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about many points of law. See "Comprehensive Guide to Bar
Admission Requirements 1996-97," American Bar Association,
pp. 32-33. The percentage of exam takers who pass varies
greatly from state to state, ranging in 1994 from a low of
56 percent in California to a high of 91 percent in Nebras-
ka. See The Lawyer's Almanac 1996, pp. 288-89. Passing
rates can vary substantially within a state from year to
year. On this point, Barbara A. Reeves of the Antitrust
Division of the U.S. Department of Justice commented, "It
belabors the obvious to point out that practicing lawyers
would benefit from restricted entry into practice in their
state. The fact that some form of examination may be neces-
sary to assure qualified lawyers does not explain the
strange fluctuations in the failure rates on some state bar
exams which occur from time to time." Barbara A. Reeves,
"UPL: The Lawyers' Monopoly under Attack," Florida Bar
Journal, November 1977, p. 609.
86. Spangenberg Group, "National Survey of the Civil Legal
Needs of the Poor," in "Two Nationwide Surveys: 1989 Pilot
Assessment of the Unmet Legal Needs of the Poor and of the
Public Generally," American Bar Association, May 1989,
p. 18.
87. Derek Bok, "A Flawed System of Law Practice and Train-
ing," Journal of Legal Education 33 (1983): 574.
88. Avrom Sherr and Simon Domberger, "The Impact of Compe-
tition on Pricing and Quality of Legal Services," Interna-
tional Review of Law and Economics 9 (1989): 55.
89. Jim Calle, "Bar Seeks to Protect Public with Non-Lawyer
Practice Rules," Arizona Attorney, March 1994, p. 10.
90. Deborah Rhode, "The Delivery of Legal Services by Non-
Lawyers," Georgetown Journal of Legal Ethics 4 (1990): 215.
91. Gardner v. Conway 48 N.W.2d 788, 795 (1951). In this
case, to entrap a tax preparer in a UPL violation, a local
bar association hired a private investigator to pose as a
taxpayer who had difficulty interpreting tax law.
92. Deborah Chalfie, "Dumping Discipline," Loyola Consumer
Law Reporter 4 (1991): 5.
93. Richard L. Abel, American Lawyers (New York: Oxford
University Press, 1989), p. 147.
94.
"Nonlawyer Activity in Law-Related Situations," Ameri-