Note:  This material is offered for the convenience of users.  Official citation should be to, and quotation should be from, 67 Fordham Law Rev. (1999)

RECOMMENDATIONS OF THE CONFERENCE ON THE DELIVERY OF LEGAL SERVICES TO LOW-INCOME PERSONS (1)

Copyright Fordham Law Review, 1999, Used with Permission

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1751 (1999)

I. RENDERING LEGAL ASSISTANCE TO SIMILARLY SITUATED PERSONS

A. Benefits of Collective Representation and the Impact of Restrictions

L IKE other individuals, low-income persons often have common legal problems, interests, or objectives, which can be served most effectively and efficiently through some form of collective action. Pos-sibilities include: class actions; litigation on behalf of one or more in-dividuals or entities that is intended to achieve a result that will affect others who are similarly situated; administrative or legislative advo-cacy; creating and engaging in action through a formal entity or infor-mal
association of individuals; and community education. Low-income persons should have available to them all these options.
Where individuals seek to attain a common objective, lawyers should be encouraged to assist their clients in taking advantage of those op-tions
that will be most effective in a particular situation. Lawyers serving low-income persons and communities should not be subjected to restrictions on professional practice that preclude them from assisting clients through class actions, administrative or leg-islative lobbying, or other forms of collective action that may, in a
given situation, be the most effective and efficient means to achieve a common objective.

Legislative Advocacy:
The lawmaking process in the United States is structured to involve a "marketplace of ideas." Because legislators cannot be experts in all
areas of the law, they depend on input from a range of persons with special knowledge about the impact on society, or on different groups,
of existing or proposed laws. If lawmakers are deprived of access to persons who have relevant specialized knowledge, the fairness and ef-fectiveness
of the process is compromised (diminished), and the probability of producing fair, balanced, and effective laws is reduced.
Legislative access to legal expertise from lawyers representing the poor is particularly important because impoverished segments of soci-ety
have particularly limited abilities to wield influence in the legisla-tive arena, as well as limited abilities to obtain representation to

1. The recommendations are consecutively numbered for ease of reference. Citations to these recommendations elsewhere in this volume shall be as follows:
Recommendations of the Conference on the Delivery of Legal Services to Low-Income Persons, 67 Fordham L. Rev. 1751, Recommendation ___, at ___ (1999) [hereinafter
Recommendations].
 

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1752 (1999)

challenge problematic legislation, and, therefore, are particularly vul-nerable to poorly designed legislation.
Moreover, laws that are poorly drafted, obsolete, or inefficient are breeding grounds for litigation. It is wasteful of the public fisc to ham-per
efforts to update and improve laws. Restrictions on the participa-tion in the legislative process of legal services attorneys, who are
uniquely able to identify and explain to lawmakers problems with ex-isting and proposed laws affecting poor people, are contrary to effi-cient
and effective lawmaking, and likely to encourage litigation. Legal problems that might be resolved through a change in law are
more likely to be litigated if poverty lawyers are not permitted to pro-pose and advocate for such a legislative change.
We believe that it is in the interest not only of low-income clients, but also of legislators, clients, and society at large, which pays for all
the systems for making and enforcing the laws, to enable all attorneys, including publicly funded legal services attorneys, to carry out fully
their responsibilities under Model Rule 6.1 (footnote 2) (concerning voluntary pro bono publico service).
For the foregoing reasons, we recommend that:

1. Funders of legal services for the poor refrain from imposing limits on the access of legal-services attorneys to the law making
process; and

2. Standards for evaluating legal-services programs should identify an ability and commitment to participate in lawmaking as one
component of the most effective delivery system.

Class Actions:  The public has a strong interest in equal access to justice and in the efficient resolution of legal disputes affecting large numbers of people.
Accordingly, we have considered the following in formulating our recommendations:

Other persons affected by the common legal issue: Many low-income persons affected by a common legal problem and who would benefit
from a class action resolution are unable to obtain counsel at all. For them, justice would be denied altogether. In an era of very limited
resources for low-income persons, if there is not a class action, then many people will go unrepresented.

Judicial and public economy: Repetitive litigation involving the same issue for different litigants is wasteful of judicial resources in
that it involves repeated interpretation of the same law. It often leads to inconsistent decisions at the trial level, generating repeated appeals.
This inefficiency is rendered even more wasteful if counsel for the party adverse to a legal services client is publicly funded.

Impact on other users of the judicial system: When court calendars are clogged with numerous cases involving the same issue because

2. Model Rules of Professional Conduct Rule 6.1 (1998).
 

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1753 (1999)
 

court and counsel are barred from using the class action mechanism to resolve the issue, resolution of the cases of other litigants is delayed.
This makes the judicial system less efficient and reduces public confi-dence in, and support for, the judicial system. This is a serious con-cern,
especially at a time when court case loads are growing faster than the judicial resources available to resolve them.
Quality of justice: One of the hallmarks of an effective government of law is that similarly situated persons are treated the same by the
law. Multiple litigation in different trial courts on the same issue often produces inconsistent outcomes. In legal services programs, with lim-ited
resources, not all adverse decisions can be appealed. Some liti-gants are therefore likely to be harmed irreparably by a decision.
Even if an appeal in another case leads to a favorable appellate deci-sion for a low-income client, that appellate decision often cannot be
applied to prior trial court decisions in other cases that have not been appealed. These inconsistent outcomes produce the conviction in
those harmed that they have been treated unjustly by the justice sys-tem. This undermines or destroys their respect for the law, thus weak-ening
the fabric of society.

Legal services resources: In appropriate cases, a class action is an extraordinarily effective way to address a legal problem affecting a
large number of clients. A legal services program that cannot ask the court to utilize the class action mechanism to resolve a question effi-ciently
is forced to bring the same case repeatedly before the courts, thereby wasting resources that are already inadequate to meet client
needs and eliminating its ability to represent all clients. If the office attempts to refer the case to another lawyer to undertake it as a class
action, then there may be no lawyer available with the requisite com-petence (as discussed below), or no lawyer available at all.

All attorneys have a professional responsibility to avoid wasting ju-dicial resources and to seek the most efficient ways to resolve client
problems. We therefore believe that denying a class of attorneys and their clients access to all of the tools of judicial economy, and denying
the courts in a certain class of cases the ability to administer justice most fairly and efficiently, undermines the ability of both lawyers and
judges to carry out fully their professional responsibilities.
For the foregoing reasons, we recommend that:

3. Funders of legal services programs refrain from denying legal services program counsel, or the courts in cases involving such
counsel, access to class action mechanisms when appropriate; and

4. Legal services programs' boards, in light of their fiduciary re-sponsibility to ensure that program resources are used most cost
effectively, consider whether, in seeking funding, they have a professional responsibility to explain to funders the negative
impact of such restrictions on the ability of legal services pro-

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1754 (1999)
 

gram counsel to carry out fully their professional responsibili-ties to their clients and to the court.

A Lawyer's Individual Role in Agency and Law Reform: ABA Model Rule 6.1 makes it the responsibility of every attorney to render public service, a responsibility which includes participation in activities that improve the laws and the legal system. (Footnote 3) Legal serv-ices attorneys are not exempt from that responsibility. Therefore, we recommend that:

5. Legal services attorneys who are not permitted to use program resources to bring an issue to the attention of lawmakers con-sider
whether they have a responsibility under Rule 6.1 to un-dertake such efforts on a pro bono basis, and that legal services
programs that are subject to restrictions not discourage them from doing so.
 

B. Competence

In order to provide competent, high-quality representation in mat-ters involving the common legal problems, interests, or objectives of
low-income persons, the lawyer must possess not only relevant legal skills, but also knowledge about the community being served. There-fore,
we recommend that:

6. The lawyer should strive to:

(a) understand the origin and dynamics of racial, gender, and economic inequality in the client community;
(b) know or strive to learn the context of community issues, including community history, economics, politics, and
demographics, as well as its resources, leaders, allies, and adversaries;
(c) acknowledge and be aware of the lawyer's own biases and the limitations of the lawyer's own knowledge;
(d) identify and obtain information on institutions and people who affect the interests of clients (e. g., police, landlords,
welfare departments, school officials, and the media);
(e) establish working partnerships and coordinate advocacy with others who work with client groups;
(f) respect clients' autonomy, privacy, and confidentiality; and
(g) overcome obstacles to establishing trust based on differ-ences in race and class between the lawyer and client.

To the extent that restrictions by funders impede the lawyer's ability fully to represent client communities, they compromise the ability to
provide competent representation and thus contradict the mission of seeking equal justice.

3. Id.

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1755 (1999)
 
 

C. Class Actions


     Even if an individual client's interests may be adequately served through other means, the lawyer should be prepared, where appropriate,
to provide full information about the possibilities for seeking a broader impact, so that the client has the option to
consent to undertaking a course of action aimed at achieving that objective. If the lawyer is unable to provide this type of
representation, then the lawyer should attempt to provide an appropriate referral.

8. Among the factors that a lawyer should consider in deciding whether to bring a class action are:
(a) whether the class action is likely to benefit the class, as well as benefit the named individuals;
(b) whether it is better to proceed with an organizational plain-tiff rather than a class action;
(c) whether the lawyer has the capacity to handle adequately not only the litigation but anticipated monitoring and en-forcement
of the potential relief; (d) whether the class action device is the preferable means to
achieve the best relief for the class and the named individu-als; and
(e) whether the class action is consistent with the resource allo-cation and priorities of the organization employing the
lawyer.

9. Among the factors that a lawyer should consider in deciding how to define the proposed class are:

(a) whether potential class members in geographical areas other than the place of residence of the named individuals
have access to attorneys likely to undertake similar litiga-tion on their behalf;
(b) whether potential class members in other geographical ar-eas who do have access to lawyers likely to undertake simi-lar
litigation on their behalf would be precluded from doing so by including them in the class;
(c) how a more inclusive class definition would provide repre-sentation to potential class members who would not other-wise
be represented, would affect the likelihood of success or extent of relief, or would cause the lawyer to expend dis-proportionate
resources on the litigation; (d) the degree to which the lawyer has sufficient knowledge of
the contextual circumstances in which the claim arises for differing potential members of the class (see the section
above on competence); (e) whether the lawyer has the resources or access to the re-sources
necessary to monitor and enforce the anticipated relief for the defined class;

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1756 (1999)
 

(f) whether the class as defined will be manageable, and whether the lawyer is able and willing to manage it; and
(g) the effect of the definition of the class on the possibility of settlement.

10. Lawyers undertaking class representation should enter into a retainer agreement that clarifies the extent of representation
and the responsibilities of the lawyer and the class representa-tive. There is a need for further study on whether such a re-tainer
can limit the scope of representation in a way that allows the attorney to refuse to represent the class on a poten-tially
meritorious appeal, and, if so, the extent to which judicial knowledge or approval is required for such a refusal.

11. In the class action context, the interests of individual class rep-resentatives may conflict with those of other class members.
Lawyers should ensure that class representatives understand their role as fiduciaries for the class. Lawyers should attempt
to protect individual representatives' interests within the con-text of advocacy for the class as a whole, but if a conflict is
unavoidable, they must act in the interests of the class as a whole.

12. Assuming that it is permissible for the lawyer to decide to withdraw representation at a particular stage of the case (e. g.,
post trial), the decision whether or not to do so should be made with due regard for such relevant considerations as: (a)
possible limitations of the lawyer's available resources; (b) the impact of withdrawal on the class; (c) the class's or clients' rea-sonable
expectations; (d) availability of alternative counsel; and (e) the likelihood of success.

13. There may be situations where, because of unanticipated changes in the law or legal processes, or similar developments,
it is appropriate for a lawyer to withdraw from the representa-tion of a class. Although such situations are difficult to define
precisely, further study should be undertaken toward develop-ing principles that should guide this decision and the lawyer's
obligations (such as to assist in obtaining substitute counsel) in such situations.
 

D. Representation of Entities and Associations Serving or Comprising Low-Income Persons

Representing community groups is important work in light of such groups' valuable role in improving neighborhoods and communities,
building social capital, and solving collective problems. Community groups need legal assistance in a number of areas, including: initial
structuring, acquiring resources, maintaining their operations, comply-ing with regulatory regimes, and otherwise accomplishing their
objectives.

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1757 (1999)
 

14. In representing a group, lawyers should draft clear retainer agreements spelling out the scope and objective of the
representation.

15. Representing a group competently often requires an under-standing of a specialized area of transnational law. The lawyer
also must develop a detailed understanding of the group, its history, its processes, and its objectives. The lawyer should
recognize needs for other kinds of technical assistance, such as accounting and organizational development, and should work
with the leadership to identify resources to address these needs.

16. The rules of professional conduct that govern entity represen-tation apply in this context. For example, lawyers generally
should advise the leadership of the group, and should defer to its decisions on behalf of the group.

17. Where clients with common interests would be served well by the creation of an entity, it is appropriate to advise them of the
option and to assist them in exploring the possibility. Lawyers working with an emerging organization can play an essential
role in assisting the group in choosing a structure, evaluating goals, and defining its processes. In counseling the group, the
lawyer should be alert to situations where: (a) the decisionmaking process departs from the process pre-viously
defined by the group in light of its mission; (b) substantive decisions appear to be inconsistent with the
group's mission or the interests of those whom the group represents; or
(c) substantive decisions appear to be inconsistent with the re-tainer agreement.
In these and similar situations, the lawyer should be guided by Model Rule 1.13( b). However, the lawyer should be careful to
avoid usurping the functions of the group's leaders or substi-tuting her judgment for theirs.

18. Further study should focus on whether traditional conflicts-of-interest principles should control the representation of multi-ple
community groups. Factors to be considered should in-clude the availability of alternative representation (including
pro bono representation from the private bar) and questions about the adequacy of clients' consent to waive conflicts.
 

E. Building Coalitions and Collaborative Relationships

Lawyers and law offices serving low-income clients and communi-ties should be encouraged to participate in coalitions and to build col-laborative

relationships across professions and between client groups and other entities that address issues relevant to the client population.
Doing so enables lawyers to better represent their clients or client
 

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1758 (1999)
 

community by: (1) enabling lawyers to develop competence, by pro-viding access to information relevant to the representation of their
clients; (2) providing lawyers access to individuals and organizations that may assist the lawyer in dealing with processes with which those
individuals or organizations have superior experience or expertise; (3) efficiently disseminating law-related information of relevance to the
community, thus facilitating educational objectives of the lawyer or law office; and (4) expanding or providing support for participation in
legislative advocacy and developing public awareness around client and community matters.

Coalitions or collaborative relationships with other professionals and client groups allow the lawyer to exchange information, skills, and
strategies. In addition, organizers and client groups often possess both a knowledge of community resources and constraints and the
skills and experience of bringing people and groups together. As the legal services community continues to shrink, these relationships are
essential.

Increasingly, coalitions and professional collaborations are being recognized for their ability to disseminate information efficiently and
train the community on law-related issues and procedures. Collabora-tions that provide another means to "legal access" are empowering to
a client community. Law reform is often best accomplished through legislative advocacy as well as litigation. Consequently, coalitions can provide a lawyer
with an organized body that will advocate politically (and through the media) on an issue, as well as offer legal resources to clients with
problems. In addition, members of coalitions may offer to organize a part of a client community.

Working in coalitions or forming collaborations also create oppor-tunities to access additional resources for serving low-income persons.
Therefore, we recommend that:

19. To the extent that lawyers or law offices participate in a coali-tion or collaborate in their individual capacity and not as a
representative of a particular client (or as a representative of the coalition itself), they should clarify their role as appropri-ate
to avoid misleading others about the role in which they act.
 

F. Conflicts Issues

20. Public interest lawyers are governed by the same ethical rules regarding conflicts of interest among clients as private lawyers.
However, where alternative sources of legal representation are lacking, lawyers should consider ways to resolve conflicts
through disclosure and informed consent, insofar as permitted by the ethics rules.

RECOMMENDATIONS                                                                                   67  FORDHAM LAW REVIEW  1759 (1999)
 

21. In addition to "formal" conflicts of interest among clients, public interest lawyers may experience tensions between the
interests of an individual client or group of clients, and the in-terests of other members of the client community or the goals
of the lawyer's organization. Potential for such tensions should be considered in the case selection process. However,
once an attorney-client relationship has been formed, lawyers must fulfill their ethical duties of loyalty and zealous represen-tation
even if such tensions emerge.

22. Lawyers should raise these issues in client counseling (i. e., dis-cuss with clients how pursuing their interests may harm other
people). If the client agrees after being advised of potential harm to other persons, the lawyer may pursue advocacy strate-gies
that seek to reconcile the client's interests with those of other unrepresented community members. If the client does
not consent, however, the lawyer must pursue the client's in-terests even if other community members are harmed.

23. Similar tensions may arise when a lawyer undertakes represen-tation that later appears inconsistent with an efficient alloca-tion
of advocacy resources (e. g., when the only remaining issue in a case involves retroactive benefits for a small number of
class members, or when an appeal is possible but unlikely to succeed). The decision whether to withdraw from ongoing
representation involves different considerations from the deci-sion whether to undertake representation initially. Lawyers
must comply with ethical restrictions on withdrawal from pending cases, and, more broadly, should respect clients' rea-sonable
expectations of ongoing advocacy.

24. On the other hand, entering into a lawyer-client relationship should not require the lawyer to pursue every available rem-edy
for the client for an unlimited time. Retainer agreements should clearly state the scope of representation agreed upon at
the outset. Further study should be conducted on the question whether it is permissible to terminate the lawyer-client rela-tionship
in circumstances where the potential benefits of con-tinued representation are greatly outweighed by the costs,
risks of harmful results (e. g., making "bad law" on appeal), or by impairment of the lawyer's ability to serve other clients.
 
 

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