students in a required classroom course. [32] Problems arise from resistance to what is in many law schools the only course required after the first year. Many students seem to have difficulty realizing how commonly ethical issues come up in practice. In the clinic, students with training in the issues and supervisors alert to recognizing them see that ethical issues come up all the time.
Furthermore, ethical issues in the clinic arise in context. This helps students and teachers see that many ethical dilemmas do not have simple, bright-line answers. Judgment must be exercised in recognition of the competing principles at stake. [33] One can teach the rules of professional conduct in a classroom course, but it is difficult in a lecture, a written problem, or even in a simulation to provide the complex context of how ethical problems arise in practice. The complexity of practice motivates students to realize both the importance of understanding professional responsibility law and the nature of the decision-making that must be used in applying it.
III. How would one teach professional responsibility in the clinic?
First, as previously described, I would identify the sources of law on basic topics in the law governing lawyers for the jurisdiction in which the clinic functions. The inventory of topics from my course in the preceding section and the more detailed Appendix that follows offer a starting point for considering the domain of issues within the field. When there are multiple legal professions, focus on rules applicable to the legal profession(s) to which the students' work is most analogous. It likely, however, also will be useful to gather the rules for the other legal professions. In some instances, it will be important to talk about the rules of a profession with which the students interact, e.g., prosecutors or judges. It also may be useful to compare the way rules differ among professions as a way of understanding the rules and looking at them critically.
If materials have not been compiled, students could be assigned responsibility to research and compile the material. As suggested in the next point, priority should go to the topics most likely to come up in the work of the clinic. Collection of rules on paper also needs to be tempered with an assessment of whether the rules are enforced in practice, by whom, and what consequences flow from violation.
Second, consider which of the topics are most central to the work of the clinic. For example, I assume that rules on confidentiality and avoidance of conflicts of interest would be fundamental in any clinic. Some topics taught in a comprehensive classroom course for students going into all types of legal practice might not be relevant to clinics or come up only occasionally. For example, most clinics offer free legal services so rules on setting fees likely would not arise. The Appendix offers a starting point to consider on what topics a clinic should concentrate. A teacher can read through the questions in the Appendix and note those that seem of highest priority to the work of the clinic or matters the teacher believes most strongly should be raised with students.
Third, assemble the citations or text of the legal rules on the topics of that the teacher believes should have priority. Provide them in manual form to students at the outset or in increments as particular topics are studied.
Probably most important is a fourth step: the clinical teacher's recognition and raising of ethical issues as they arise in clinic work. As one would with questions of substantive law or procedure, students can be directed to research the topic, report conclusions, or perhaps write a short analysis of the problem-if the issue is recognized. The student can benefit not only from such research but also from dialogue with the teacher on the subject and discussion among peers. American clinical teachers sometimes refer to the "teachable moment"--the point where a point simply "comes up" in the day-to-day work of the clinic and provides a concrete context and motivating moment to engage the student in learning. Such moments to discuss professional responsibility issues may arise in one-on-one supervision of the student or in case rounds with the class group.
The teacher may decide some topics are so fundamental that readings should be assigned, students should be assigned to make oral or written reports for the class, hypothetical problems should be prepared for discussion, ethical issues should be raised in a simulation, and so on. Likely over time, real situations have arisen in clinic practice that can be the basis for teaching materials.
Practicing lawyers might be asked to come in and talk with students about their view of problems that commonly arise and their answers to the types of ethical issues that arise in clinic cases. The Jagiellonian clinic employs practicing lawyers who work jointly with the professors responsible for the course. These practitioners often comment on ethical questions. Such dialogue with practitioners can increase teacher and student knowledge on what "really happens" regarding lawyer rules. The Jagiellonian clinic also has had the president of the Advocates' Association Cracow speak with the students.
The Civil Law Clinic at Jagiellonian University has incorporated instruction in Professional Responsibility. Let me give two examples of professional responsibility issues that arose in clinic cases-one relatively simple and another requiring more complex analysis. A woman came to the clinic to ask for some advice about rights to an inheritance of some property. Questioning revealed that it actually was her father who was the heir, but he was not interested in seeking legal advice. This provided an opportunity for the clinic supervisor to engage students on issues regarding the contact and consent necessary to form a client relationship and conflicts of interest.
More complex considerations arose in one of the cases in which the clinic is appointed as a guardian for an absent person. A woman was seeking to raise the support order for her children against her absent former husband. The funds for the children were coming from the government since the husband was absent, but the law requires a support action to be filed against a legally responsible parent. The state retains a right to seek reimbursement for funds paid to the children from the parent against whom there is a support order if he is later found.
The student acting as a guardian opposed the increase in support order saying that, since the husband was absent, the court had no way to determine what would be an appropriate support order based on what he could afford to pay. The court entered an increased support order at a figure lower than the former wife had requested but higher than the current order.
The clinic student did not want to appeal the support order because she thought it was fair, and the father should pay for his children. The clinic supervisor raised the duty to represent the client vigorously. The Polish advocates' code of ethics includes the rule that an advocate must have the permission of a client to appeal. Supervisor and student considered how this principle should apply when the person cannot be found, and the student is functioning as a guardian for his interest. They had to consider whether the proper analogy was advocate to client in this guardianship situation.
Their discussion went on to consider that the appeal not only could result in a lower award for the client but also could result in a higher award as requested by the former wife since she had the right to cross-appeal. It's probably a good idea to include what you actually did. I didn't get that clearly from Fryderyk. You may want to footnote the advocate's rule or any additional explanation of any of this that you think important. Just as in an American clinic, this scenario offers no easy, bright-line answer. The "law governing lawyers" on the point offers some useful information, but determination of whether and how it should apply is not a simple one. This example sounds very similar to the Luban and Millemann's account their clinic's consideration of ethical issues that arose at the University of Maryland. [34]
Clinical teachers at Jagiellonian University and Warsaw University have initiated a very useful cooperative project. Joint consideration has been given to issues of professional responsibility topics most likely to be of concern for students in their day-to-day work. Working from the Advocate's __________, a draft code of conduct for legal clinics was developed by ____________. _________ produced a draft law on student legal clinics addressing such issues as protection of client confidentiality since the Polish equivalent of the attorney-client privilege does not cover communications to clinic students. I want to be sure I am giving appropriate credit to those who deserve it.
Conclusion
Some people mistakenly characterize clinical education as "practical" as opposed to "theoretical." Learning from practice entails forming analytical constructs--theory--to be tested in the world. Clinical education is more appropriately termed "theory about practice" rather than practice versus theory.
The law regulating lawyers, professional responsibility, and legal ethics are subjects important to the welfare of clients, lawyers, and the legal system in any country. The substance of the law governing lawyers that should apply to lawyers appropriately will vary among countries, but the topics on which rules will and should exist likely are similar across legal cultures. This article offers a framework and mode of analysis on topics that could be considered for instruction on lawyers' professional responsibility in law clinics around the world. It also provides suggestions for how clinical teachers might go about organizing instruction in the field for their students.
Clinics must offer instruction in their country's professional responsibility standards to assure that the work of the clinic meets the standards for lawyers doing similar work. If for no other reason, this would be appropriate from a concern for liability. Of course, however, the concern is loftier than that. Clinics seek to provide high quality service, and as educational institutions, they want the habits learned to be model ones that students should carry forward into life after the university.
Teaching materials on lawyers' professional responsibility that are prepared in clinics may be useful for instruction for legal apprentices or in continuing legal education for practitioners. Further, professors and students, by their nature, will look at the law governing lawyers, professional responsibility standards, and legal ethics in a country from a theoretical and critical perspective. Such inquiry by faculty and students can lead to scholarship and interchange with the legal profession(s) regarding what the law governing lawyers, professional standards, and legal ethics for the lawyers of the country should be.
APPENDIX
The following is organized around the eight units of my 42 class hours in Professional Responsibility. The eight units do not receive equal time. Indeed, coverage of the first four units takes more than three-fourths of the semester.
For my students, these unit headings are followed with an outline of topics and assignments for each. Some topics appear with a strikeover showing that the topic is properly a part of that unit, but we will not have time to reach the topic in class.
This appendix is meant to allow a teacher in another country to contemplate what questions of law regulating lawyers, professional responsibility, and legal ethics should be included in the curriculum of a clinic course. My assumption is that a teacher would begin by choosing the questions on which the teacher thinks that students should have information about the legal rules within the country and on which clinic discussion should be focused. The teacher then would assemble, or have the students assemble, the law regulating lawyers on that question from all pertinent sources in the country's law. Once this has been done for a country, the results can be shared among teachers and clinics.
Attempting to apply the questions below to a particular country may reveal that the questions must be reframed or that different questions should be asked. Analysis of why a question is not apt and what questions should be asked instead still may be useful in stimulating thought about the framework of the law regulating lawyers and concepts of professional responsibility and legal ethics in a country.
In the United States, some courses combine a 30 to 42 class hours of instruction in a classroom course with a clinic course with time set aside in the clinic for discussion of ethical issues that arise. That framework would be needed to address even most of the questions on the list below. For a clinic without extra classroom time, the list of questions must be pared down considerably from those listed below. The teacher would need to set priorities on those most crucial to the clinic's work, and those that the teacher thinks most important to raise as part of the education of future lawyers.
These questions generally are framed as: What is the law on ____? This also implies additional questions. Where is the law found? Is the law enforced? Who would bring a claim for violation, and where would that claim be considered? What are the penalties if a violation is found?
UNIT ONE:
FRAMEWORK FOR REGULATION OF THE LEGAL PROFESSION
UNIT TWO:
FUNDAMENTAL OBLIGATIONS OF LAWYER TO CLIENT
UNIT THREE:
CONFLICTS OF INTEREST
UNIT FOUR:
WHERE DUTY TO CLIENT IS BOUNDED
UNIT FIVE:
THE BUSINESS OF LAW PRACTICE
UNIT SIX:
AVAILABILITY OF LEGAL SERVICE TO ALL PEOPLE
UNIT SEVEN:
THE ENTITY CLIENT & RULES FOR THE JUDICIARY
UNIT EIGHT:
THE LEGAL PROFESSION--THE PUBLIC'S PERCEPTION; OUR PERCEPTION; OUR
RESPONSIBILITIES
ADDITIONAL ISSUES SPECIFIC TO THE CLINIC
* Leah Wortham is an Associate Professor of Law at the Columbus School of Law of The Catholic University of America (CUA), Washington, D.C where she has been on the faculty since 1981. Professor Wortham has taught the required course in Professional Responsibility since 1983. She was the coordinator of CUA's clinical programs for nine years and an Associate Dean for five years. Since 1995, she has assisted faculty at Jagiellonian University in Cracow, Poland, in their establishment of a legal clinic. She served on the Legal Ethics Committee of the District of Columbia Bar for six years including as Chair and Vice-Chair. The Committee issues opinions interpreting the D.C. Rules of Professional Conduct as well as advising lawyers on what the Rules provide. Professor Wortham authors an annually updated comparison of the D.C. and American Bar Association Model Rules of Professional Conduct, which is distributed to all new admittees to the D.C. Bar. She teaches this comparison in a mandatory course for new admittees to the D.C. Bar and in a continuing legal education course for lawyers. Professor Wortham also is a hearing committee member for the D.C. Board of Professional Responsibility, which administers lawyer discipline. The author would like to thank Lukasz Bojarski, Lisa Lerman, William Wagner, and Fryderyk Zoll for their comments and assistance.
NOTES: