Will any law schools close as a result of the decline in enrollment and the lingering effects of the 2008 recession?

This was how I began a draft of a blog post five years ago. (And that I'm finally revising....) It's a little strange, perhaps, now, to link some of the present status of legal education to an economic event ten years ago, or that we've been discussing the same decline in enrollment problems for many years.

In part, I confess, I had deep skepticism that any law schools would close--at least, any accredited law schools. From my research, I couldn't find a single ABA-accredited law school that had ever closed. The ABA has been accrediting law schools for about a hundred years, and there had been closures of non-accredited or state-accredited schools. I wondered, then, what closures might look like.

I had compiled a few of the most notable predictions concerning law school closures a few years ago.

June 17, 2010, Professor Bainbridge:

If admission applicants drop enough, maybe some of the bottom tier of schools will have to close for lack of qualified applicants. (Or maybe they'll just admit unqualified applicants.) 

October 19, 2010, ABA Journal:

As large law firms continue to hire fewer highly paid associates, law school applications will eventually drop and the number of law schools will likely contract, two professors predict in a recent article.

April 25, 2011, The New Republic:

I'm not saying law schools will go away -- the prestigious ones, especially, will probably come out just fine -- but vast swaths of it [sic] will probably disappear. 

October 3, 2012, Brian Leiter's Law School Reports: 

My own opinion was that we'll see several law schools close during the next decade, but probably not more than ten--and that was the majority view among readers by a wide margin.  Most vulnerable are going to be free-standing law schools that are relatively young.  Relatively young law schools part of universities that are in vulnerable financial shape are also likely candidates.  

Here we are, ten years after the recession, eight years after the peak law school applicant and enrollment cycle, and we've seen some fairly significant movement. (I won't include the list of prospective new law schools that were abandoned before they began in the last decade.)

Cooley closed its Ann Arbor branch campus in 2014, but that was a branch campus, not a full closure.

William Mitchell and Hamline announced a merger in 2015, but I wasn't inclined to call that a "closure," despite two schools becoming one school. And, that said, enrollment looks more like the size of one school than two schools put together.

Indiana Tech announced its closure in 2016--but, in part, I discounted that closure because the school was not fully accredited by the ABA--only provisionally.

Whittier announced its closure in 2017, and there was the first fully ABA-accredited institution to do so.

Charlotte announced its closure in 2017, a second fully ABA-accredited institution, and the first for-profit law school (six for-profit law schools arose since a consent decree in 1995).

Valparaiso announced in 2017 that it would not enroll an incoming class and was looking for future options for the school--whether closure or selling the institution.

And just yesterday, Savannah announced it would be closing--a branch of Atlanta's John Marshall.

It's been a trickle of closures--a merger, a couple of branch closures, a suspension of admissions, a couple of outright closures. It's hard to portend what else might come. Arizona Summit and Thomas Jefferson are on probation status with the ABA, but that might change. Concordia, Lincoln Memorial, and North Texas are provisionally accredited, and we might see an update on their statuses soon. And there might be fully-accredited schools out there making difficult decisions.

Professor Jerry Organ in 2014 presciently compared a historic decline in dental school enrollment and ultimate closures with what he saw to be possible future closures in legal education--the tail was long, he emphasized, before the true change in the quality of students and the long-term financial pressures closed dental schools. Here we are, a decade after the recession, and we are seeing some of the consequences. Yes, next year appears to be a relatively good year for law schools compared to the last several. But that is probably not enough to change what might be still future difficulties at many institutions. Only sustained long-term growth in quantity and quality of law school applicants, driven by a market desire for more such law graduates, will bring much-needed stability.