The State Bar seeks public comment on proposed changes to the rules for the Law Office Study Program to modernize and improve the program, eliminate unnecessary barriers to participation, and address the Court's concerns.

Deadline: August 8, 2025, 11:59 p.m. (60 days)

Direct comments to

Comments should be submitted using the online Public Comment Form. The online form allows you to input your comments directly.

Background

The Law Office Study (LOS) Program allows individuals to qualify for the California Bar Exam without attending law school by studying law for four years in a law office or judge’s chambers. The program offers an alternative pathway to licensure for those for whom law school is not a good fit. In 2022 and 2023, revisions to the LOS rules were circulated for public comment and approved by the Committee of Bar Examiners (CBE) and the Board of Trustees. The revised rules were submitted to the California Supreme Court in July 2023. On September 20, 2023, the Court denied the proposal and provided guidance for further review.

Discussion/proposal

As part of its comprehensive review of Admissions rules and applicant materials, the CBE evaluated the LOS Program’s requirements and application process. The program serves those unable to attend law school due to personal, academic, or financial barriers. The CBE sought to revise the rules to remove unnecessary obstacles and provide clearer guidance to participants and supervisors. Additional revisions were made following the Court’s 2023 feedback.

To modernize the program, the proposed changes eliminate the requirement that study occur only "during regular business hours" and allow study in locations beyond a law office or chambers. To maintain oversight for remote study, the revised rules require synchronous supervision for at least 20 hours per month and mandate that at least 10 of the required 120 study hours per six-month period be conducted in person. The revisions also clarify application and participation procedures to help ensure program compliance.

In response to the Court’s concern about potential conflicts between LOS participation and the Practical Training of Law Students (PTLS) Program, the proposed rules prohibit concurrent enrollment in PTLS for LOS students studying under a judge.

The CBE recommended these rules for circulation, and the Board approved them. This request seeks input only on the LOS rule changes; related PTLS rule changes are circulating separately.

Any fiscal/personnel impact

If adopted, the rule changes may lead to a manageable increase in LOS applications, which can be supported with existing resources. Additional application revenue could help fund any needed staffing. Updates to the Admissions Information Management System will require a moderate effort from the Office of Information Technology to revise text, automate functions, update logic, and add fees. The Office of Strategic Communications & Stakeholder Engagement will also make minor updates to the State Bar’s public website.

Background material

• From the Committee of Bar Examiners October 14, 2022, meeting: Agenda Item IV B. Action on Revisions to the Practical Training of Law Students and Law Office Study Rules; Recommendation to Circulate for Public Comment
• From the Board of Trustees November 17-18, 2022, meeting: Agenda Item 706 Proposed Amendments to Admissions Rules Related to Testing Accommodations, Moral Character, Law Office Study, and the Practical Training of Law Students Program: Request to Circulate for Public Comment
• From the Committee of Bar Examiners March 24, 2023, meeting: Agenda Item III B. Action on Rules Revisions Regarding Practical Training of Law Students and Law Office Study Programs: Recommendation to Adopt Following Return from Public Comment and Transmit to the Supreme Court
• From the Board of Trustees May 18‒19, 2023, meeting: Agenda Item 705 Proposed Amendments to Admissions Rules Related to Moral Character, Law Office Study, and the Practical Training of Law Students Program (Rule of Court Title 9, Division 4, Rule 9.42, and State Bar Rules 3.2–3.10, 4.3, 4.5, 4.6, 4.29, 4.40–4.52, 4.80–4.93, and Appendix A): Return from Public Comment and Request for Adoption Following Transmission to the Supreme Court for Approval
• From the Committee of Bar Examiners March 14, 2025, meeting: Agenda Item 4.4 Action on Revisions to the Practical Training of Law Students and Law Office Study Rules: Recommendation to Circulate Revised Rules for Public Comment
• From the Board of Trustees May 22‒23, 2025, meeting: Agenda Item 7.1 Action on Revisions to the Practical Training of Law Students and Law Office Study Rules: Recommendation to Circulate Revised Rules for Public Comment
• From the Board of Trustees May 22–23, 2025, meeting: Agenda Item 7.1: Attachments A–H

Source

Board of Trustees 

Deadline

August 8, 2025, 11:59 p.m.

Direct comments to

Comments should be submitted using the online Public Comment Form. The online form allows you to input your comments directly.