“All Law Schools Are Free”: An outsider hits the nail on the head

Old Guy stumbled upon a ten-year-old criticism of the law school scam. Although written by an outsider (specifically a psychiatrist), it shows real insight into what was wrong with law school in 2011—and what is still wrong with it today.

Long-time anti-scam warriors will be familiar with an old article in The New York Times that used as its chief example Michael Wallerstein, "a tall, sandy-haired, 27-year-old radiating a kind of surfer-dude serenity". Wallerstein borrowed a quarter of a million dollars to attend now-defunct über-toilet Thomas Jefferson while indulging in high living that included a fancy apartment—he nearly used his borrowed funds for the downpayment on a $350k condo—and trips to Europe for "study". After graduation, he couldn't find work other than temporary document review under a manager who likewise had failed to thrive ("I was 32 when I graduated, and at 32 you’re washed up in this field"). He couldn't pay the interest on his loans, never mind the principal. His fiancée was if anything even more oblivious, hoping that he wouldn't "wind up in one of those time-gobbling corporate law jobs" that he would never get, all because "[w]e like hanging out together". (While he stiffed his creditors, somehow he and his brainless bit of stuff appear to have found the money for a "Boho-Chic Wedding", whatever that means.) Yet Wallerstein was "one of law schools’ satisfied customers" on account of the "prestige" of nominally being a lawyer.

"Do you hate law grads yet?" asked our psychiatrist. Yes, we do. Even those of us who are law grads ourselves. And Wallerstein is particularly odious. The psychiatrist called him an "intelligent but entitled douchebag". I disagree with the "intelligent" part, but the rest is true in spades.

The psychiatrist ripped into the garbage-purveyors at You Ass News and the scamsters who manipulate the worthless "rankings" for status and profit, but also exposed the plight of graduates who find themselves all but indistinguishable from the rest because they too are not meaningfully assessed:

Law students had no real measure of their status as an applicant; no reliable descriptor of what kind of a school they went to (short of branding); and no reliable measure of their performance there.  "What do you mean I can't get hired?"  They think to themselves,  "amn't I bright? Hard working? Fluent in legal theory?"  And the employers respond, "how the hell would we know that?"

Back to the douchebag Wallerstein and his coveted "prestige" of being a document-review monkey masquerading as a lawyer:

I don't doubt for a moment he sincerely believes he is a lawyer, because lawyer for him isn't a profession or even a job, it's a label, a code word for a kind of intellectualism he wants for himself.  As long as "all of my friends see me as..." it was well worth the cost.  He didn't study to become an attorney, he bought a back-up identity.

It's worth asking why Wallerstein chose a JD as a back-up identity, and not an MD or a PhD.  Can we agree it was easier?  Why not an MBA?  Because an MBA is for something else; a law degree is a brand in itself.  You can get an MBA and still be nothing unless you find a job.  Get a law degree, you're always a lawyer.

That may be correct (with one slight change: one has to maintain a license in order to be a lawyer). An undeserved intellectual cachet attaches to the JD. Lemmings from Maine to California are told that "you can do anything with a law degree". The magical "million-dollar" JD supposedly sets one head and shoulders above the generality. An MBA is nothing without an overpaid corporate job in so-called management, but a JD is thought to represent quality whether its bearer works in the field of law or not. Perhaps there was something to that sixty or seventy years ago, but how much intellectual superiority can the JD connote in a day—a very bleak day—when über-toilets raffle off "scholarships" to people who haven't even applied for admission?

On the prestige of a law degree:

In actuality, law school is utterly useless. The only thing that was useful was the writing class, which basically taught you how to argue thoroughly but efficiently on paper.

That overstates the outcome of the writing class. The few people who come out able to argue thoroughly but efficiently on paper were able to do so before law school. That said, "utterly useless" isn't wide of the mark. Certainly law school, pretensions aside, does not teach anyone "to think like a lawyer"; it doesn't even impart much knowledge of law.

Continuing:

I go through this to show you that law school, while it attracts people wanting to practice law,  also attracts college kids who are bright but emotionally adrift.  They don't know what they want-- besides a mental image of a lifestyle-- and they don't know who they are-- besides a mental image of an identity.  A three year law program is a great way to postpone reality and still have something to show for yourself.  

Again, law school also attracts plenty of people who are not bright. But this psychiatrist has put a finger on an important element of the law-school scam: just like an undergraduate program, it's an extension of high school. Thousands of lemmings leap into law school without intending to practice law; many others entertain fantasies of being paid six figures for saving dolphins or hobnobbing at cocktail receptions in Vienna. These and many others go to law school "to postpone reality" while collecting a faux-prestigious JD at the end (unless they fail out, as many do).

Lemmings can afford the frivolous venture for one simple reason:

[B]ecause all law schools are free.  Read it again.  All law schools are free.

Not after you graduate, of course, but right now.  Law schools can charge anything they want because everyone has enough money to pay for it- today.  As long as there are guaranteed government loans available for this, there is no economic incentive to lower the costs.  And as long as the price is zero, demand will always be infinity.

If it was true supply and demand, #1 ranked Harvard and #100 ranked Hofstra wouldn't have the same tuition.  But they do, the same as stupid Washington University, which is so stupid it's in Missouri.  "It's underrated."  Bite me.  Are we saying that Hofstra's worth the same money as Harvard?  That people would pay anything to go to Hofstra?  No, they don't have to pay anything to go to Hofstra.  That's the point.

The psychiatrist correctly excoriates scam-professor Steven Greenberger for proposing to address the high cost of law school through a warning like those put on packages of cigarettes. That kind of warning, which the scamsters haven't given even once in the many years since Greenberger made his scam-serving suggestion, would afford a handy to excuse to the scamsters while failing to deter significant numbers of lemmings. 

I don't agree that supply and demand would solve the problem. Even without student loans, Hofstra could charge high rates because there is no real competition: the choice is not between Hofstra and Harvard; it is between Hofstra and nothing. Nevertheless, I do agree that non-dischargeable student loans should not be available for law school, at least in the current free-for-all of arbitrarily large amounts for anyone whom some goddamn über-toilet choo$e$ to admit. Those who worship at the altar of free markets—Old Guy certainly isn't among the devout—should demand that the loans be dischargeable in bankruptcy. As things stand, federally guaranteed student loans underpin the contemptible and pernicious hackademic–industrial complex.

The Law-School Scam is just one ugly part of the Degree Scam

The Law-School Scam, exhaustively discussed by your dutiful servants here at OTLSS, is only one small part—a particularly ugly one, I admit—of the Degree Scam. To understand the Degree Scam, we need to review a bit of history. So gather around Old Guy, boys and girls, and let him tell you a story.

For most of the first half of the twentieth century, few children in the US went on to high school. Many did not finish elementary school. Black, Latino, Indigenous, and rural white people were especially unlikely to attend school for more than a few years, if that.

By World War II, high school was common in most places, though by no means all—for white people, that is. Black people in many areas—not just the Southeast—were still deprived of high school or at best were sidelined into "seg" dumping grounds. Much the same was true of other racialized groups; indeed, it is still more or less true today. Of course, with so few students going to high school, university degrees were rare.

The end of the war marked the beginning of a distinctive generation, the baby boomers, so called because of a spike in the birth rate that extended from 1946 almost until the mid-sixties. The baby boomers profited handsomely from the economic upswing that followed the war—especially in the US, which, unlike much of the rest of the world, emerged practically unscathed. The French call the period from 1945 to the early 1970s the thirty glorious years (les trente glorieuses), and for good reason, because it was unusually prosperous. Simply by chronological accident, the baby boomers reaped the fruits of cheap housing, cheap goods, high wages, rapid growth, nearly full employment (at least among white men, and increasingly among white women and some racialized populations), abundant opportunities. The baby boomers tend to credit themselves for what was really nothing but dumb luck.

As I mentioned, few people in the US went to university. That changed with the baby boomers' cohort. Since most baby boomers had attended high school (unlike the generations before them), they were admissible in principle to university. Various social changes drove many of them to enroll for a bachelor's degree in the 1970s, including the civil-rights movement (which increased blue-collar employment for Black men while also displacing many white men, thereby leading the latter to look into other options) and the fizzling out of les trente glorieuses.

University was so cheap in the 1970s that a baby boomer could work during the summer at some low-paying job—grocery clerk, telephone operator, whatever—and save enough money to cover tuition for the entire following year. A degree back then set a baby boomer apart, precisely because degrees were so uncommon. Many down-at-heel white people and even some racialized people were able to get good jobs in engineering, law, business, teaching, other domains. But even blue-collar employment, at least for able-bodied men, still paid so well that a factory worker who had never finished high school could typically afford a house, a car, and various other trappings of comfortable life, all while accumulating a defined-benefit pension and enjoying other valuable benefits.

Things changed rapidly for the worse in the early 1980s, which is why the idiotic far right nowadays talks of "making America great again". Cushy blue-collar jobs were drying up while decadent white yuppies blew everything that they had and more on high living. Old Guy's generation, namely Generation X, were urged to finish high school, because prospects for dropouts were rapidly deteriorating. Old Guy remembers hearing in the late 1970s that soon one the job of garbage collector would require a high-school diploma. His was the first generation in living memory that made less money than the one before.

Just a few years later, when Old Guy did finish high school, Generation X was being told to go on to university, as a high-school diploma was worth next to nothing. And the universities needed lakes of young blood on which to feed their bloated staffs of baby boomers. Thus Generation X was herded into universities, which happily instituted remedial programs for the hordes of "students" unable to read their high-school diplomas. By then, however, university was no longer cheap; nobody could pay for it with the money saved from bagging groceries the prior summer. It was terribly expensive, and those of us with no trust fund or Daddy Warbucks had to borrow five-figure sums at high interest in order to pay for it—without access to bankruptcy, a cherished tactic of baby-boomer yuppies eager to rid themselves of responsibility for their irresponsibility.

Generation X finished university with poor prospects. The few jobs to be found were often temporary, short-term endeavors. The word pension sounded obsolete. When everyone and her pet gerbil had a bachelor's degree, the things were all but worthless. How else to distinguish oneself but with a master's degree? (The baby boomers themselves had just come out of their fad of pursuing an MBA, often at an employer's expense. But an MBA or any other degree loses its prestige when everyone in town has a fistful of them.)

Naturally, the Degree Scam, already well under way, was delighted to expand the offerings. Sign up for a Master's of Fine Arts, a Master's of Creative Writing, a Master's of This, a Master's of That! And of course law school is the all-purpose solution, since You Can Do Anything with a Law Degree (cue jaunty music from the Roaring Twenties). So law schools spread like kudzu to the point that you could hardly throw a brick without breaking the office window of some fat-assed boomer pig who wolfs down red-velvet cupcakes while being fanned by her rented slaves on a package tour in Kenya or some born-with-a-silver-spoon-up-my-ass princess who oppresses those with the temerity to criticize her scholarshit about the Open Road. Insidiously, the boomer scamsters touted their extremely costly offerings—funded with non-dischargeable federally guaranteed student loans at high interest rates—as opportunities for racialized and other groups on the receiving end of discrimination, without drawing attention to the fact that a bunch of mostly white, upper-class scamsters were lining their pockets with the proceeds of this allegedly eleemosynary campaign.

Generation X was royally fucked by the baby boomers, but it must be said that Generation X was also the last generation for which university made any financial sense at all (just barely, in Old Guy's case). Conventional Wisdom™ dispensed by the boomers, who fancy themselves the fount of all knowledge, treats "education" as an "investment". Careful readers will note the propagandistic bait-and-switch ploy that equates education (properly understood as self-cultivation) with institutional dispensations (degrees issued by universities) and investment (placement of money for an anticipated gain) with expenditure (payment of whatever monstrous amount the universities demand). (On the subject of "investment", note politicians' tendency to speak of investments rather than expenditures. "We are investing $1 billion in our armed forces." No, you are spending—squandering—that money.) If going to university were truly an investment, we'd expect to see an analysis of the expected gains and the risks. Yet we never see one. Instead, paying whatever the universities charge is an "investment", and that's the end of the matter.

What worked for the baby boomers, however, does not work today. The baby boomers paid pocket change for their degrees and got good jobs. Hell, baby boomers without a degree, without even a high-school diploma, were better off than most of today's young graduates of law school, even before we take student loans into account. So tell the baby boomers to stick their Conventional Wisdom™ up their ass. Don't fall for it.

It is difficult to encourage independent thought in the anti-intellectual US, but Old Guy is going to try. Consider that your effort to break into the legal "profession" would require at least seven years of university, not to mention preparation for one or more bar exams. During that time, your earned income is likely to be very low. Instead of going for a mythological career in law, you could get a job right after high school, live cheaply, save much of your income, invest in index-linked ETFs with low managerial fees, and be well on your way to an early retirement while some dolt of your age is still struggling with the formation of contracts over at Cooley. Or you could go to trade school, work as a paid apprentice, and be fully licensed around the time that dolt first showed up for classes in a Cooley sweatshirt. By the time the Cooleyite in the polyester-covered mortarboard was applying for food stamps and receiving bills for student loans well into the six figures, you'd have a respectable nest egg, and almost certainly far better prospects of income for the rest of your days.

Knowing full well that few of his readers will perform the exercise described above, Old Guy will reduce his recommendations to a form that will fit on an index card, if not a bumper sticker:

1) Consider university if you are going into medicine or nursing AND can succeed AND have figured out how you are going to pay for it AND have a serious Plan B.

2) Go ahead and attend university if you have the money to blow on it AND don't need to earn an income with the anticipated degree.

3) Otherwise, DO NOT GO TO UNIVERSITY.

If you've already finished university and are now contemplating law school, the advice is the same, except that you can drop item (1).

Which law schools are worth attending? Part II

Just over six years ago, Old Guy posted his first article here to answer an important question: which law schools are worth attending? Using a simple but reasonable model and the data supplied by our friends at Law School Transparency, he concluded that 13 schools—Berkeley, Columbia, Chicago, Cornell, Duke, Harvard, Michigan, Northwestern, NYU, Penn, Stanford, Virginia, Yale—were "the only ones that anyone not independently wealthy should consider". Just maybe the total could be raised to 16 by including three marginal schools that people paying little or nothing might consider as long as they understood that "they [were] taking a big risk".

This recent report by Andrew Gillen of the Texas Public Policy Foundation revisits Old Guy's question. Pointedly entitled "Objection! Law schools can be hazardous to students' financial health", the report assessed law schools' performance and relative value by applying "a debt-to-earnings test called Gainful Employment Equivalent (GEE)" (at 1) to data from the US Department of Education. Of the 218 law schools (not all accredited), 168 had publicly available data; the others were so small that the Department of Education concealed their data so as to protect the privacy of students and graduates (at 2).

How many schools met Gillen's standard? Exactly as many as Old Guy cited in his more generous estimate: "of the programs with data, only 16 (10%) law schools pass GEE, with another 30 (18%) on probation. A shocking 122 (73%) law school programs fail GEE. Thus, almost three quarters of law school programs leave their typical student borrower with a debt so high relative to their post-graduation earnings that they are unlikely to be able to afford to make their student loan payments" (at 2).

The following are the schools that passed GEE (at 5–9):

• Berkeley
• Boston College
• Chicago
• Columbia
• Connecticut
• Harvard
• Iowa
• Michigan
• Northwestern
• NYU
• Penn
• Stanford
• Texas
• Vanderbilt
• Virginia
• Washington University in St Louis

This list will surprise the esteemed readers of Outside the Law School Scam for including several mediocre institutions while omitting some well-regarded ones. Most of the mediocrities barely scraped through. As for the missing élite institutions, please note that Cornell, Duke, and Yale were omitted for want of data, probably because relatively few of their graduates took out student loans.

Since Gillen's data come from 2015–16, the report amusingly includes the über-toilets that have shut down since that academic year, the first of which was Indiana Tech.

Gillen aptly observes that "only 15% of law school graduates attended a program that passed GEE. Another 17% attended a program on probation [by the Department of Education]. An astounding 68% of law school graduates attended a program thath fails GEE, indicating that the typical graduate ho borrowed will be unable to afford their student loan payments. In other words, for every law school graduate from a passing program, there was one graduate from a program on probation, and four graduates from a failing program" (at 2).

A glance at the five-page list of law schools shows that debt, where reported, is typically well past $100k. The following had median debt in excess of $185k (and remember that this was five years ago): Florida Coastal ($198,655), Whittier ($196,008), Thomas Jefferson ($195,892), Southwestern ($193,653), Arizona Summit ($188,191), Charlotte ($188,985). Small wonder that four of these six are defunct (well, Thomas Jefferson still operates, just without ABA accreditation) and that at least one of the others has one foot in the grave. In the department of earnings, the long-reported bimodal pattern stands out in sharp relief: 7 schools have median earnings above $150k, 19 have median earnings below $40k, and most of the rest seem to be close to the lower end (perhaps below $55k).

Unsurprisingly, high debt often accompanies low earnings. Of the six mentioned above where median debt exceeds $185k, the highest median earnings were $45,200 (at Arizona Summit, in case you care to know). Arithmetic could not have informed many decisions to enroll at über-toilets where the median debt is more than four times the median earnings.

Old Guy is grateful for Gillen's effort but wishes to point out that median earnings at the time of graduation are unlikely to last: even those few who get jobs paying $150k or more are likely to lose those jobs within three or four years—and find themselves unable to make comparable money again. Borrowing $183,857 to go to NYU, or $129,030 for Vanderbilt, is likely to turn out badly when the income that supports the high payments proves temporary. In addition, the median figures may be misleading. Harvard's median debt of $133,617 may appear manageable, but remember than many students get the entire cost paid from a trust fund or a parent's bank account and thus do not borrow anything, while many others borrow all or nearly all of the cost and thus run up a debt in the vicinity of $362k at graduation (figure from Law School Transparency). Debt around $362k is unaffordable even on a median income of $158,200. Similarly, median earnings often conceal a great deal of variation—especially at the bottom end, with quite a few graduates being unemployed or making little money at a temporary, part-time, or non-legal job.

Old Guy therefore stands by his original list. Perhaps Vanderbilt can be appropriately added (it was one of the three marginal candidates on Old Guy's extended list of sixteen schools), and Old Guy is willing to entertain arguments on behalf of Boston College, Connecticut, Iowa, Texas, and Washington U, especially for applicants receiving a full scholarship. Gillen and Old Guy differ on three or four schools (presumably he would accept Cornell, Duke, and Yale even though their data are not public), which is to say that they substantially agree—and that should come as no surprise, since their analyses are based on relevant facts and logic, not on arbitrary "rankings" by some long-defunct magazine or propaganda from admissions offices or pie-in-the-sky fantasies by lemmings who expect to achieve a financially successful career even though most new JDs today do not.

Although we can argue about the merits of individual law schools, the key point is that only about one school in twelve works out adequately for the median student when we generously and unrealistically assume that income shortly after graduation will not decline until the student loans are paid off. Anyone considering a law school can start with Old Guy's list or Gillen's (the latter should be supplemented with Cornell, Duke, and Yale) but must perform the financial analysis in light of individual circumstances. Perhaps UCLA on a full scholarship wouldn't be a horrible idea for you even though Harvard with no scholarship—and no trust fund or benefactor—would be. 

Gillen's final paragraph (at 4) can appropriately end this article as well: "Among the riskiest of the largest academic fields is law. Seventy-three percent of law schools fail these debt-to-earnings tests, and 68% of law school graduates attended a program that fails. Students should think twice about enrolling in one of these failing programs, and policymakers should stop providing taxpayer subsidies for them."

Three million readers

As the column to the right shows, OTLSS has been visited more than three million times. Thanks to our many allies in the battle against the law-school scam.

People have pointed out that OTLSS appears to be the last of the scam-blogs and that we have been publishing less and less. Old Guy does what he can to sustain the last major source of information on the law-school scam. Times have been difficult for most of us (Old Guy by no means excluded), and the dearth of news on law schools—other than a few recent closures—has contributed to a decline in our anti-scam journalism. We remain vigilant, however, and shall continue to provide the news, analysis, and activism that you have rightly come to expect.

Projects for the new year include a fresh analysis showing which schools may be worth attending and a summary of the data from the ABA's 509 disclosures, which were just released.

We at OTLSS thank you for your continued support and wish you happy and scam-free holidays.

Cooley dumped by Western Michigan University

In an apparent bid to lift itself out of the bottom of the shitter, Cooley affiliated itself with Western Michigan University in 2014. Recently Western Michigan decided to dissolve this ill-advised marriage in November 2023.

Western Michigan was gracious enough to utter a few pieties about returning to its core mission (Cooley was specifically identified as "a distraction"), and it conveniently blamed COVID-19 for the downfall of its bonds to that laughing-stock of law schools. Astute observers of the law-school scam, however, will perceive a different motive behind the propaganda. However much the partnership may have improved Cooley's reputation, it only tarnished Western Michigan's. Cooley indeed has been closing campuses, and it also is at risk of losing its accreditation. How could Western Michigan have gained from that deal? 

Recent months have seen little news here at OTLSS. Stay tuned, however, for a report on the celebrated OTLSS question of whether law school is worth attending at all.

Cooley closes another campus

Cooley, which once rated itself the second best law school in the US, is closing another campus. The one in Grand Rapids will be gone at the end of the month.

Allegedly the closure of one more campus places Cooley "in a position of strength". If it is so damn strong, why has it closed three campuses in the past few years? Cooley's president blamed COVID-19 and changes in the demand for law degrees, without ever mentioning the utter shittiness of his über-toilet. Yale, which Cooley left in the dust on the widely ridiculed Cooley rankings, managed to increase its first-year enrollment by 4% in precisely the same context. How is it that Cooley shrank by 46%? Might it be that something other than external factors contributed significantly to Cooley's fate?

Cooley has recently failed to meet one of the ABA's standards for maintaining accreditation. In practice, the ABA can be expected to extend the time for achieving compliance, which is a polite way of saying that it will not meaningfully enforce its own so-called standards.

The number of law schools that have closed in the past five years or so now stands at thirteen:

Cooley (one campus)
Hamline or Mitchell*
Indiana Tech
Whittier
Charlotte
Savannah
Valpo
Arizona Summit
Cooley (a second campus)
Thomas Jefferson†
La Verne†
Concordia
Cooley (a third campus)

Which school will be the next to close? Florida Coastal and Appalachian are strong contenders. Not far behind are Mississippi College, Golden Gate, Ohio Northern, Faulkner, Western State, District of Columbia, John Marshall, Vermont, and a number of others. Step right up and place your bets!

NOTES:

* Hamline and Mitchell merged. Which one closed is difficult to say: arguments can be made on each side. Anyway, the two schools became one, so effectively one of the two closed. The merger was a closure in dignified guise.

† Forfeited ABA accreditation and continued with only the accreditation offered by California.

Concordia University's law school closes after all

Only four months ago, Concordia University's law school in Boise, Idaho, announced that it would be acquired by Concordia University in St Paul, Minnesota. Now the deal has fallen through, and Concordia's law school will not be opening this autumn after all. Count one more law school as dead.

Although the institutions involved decline to provide details, it seems that a $300M lawsuit against the parent university (based or formerly based in Portland, Oregon) resulted in liens that blocked the transfer of the law school's assets. The parent university recently announced its own closure, but of course its assets may still have to answer that nine-figure claim and possibly other claims as well.

Anyone interested in keeping Concordia's law school alive might consider raising money with which to settle or at least secure that claim. A bake sale should do the trick: just make a dollar's profit by selling a carrot cake or a plate of brownies (or red-velvet cupcakes for Lisa Tucker McElroy) to every person in the US! We have helpfully offered numerous other ideas for bailing a law school out. Indiana Tech never tried them, but maybe Concordia can succeed.

Our dear friends at Law School Transparency have already stricken Concordia from their database, so I cannot provide a link to their data. But the entering class of 2019 had only 59 students, and Concordia was definitely deep in über-toilet territory. It achieved ABA accreditation just last year.

What shall become of those 145 Concordians who have been left high and dry? The U of Idaho has tentatively offered to take them in, one and all, if only it can find a place for them. Options include moving them all to the university's own law school (far away in Moscow, Idaho) and cobbling together a temporary place for them at the university's facilities in Boise. Expect plenty of other toilet institutions to come begging for the newly scuppered Concordians, much as the U of North Dakota scooped up much of the jetsam of Arizona Summit when the latter went tits up days before classes were supposed to start.

Twelve law schools have closed in the past few years (if we count campuses of the Cooley chain as separate law schools) or at least forfeited their ABA accreditation in lieu of closing for good:

Cooley (one campus)
Hamline or Mitchell*
Indiana Tech
Whittier
Charlotte
Savannah
Valpo
Arizona Summit
Cooley (another campus)
Thomas Jefferson†
La Verne†
Concordia

Which will be next?


NOTES:

* Hamline and Mitchell merged. Which one closed is difficult to say: arguments can be made on each side. Anyway, the two schools became one, so effectively one of the two closed. The merger was a closure in dignified guise.

† Forfeited ABA accreditation and continued with only the accreditation offered by California.