Oklahoma Bar Journal
1) the way legal education is conducted that “changes” the way a student thinks,
2) the adversarial nature of the practice and
3) the misalignment of a lawyer’s personal values with their professional duties.
The unhappiness, the research shows, starts in law school. Undergraduates who choose to study law are not that different from other undergraduates, but the unique law school experience promotes changes in the personality and world view of law students, which have been identified as compatible with depression. Lawyers, because of the nature of the job, are realistic pessimists, perfectionistic and competitive, the same personality traits that signal a tendency toward depression. In addition, particularly in the early years of practicing law with the crushing billing requirements and student loans, many young lawyers rely on substances to make their experience tolerable. This coping mechanism has the opposite effect – the more addicted a lawyer becomes to drugs or alcohol, the harder it is for the lawyer to competently represent clients, which in turn increases addictive activity. So, what exactly is the problem, and how can lawyers, law schools and legal employers ameliorate the mental health crisis in the legal profession?
THE ‘LAWYER PERSONALITY’
Myers-Briggs Type Inventory
Despite popular opinion, no two lawyers are the same. Still, research has shown there is a “lawyer personality.” Researchers have used the Myers-Briggs Type Inventory (MBTI) in an attempt to quantify why lawyers are “the way they are.” Studies have been performed on students before and after entering law school to determine if law school changes personalities. Law students have been tracked into practice to determine whether the changes in personality that occur in law school are permanent.
The MBTI characterizes personality, and there are four basic personality traits that can be arranged into 16 personality types. The four basic traits are:
- Extroversion (E) or Introversion (I): Do you prefer to focus on the outer world or your own inner world? Do events where you interact with many people energize you or wear you out?
- Sensing (S) or Intuition (I): Do you prefer to focus on the basic information youtake in, or do you prefer to interpret and add meaning?
- Thinking (T) or Feeling (F):
When deciding, do you prefer to look at logic and consistency, or do you prefer to first look at the people and special circumstances?
- Judging (J) and Perceiving (P): In dealing with the outside world, do you prefer to reach a firm decision, or do you prefer to stay open to new information and options?1
So, for example, if you are a person who was extroverted, preferred to focus on basic information, are more likely to consider special circumstances when deciding and wanted concrete answers, your personality type would be an ESFJ.
Not all lawyers are the same personality type, and students entering law school are not much different from other undergraduates, but by the time they graduate from law school, students are highly concentrated in some of the personality indicators. In general, lawyers are thinkers who prefer to interpret information rather than rely on basic facts. Lawyers also prefer not to have loose ends – they prefer decisions.
The most common personality type among lawyers is INTJ, which is defined by the MBTI as people who:
- Have original minds and great drive for implementing their ideas and achieving their goals.
- Quickly see patterns in external events and develop long-range explanatory perspectives.
- When committed, organize a job and carry it through.
- Skeptical and independent, have high standards of competency and performance – for themselves and others.2
Of all the elements, lawyers are overwhelmingly concentrated in the “thinking” characteristic. It appears, however, this personality is not ingrained before law school, and something about legal education changes students and even changes parts of their personalities. The research shows that students are profoundly changed through their law school experience.
Several studies bear this out. In 1967, more than 50 years ago, Paul Miller studied law students to discover whether personality was related to law school dropout rates. This study did not include women because so few were enrolled. At the four law schools where Miller did his research, he found that law students had distinctively different personalities from general college students, with a marked preference for “thinking” over “feeling.” Seventy-two percent of law students preferred “thinking” over “feeling,” while 54% of law school dropouts did. In fact, having a “feeling” bent that is not changed by legal education was the only consistent predictor of law school attrition – the dropout rate was unrelated to undergraduate grade point average or LSAT score. Another study around the same time (1967 and 1968) showed that lower-ranking law students had higher “humanitarian” scores.3
These results were replicated in an unpublished 1994 study by Lawrence Richard,4 who described the differences between people with a thinking as opposed to a feeling orientation. Although students entering law school tend toward introversion, this tendency becomes much more pronounced after legal education. Curiously, though, law school also makes students much less philosophical and interested in abstractions, ideas and the scientific method, training their personality toward practical pursuits.5 It appears the trend toward pessimism and thinking is exacerbated in law school – and not that pessimistic people tend to choose the law.6
One of the significant findings of the Richard research is that it replicated the 1967 results by Miller, even though it included women, indicating that introducing women into the profession has not changed the profession. A 1990 study found 77.9% of law students preferred a thinking style, including women, 65% of whom, in the general population, prefer feeling to thinking.7 It also appears that law school changes women more than men. A Pennsylvania State University study found that women’s basic attitudes changed significantly during law school. In the first year, men and women reported very different attitudes about justice, the practice of law and society. First-year female law students were much more critical than men of the status quo, legal education and themselves as students. By the third year, the differences between the sexes were remarkably small. Third-year female law students were less critical than their third-year male colleagues and far less critical than their first-year female counterparts. A disproportionate number of the women who were studied entered law school with commitments to public interest law, ready to fight for social justice, but their third-year female counterparts left law school with corporate ambitions and some indications of mental health distress. Further, although women entered law school with a decided bent for an ethic of care, they left law school having shifted to a “rights” orientation.8 It may be that “feeling” is incompatible with not only law school but the practice of law itself. A 1992 study found that those with a “feeling” preference were most likely to be disenchanted with the practice of law.9
The general public has a perception that lawyers are different from everyone else in basic ways, particularly in levels of honesty and integrity, the way they think and their ability to relate to or care about others.10 While lawyers definitely have more of a “thinking” bent, so do other occupations, including engineers and physicians. However, the practice of law itself informs public perception and contributes to lawyer distress. It appears law school erodes students’ intrinsic values and systematically marginalizes emotions, morality and social context as important components in decision making. Power and materialistic values, however, are not systematically devalued by “learning to think like a lawyer.”11
Lawyers deal with tough conflicts. Trial lawyers are called in when ordinary methods of resolving differences have failed. Transactional lawyers must anticipate and plan for how to avoid or address such conflicts in advance. “If there were even a somewhat obvious win-win resolution, it would have been reached prior to reaching the attorneys.”12 In addition lawyers participate in a largely zero-sum game, where somebody wins and somebody loses and the adversarial skills of lawyers are “negative” communications and are often hostile.
Lawyers are required to perform “necessary evils.” They use their professional skills to inflict “pain” on another in the service of a higher good. They also have to inflict this pain in the presence of the adverse party’s family and friends. “Think of a criminal defense attorney defending a child sex abuse case who must conduct a probing, challenging cross-examination of the child victim …”13 To perform their work, lawyers must necessarily intellectualize this pain and suppress their compassion.
And as the pace of life increases, so does the pressure on lawyers. The ubiquitous smartphones, email and online dockets compress the available time for responding to clients and the court and make time management that more difficult.
Dr. Martin Seligman, a pioneer in the study of “positive psychology,” which is essentially the study of what makes people happy, wrote an entire chapter on unhappy lawyers in his book Authentic Happiness: Using the New Positive Psychology to Realize Your Potential for Lasting Fulfillment, saying:
The adversarial process lies at the heart of the American system of law because it is thought to be the royal road to truth, but it does embody a classic win-loss game: one side’s win equals exactly the other side’s loss. Competition is at its zenith. Lawyers are trained to be aggressive, judgmental, intellectual, analytical and emotionally detached. This produces predictable emotional consequences for the legal practitioner: he or she will be depressed, anxious and angry a lot of the time.14
An oft-cited study done by Johns Hopkins University in 1991 revealed that lawyers were the unhappiest of 200 studied professions. Two recent studies have addressed the well-being of lawyers: one that concentrated on law students and the other on practicing lawyers. The first study was performed in 2014 and was a multi-school study of law students to address patterns of alcohol use and consumption of street drugs.15 The study revealed law students had high rates of alcohol use and thoughts of suicide, and 14% admitted to using prescription drugs in the last 12 months, mostly Adderall to “prevent their classmates from having an academic advantage.”16 Most students admitted to drinking enough to get drunk in the last 30 days, and almost 14% were worried they might be alcoholics.17 Anxiety was identified in 37% of law students, with 30% of those having developed the problem in law school.18
Effect of Law School
It is also common knowledge in the legal community that substance abuse rates and suicide rates for practicing lawyers are alarmingly elevated when compared to the general population,19 and it strongly appears this starts in law school. Lawyers are also reluctant to ask for help or receive treatment. The second study was done by the American Bar Association in cooperation with the Hazeldon Betty Ford Foundation.20 Lawyers in the ABA study reported they didn’t seek treatment because they didn’t want others to find out and wanted to preserve privacy and confidentiality. They were worried about losing their license to practice, and 18% said they didn’t have the money for treatment. Twenty-two percent said they didn’t know who to ask for help.21
The ABA study also found depression and substance abuse problems of students in the summer before law school mirror that of the general population, but these rates escalate in law school and never return to pre-law school levels.22 Forty-four percent of lawyers in the study who identified their drinking as a problem reported their problem was acute in the first 15 years of practicing law. Another 28% reported problematic drinking that started before law school, and 14.2% said their problem started in law school. Substance abuse is problematic in the practice of law with an American Bar Association estimate that 15 to 20% of all U.S. lawyers suffer from alcoholism or substance abuse, more than twice that of the general population.23 Twenty-eight percent of lawyers suffer from depression as opposed to only 3 to 9% of the general population. Nineteen percent of lawyers suffer from anxiety versus 1.9% of the general population. Twenty-three percent of lawyers experience symptoms of stress versus 3% of the general population. Only 3.5% of the general population has suicidal thoughts, but 11.5% of lawyers do.24 Further, a tendency toward pessimism is rewarded in law school with pessimists outscoring optimists in grades,25 and this tendency toward pessimism carries over to the practice, which contributes to mental health problems. In almost every other profession, optimism correlates with increased job performance and success, and the inverse is true with lawyers.
Pessimism is maladaptive in most endeavors. Pessimistic life insurance agents sell less and drop out sooner than optimistic agents. Pessimistic undergraduates get lower grades, relative to their SAT scores and past academic record, than optimistic students. Pessimistic swimmers have more substandard times and bounce back from poor efforts worse than do optimistic swimmers. Pessimistic pitchers and hitters do worse in close games than optimistic pitchers and hitters. Pessimistic NBA teams lose to the point spread more often than optimistic teams. Thus, pessimists are losers on many fronts. But there is one glaring exception: Pessimists do better at law. The fact that pessimism is adaptive in the profession brings in its wake a very high risk of depression in personal life.26
As stated by Richard J. Landau in the Michigan Bar Journal:
I have been a practicing trial lawyer for 33 years, but I was originally trained as a clinical psychologist specializing in cognitive behavioral therapy, a treatment for depression that research has proven particularly effective in controlled studies. Consistent with these recent reports, it is my observation and experience, based on years of work in both small and large law firm environments, that the analytical tools lawyers rely on and which are so essential to an attorney’s professional success also render attorneys uniquely susceptible to depression and substance abuse in their daily lives. Indeed, the seeds of this problem may begin in law school. Professors teach their students to “think like a lawyer.” The better a lawyer is at using these tools, the more effortless or automatic this reasoning is to the practicing lawyer, the more susceptible to depression and substance abuse that lawyer may be. To practicing attorneys, the cognitive distortions that psychologists have found associated with depression and substance abuse become essential everyday tools of the trade. Indeed, the profession rewards and advances those attorneys who are most successful at employing the very tools that make them susceptible to depression and addiction.27
However, since when entering law school students are not distinguishable from regular undergraduates, it seems there is something about the law school experience that changes people.
Law school also appears to intensify students’ tendencies to ignore emotions, interpersonal concerns, and warm interpersonal relations. There may be nothing maladaptive about law students’ preference for logic and rationality (e.g. thinking) over interpersonal concerns and emotions (feeling), but this preference may become extreme and thus dysfunctional during law school and thereafter. It may contribute to an unbalanced approach to life and difficulties relating to peers, family, friends and clients.28
Mental health deterioration, then, begins in law school. The emphasis on class rank, grades, law review, etc., can subvert the reasons many students enter the law in the first place – to do good and make a positive difference in the world. There is a trend in law schools to attempt to ameliorate this effect and to help students put grades and class rank into perspective – study after study has shown that grades and class rank only slightly correlate to higher incomes after law school and do not correlate to happiness or satisfaction in the practice.29 However, many legal employers still rely on grades and class rank to make hiring decisions, although numerous studies have shown these factors are very weak predictors in determining competence and success as a lawyer. Those with top grades are no more likely to succeed than those students with simply “good” grades. In fact, a study in 2008 found, “The Harvard attorneys do not perform any better than those at the 30th-ranked law school.”30 Success as a lawyer is more related to drive, willingness to take risks, marketing skills, communication skills and a passion for one’s work.31 Happiness as a lawyer is even less dependent on law school success.32
CONSEQUENCES OF IGNORING LAWYER WELL-BEING
There is a plethora of ethical problems and harm to clients arising from ignoring the declining mental health of lawyers. Besides medical and societal problems attendant to substance abuse, there are ethical problems. Impaired lawyers miss court dates, deadlines, poorly prepare and poorly represent clients and are at risk of mishandling client funds.
- 5 O.S. §1.1 (Competence) requires thoroughness and preparation reasonably necessary for representation.
- 5 O.S. §1.3 (Diligence) requires reasonable promptness in representing a client.
- 5 O.S. §1.15 (Safekeeping Property) requires a lawyer to hold the property of clients and third parties in connection with representation separate from the lawyer’s own funds and property.
- 5 O.S. §8.4 (Misconduct) prohibits criminal, dishonest or fraudulent acts, often part of claims against lawyers who misappropriate client property. Many ethical complaints involve trust violations.33
Addressing the mental health and substance abuse issues in the bar has a direct and measurable benefit to both the lawyers and their clients. As Patrick J. Schiltz notes, “People who are this unhealthy are almost by definition unhappy.”34
WHAT CAN LAW SCHOOLS DO?
The research shows that law schools should strive to provide accessible and confidential outlets for students to seek help. Peer mentoring groups worry that students fear the information will not be held confidential and students’ problems will become part of the law school gossip mill. In addition, law students must feel supported by the school’s administration, faculty, staff and other students, and they must believe if they ask for help, they will get it. The culture of law school needs to be changed, so students do not feel asking for help is a sign of weakness but a strength.
Law schools should consider establishing student assistance programs much like bar associations’ lawyer assistance programs. Professors should pay attention to student absence as a sign the student is struggling with something – perhaps mental health issues or substance abuse. Other students should be educated as to the signs of mental distress among their colleagues and how they can offer help and resources.
WHAT CAN LEGAL EMPLOYERS DO?
Legal employers should make the health and well-being of lawyers a priority, both because it is good for the lawyers and because it is good for the employer. It is axiomatic that addicted, exhausted, depressed and anxious lawyers are not good lawyers. Mistakes will be made, ethics may be flexible, corners will be cut – all things that affect the quality of representation of clients and thus the bottom line. A significant number of formal disciplinary proceedings against lawyers have identified a substance abuse or mental health issue as contributing to the lapses. In addition, the supervisors of these lawyers are responsible for the actions of these impaired lawyers
if they know about the problem.
Ethical Rule 5.1 (Responsibilities of Partners, Managers and Supervisory Lawyers) provides that a lawyer who is a “partner or has comparable managerial authority in a law firm in which the other lawyer practices, or has direct supervisory authority over the other lawyer” is responsible for the other lawyer if the supervisory lawyer has knowledge of the unethical conduct and fails to take action to avoid or mitigate its consequences. The mental health of subordinates, therefore, is an ethical duty of supervisors.
Law firms and corporate legal departments should create wellness programs that have buy-ins from leadership and should create a culture where asking for help is not viewed as weakness or a lack of commitment to the practice.
WHAT CAN BAR ASSOCIATIONS AND THE SUPREME COURT DO?
Wellness is critical to competence. An impaired lawyer is an incompetent lawyer. The most frequent ethical violations by lawyers requiring discipline are concentrated in the areas most affected by substance abuse or mental health issues. The 2020 annual report of the OBA Professional Responsibility Commission35 found that almost half of complaints made against lawyers were for neglect, followed by misrepresentation, personal behavior, trust violations and incompetence. Impaired lawyers can also struggle with relations with the court, their clients and third parties. An ABA study in 2017 recommended that lawyer supervisory organizations adopt the following:
- Identifying the stakeholders and the role each can play in reducing the level
of toxicity in the profession;
- Eliminating the stigma associated with help-
- Emphasizing that well-
being is an indispensable part of a lawyer’s duty of competence;
- Educating lawyers, judges and law students on well-being issues; and
- Taking small, incremental steps to change how the law is practiced and how lawyers are regulated to instill greater well-being
in the profession.36
Education promoting well-being is required by several bar associations as a CLE requirement. Healthy lawyers are more productive, happier and less likely to come to the attention of disciplinary committees.
WHAT CAN LAWYERS DO?
It turns out that what makes lawyers happy is the same things that make everyone else happy.37 People are happier in their work if:
- Their work aligns with their internal values;
- They feel competent in their chosen field;
- They relate to and feel valued by their co-workers and
- They feel they have autonomy in their work.38
Surprisingly, happiness is not increased by:
- More income (other than an income that allows the lawyer to meet basic needs and have some level of comfort – around $75,000 per year, all other things being equal.)
- Higher class rank in law school;
- Making partner in a law firm or
- Being on law review.39
And, also surprisingly, lawyers are only a little happier if:
- They take a lot of vacations;
- They have children;
- They are married or have long-term, committed relationships;
- They exercise;
- They are in an affiliated religion and utilize prayer or
- They work in a smaller town.40
Lawyers are unhappier if:
- They abuse alcohol or drugs or
- They are subjected to an unreasonable billable hour requirement.
So, what can practicing lawyers do to increase their happiness levels? Research confirms that:
- Lawyers should align their work with their values and seek out work they find interesting and meaningful. It is possible to practice law without doing violence to what you believe to be right. Look back to why you went to law school in the first place, what kind of work you actually enjoy and take active steps to pivot your practice/work life in that direction.
- Develop your skills so you feel comfortable and competent in your chosen area of the law. If you hate litigation, don’t feel like you have to be in a courtroom or you are not a “real lawyer.”
- Recognize that mistakes are a part of life and let them go. You are not a perfect person, and you won’t be
a perfect lawyer.
- If you are in a firm or other environment where you do not feel valued or you don’t relate to your co-workers, start looking for a work environment more compatible with your relationship needs.
- Cultivate a work environment where you have some control over what you do and when you do it.
- Remember that more money is not likely to make you happier.
- Set realistic and obtainable goals based on what you have accomplished and experienced in the past.
- Accept that the practice of law is inherently stressful and take active steps to manage your stress in a healthy way. Don’t be afraid or embarrassed to get help. If you are feeling distressed, remember the OBA offers six free counseling sessions, group sessions and the Lawyers Helping Lawyers Assistance Program as a member benefit. You can access that resource at www.okbar.org/lhl.
The practice of law is unique in that a specific thinking style is necessary to perform the work. It is a necessary evil that lawyers are required to view their client’s problems dispassionately and logically and tap into pessimistic attitudes to anticipate problems. Lawyers have to remain objective to serve their client’s needs, and it is a fact of the practice that they often don’t accomplish outcomes that align with their personal views of justice. To be happy in the practice of law is to align your practice to the extent possible with your internal values and have some control over who you represent and what kinds of cases and practice you have.
It is also important that lawyers learn to “let go of outcomes.” Because lawyers are often perfectionists, they tend to believe they are responsible for a client’s bad outcome. The only control a lawyer has is the competent and professional management of a client’s case. Individual lawyers have no control over a judge or jury ruling, the conduct of the client who doesn’t follow advice, government agencies or the adverse party or their counsel. So long as representation is zealous, professional, ethical and competent, the outcome is not under the lawyer’s control.
It is possible to love being a lawyer. The intentional structure of a practice that aligns with your values and your abilities is the key.
ABOUT THE AUTHORS
Virginia Henson is a sole practitioner in Norman, where she practices primarily in the area of family law. She is a member of the American Academy of Matrimonial Lawyers. Ms. Henson was the recipient of the 2020 Golden Quill Award and is a frequent CLE presenter.
Alli Haselwood is a 1L at the OU College of Law. Before entering law school, she was an engineer with General Electric and Baker Hughes. Ms. Haselwood holds a degree in mechanical engineering from OU.
- Myers Briggs, https://bit.ly/3phBVHs (last visited Feb. 3, 2022).
- S.S. Daicoff, Lawyer, Know Thyself, 201 (2004).
- Paul Van R. Miller, “Personality Differences and Student Survival in Law School,”19 J. Legal Educ., 460 (1967); Norman Solkoff, “The Use of Personality and Attitude Tests in Predicting Academic Success of Medical and Law Students,” 43 J. Med. Educ. 1250 (1968).
- Lawrence R. Richard, Psychological Type and Job Satisfaction Among Practicing Lawyers in the United States, (1994) (unpublished Ph.D. dissertation on file with Temple University).
- Daicoff, supra.
- Dave Shearon, “Hope About Lawyer Happiness,” Positive Psychology News (Feb. 3, 2022), https://bit.ly/3viMYE0.
- L. Guiner et al., “Becoming Gentlemen: Women’s Experiences at One Ivy League Law School,” 143 U. Pa. L. Rev. 1, 1-110 (1994).
- Daicoff, supra.
- Lawrence Richard, “The Lawyer Types,” ABA J., Jul. 1993, at 76.
- “Lawyer” jokes, for instance, commonly address one or more of these negative stereotypes. See e.g., Thomas W. Overton, “Lawyers, Light Bulbs and Dead Snakes: The Lawyer Joke as Societal Text,”42 UCLA L. Rev., 1069, 1082-85 (1995).
- Dave Shearon, “Hope about Lawyer Happiness,” https://bit.ly/3viMYE0.
- Shearon, supra.
- Shearon, supra.
- Martin Seligman, Authentic Happiness, Random House Australia: 2002.
- Jerome M. Organ et al., “Suffering in Silence: The Survey of Law Student Well-Being and the Reluctance of Law Students to Seek Help for Substance Use and Mental Health Concerns,” 66
J. Legal Educ. 116, 116 (2016), https://bit.ly/33Qp8nO.
- Id at 135.
- Id at 132.
- Id at 137.
- L. Dowell, “Attorneys and Alcoholism:
An Alternate Approach to a Serious Problem,”
16 N. Ky. L. Rev., 169 (1998).
- Hazeldon Betty Ford Foundation and the American Bar Association. “The Prevalence of Substance Use and Other Mental Health Concerns Among American Attorneys,” 10 Journal of Addiction Medicine 1 (Feb. 2016); Debra Weiss, “School Rank and GPA Aren’t the Best Predictors of Big Law Success,” ABA J. (Oct. 16, 2008).
- Hazeldon, supra.
- G. Benjamin et al., “The Role of Legal Education in Producing Psychological Distress Among Law Students,” Am. Bar Found. Res. J. (1886).
- Jones, D. (2001). “Career killers.” In B.P. Crowley & M.L. Winick (eds.) A Guide to the Basic Law Practice. Alliance Press, 180-197.
- Hazeldon, supra, pages 46-52.
- J. Satterfield et al., “Law School Performance Predicted by Explanatory Style,”
15 Behavioral Science & the Law (1997).
- Martin Seligman, Ph.D., https://bit.ly/3IyIrkw.
- Richard J. Landau, “Does ‘Thinking Like a Lawyer’ Play a Role in the Legal Profession’s Mental Health Crisis?” Mich. Bar. J., 40 (Oct. 1997).
- Amiram Elwork & G. Andrew H. Benjamin, “Lawyers in Distress,”1995 J. Psychiatry & Law, 205, 216 (noting that lawyers’ traits cause them to be unbalanced).
- G. Andrew H. Benjamin, et. al., “The Role of Legal Education in Producing Psychological Distress Among Law Students and Lawyers,” Law & Social Inquiry, Volume 11, Issue 2, pages 225–252, (April 1986).
- Kerma Partners and Redwood Thinktank, “Are we Selling Results or Resumes?” ABA J. (2008).
- Debra Cassen Weiss, “School Rank and GPA Aren’t the Best Predictors of BigLaw Success,” ABA J. (Oct. 16, 2008).
- Lawrence S. Krieger & Kennon M. Sheldon, “What Makes Lawyers Happy? A Data-Driven Prescription to Redefine Professional Success,” 83 Geo. Wash. L. Rev. 554, 560 (2015).
- Oklahoma Rules of Professional Conduct.
- Patrick J. Shiltz, “On Being a Happy, Healthy and Ethical Member of an Unhappy, Unhealthy and Unethical Profession,” 52 Vanderbilt L. Rev. 871 (1999).
- https://bit.ly/3hiWdvW (last accessed
Feb. 3, 2022).
- Of course, each individual lawyer must determine for themselves how activities promote their individual well-being, and any research merely addresses well-being globally among lawyers.
- Krieger, supra.
- Krieger, supra.
- Krieger, supra.
Oklahoma Bar Journal – OBJ 93 Vol 4 (April 2022)