UPDATE: as of late 2019, Western State is under new ownership and successfully petitioned for ABA accreditation, which renders portions of this post inaccurate.

One year ago today—March 22, 2018—I reflected on the “trickle” of law school closures. Some campuses closed (Cooley’s Ann Arbor branch, Atlanta’s John Marshall’s Savannah branch), two schools merged into one (William Mitchell and Hamline), and others announced their closure (Indiana Tech, Whittier, Charlotte, and Valparaiso). In the last year, Arizona Summit and Western State have announced their closures.

Western State closing two years after Whittier is a remarkable turn for legal education in Orange County, California. Orange County, with more than 3 million residents, is one of the most populous and fastest-growing counties in the United States.

California has long had a number of state-accredited schools in the state, schools that do not have full ABA accreditation. Western State has been around since the 1970s but was not the first school to gain full ABA accreditation—that was Whittier in 1978. Western State joined newcomer Chapman as fully accredited in 1998. Then UC-Irvine was accredited in 2011. But now two of those four schools have closed.

While we are a long way from the recession, and while law school enrollment has stabilized (and slightly improved) over the last few years, there remain longstanding pressures on legal education, in part from the legacy of the recession—small class sizes can only be sustained so long, scholarships have increased to attract students, the transfer market has disproportionately impacted more marginal schools, lower credentials of incoming students have translated into systemic lower bar passage rates, and so on.

We may still see a few more closures in the years ahead—for-profit schools schools have borne the brunt of the closures, but we’ll see what happens in the months to come.