The Bar Exam: A List of Famous Failures

Yesterday we wrote about Paulina Bandy, that poor creature who failed the California bar exam thirteen times, before finally passing it on try #14. Her story seems to have freaked out some of you who are sitting for the bar exam later this month next week.
Relax. Take a deep breath. You won't wind up in a 365-square-foot shack in your mom's backyard. We think.
Chances are, you will pass. And even if you fail the bar once or twice, you're still not on your way towards Paulina Bandy-dom.
As it turns out, a number of well-known individuals -- some famous for their accomplishments in law, and others for different reasons -- didn't pass the bar on the first (or even second) try.
To get the ball rolling, here's a short list of a few bar exam failures. Check it out, after the jump.
Here they are (in alphabetical order). Please feel free to add more in the comments. Thanks.
Jerry Brown: Attorney General of California (and former California governor). Failed the California bar once before passing.
Hillary Clinton: Brilliant, delicious, and everyone should vote for her. Future president of the United States. Failed the D.C. bar exam in the 1970s, but passed the Arkansas bar -- where she went on to have a successful legal career, as a partner in the Rose Law Firm.
John F. Kennedy, Jr. (deceased): Highly attractive son of President John F. Kennedy. Failed the New York bar twice, before passing on the third try. Served as an assistant district attorney in New York from 1989 to 1993
Emily Pataki: Highly attractive daughter of former New York Governor George Pataki. Failed the New York bar the first time, but passed the second time.
(We thought she was an associate at the prestigious New York law firm of White & Case, but she's not on the firm website.)
Kathleen Sullivan: Former dean of Stanford law school, leading constitutional law scholar, and possible Supreme Court nominee (or Solicitor General pick) in a Democratic administration. Failed the California bar exam when she took it in July 2005. As explained by the Wall Street Journal:
Although she is licensed to practice law in New York and Massachusetts, Ms. Sullivan was taking the California exam for the first time after joining a Los Angeles-based firm [Quinn Emanuel -- hey, does she have an electrical engineering degree?] as an appellate specialist.
Sullivan passed when she took it again in February 2006.
Pete Wilson: Former California governor. Failed the California bar exam three times, before passing on his fourth try.
So relax. Even if you fail the bar exam a few times, you can still go on to have a successful career in law and/or politics.
Just don't go as far as Paulina Bandy. Keep your failures in the single digits, and you'll do just great!
Even top lawyers fail California bar exam [Wall Street Journal]










Comments
Lord I hope I pass... I'm so far behind! But don't wanna go through this again in February...
Posted by: Anonymous | July 17, 2007 11:08 AM
Richard M Daley, Mayor of Chicago, failed at least once (too lazy to look to see if it was more than once).
Posted by: Anonymous | July 17, 2007 11:12 AM
Emily is an associate at W&C NY.
Posted by: pondering | July 17, 2007 11:12 AM
Lat: bad edit. Your Pataki commentary cuts off mid-parenthetical.
Posted by: Anonymous | July 17, 2007 11:13 AM
Chicago Mayor Richard M Daley failed twice.
Ed Koch failed too and he went on to be mayor and more importantly the judge on the People's Court.
Posted by: Anonymous | July 17, 2007 11:14 AM
ok, Emily Pataki and JFK Jr. had famous dads. As did Daley
Posted by: Anonymous | July 17, 2007 11:16 AM
Must you post this kind of stuff the week before a lot of your readers take the bar. I come to ATL to get away from studying, not to slit my wrists.
Posted by: Anonymous | July 17, 2007 11:18 AM
As long as we're talking about mayors, the Honorable Antonio Villaraigosa (Mayor of Los Angeles) failed the bar exam not once, not twice, but FOUR times. He never passed.
Posted by: Angelino | July 17, 2007 11:19 AM
Mayor Antonio Villaraigosa has failed the California Bar 4 times, and has yet to pass.
Posted by: anon | July 17, 2007 11:19 AM
A word for all you taking the bar. Everyone who takes it thinks, at some point, that they are going to fail. Everyone. There's just too much information to cram in. New York and California are the worst. So if you think you are going to fail, don't go on all-night Red-Bull-and-Fruit-Pebbles bender trying to catch up. You'll get there, as long as you don't lose it.
Posted by: word of advice | July 17, 2007 11:20 AM
11:20 is right - your cocky friends are liars. Don't get psyched out. It's the worst thing you can do to yourself. You're never going to master everything - nobody does. It's the nature of the exam and it's okay. I never grasped secured transactions but, in the end, I just memorized the elements. We had a secured transactions essay question and I passed. Best of luck. You'll be fine!
Also, can everybody lay off of Emily Pataki? This girl never had the high profile JFK Jr. did. Granted, she never had a "The Hunk Flunks" headline, either, but I wouldn't wish public failure on my worst enemy.
Posted by: Anonymous | July 17, 2007 11:23 AM
I think Charlie Crist, governor of Florida, failed a few times
Posted by: anon | July 17, 2007 11:23 AM
Um, why take the DC bar at all?
Posted by: Anonymous | July 17, 2007 11:24 AM
Villaraigosa was apparently spending too much time cheating on his wife with that hottie news reporter in SoCal.
Posted by: Anonymous | July 17, 2007 11:26 AM
11:23(1) = George Pataki
Posted by: Anonymous | July 17, 2007 11:27 AM
don't forget the AG of Delaware.
Posted by: Anonymous | July 17, 2007 11:29 AM
I guess Hillary was much more proficient in trading commodities futures than taking the bar.
Posted by: Anonymous | July 17, 2007 11:29 AM
Harold Ford took the bar exam once, failed, and never went back.
Posted by: anon | July 17, 2007 11:31 AM
secured transactions has ELEMENTS!?!?
Posted by: donniewins | July 17, 2007 11:31 AM
In "Rainmaker", Danny DeVito's character had failed the Louisiana bar six times. Which dovetails nicely with real-life Louisiana politician Cleo Fields (former Gubenatorial candidate, leading candidate to take over for Congressman Bill Jefferson if he is convicted), who also failed six times, and the mayor of Baton Rouge, Kip Holden, who failed twice.
Posted by: Anonymous | July 17, 2007 11:31 AM
I guess Hillary was much more proficient in trading commodities futures than taking the bar.
Posted by: Anonymous | July 17, 2007 11:32 AM
11:24, the DC bar takes 6-8 months to get done once you're sworn in somewhere else. Some people have jobs after law school that require them to become a member of the DC bar ASAP. For those people, it makes sense.
Posted by: Anonymous | July 17, 2007 11:33 AM
Pat Robertson, another Yalie, failed the NY bar and never took it again.
http://www.patrobertson.com/SpiritualJourney/SomethingMissing.asp
Posted by: anon | July 17, 2007 11:33 AM
11:31(1)...Just to clarify, it is Jr.
Posted by: Anonymous | July 17, 2007 11:34 AM
For anyone who thinks listing the famous and intelligent people who have failed the helps us poor pathetic bar prep folks, think again. This just adds to the neurosis as it is clear that even smart, hard-working, successful law students can fail the bar. That pretty much makes me want to kill myself.
Thanks, Lat.
Posted by: Please God let me pass | July 17, 2007 11:34 AM
Since Ms. Pataki only passed in February, she has likely not been sworn in to the NY bar yet, and thus cannot be put on the firm's website.
11:24 - In the 1970s, DC did not have the blanket waive-in rules they have now.
Posted by: Anon | July 17, 2007 11:35 AM
NY to 190 would surely ease the pain of studying for next week!
Posted by: Anonymous | July 17, 2007 11:36 AM
What about Izabella St. James?
Posted by: anon | July 17, 2007 11:38 AM
Judge Greg Mathis! Abraham Lincoln! The list is endless!
Posted by: anonymous | July 17, 2007 11:41 AM
You COULD end up like this guy: http://sptimes.com/2006/01/22/Floridian/In_his_own_defense.shtml
Posted by: anonymous | July 17, 2007 11:43 AM
11:35: Can't you be on the website, as long as your bio has a "not yet admitted" or "admission pending" note on it?
(Hello, Maury Saiger!)
Posted by: Anonymous | July 17, 2007 11:43 AM
I like this quote from the linked WSJ article (about the noted constitutional scholar and the dean of Stanford LS who failed the CA bar exam):
“Ms. Sullivan, 50 years old, did not return phone and email messages seeking comment. Her firm said she wasn't reachable over the weekend because she was at a remote location.” Yea, like the edge of a cliff….
Posted by: Anonymous | July 17, 2007 11:45 AM
11:23 - clearly your enemies are not bad enough if you won't even wish public failure and shaming upon them.
Posted by: amused | July 17, 2007 11:48 AM
I don't know Emily Pataki, and I certainly don't wish her ill. So she failed once, big deal.
Seeing her picture though, let me say she is absolutely adorable.
Posted by: Anon | July 17, 2007 11:53 AM
Is she still at White & Case? She's not on their website.
By the way, this is the letter she sent out to the ENTIRE firm after she failed: http://blogs.wsj.com/law/2006/11/14/emily-patakis-email/
Posted by: anon | July 17, 2007 11:54 AM
Adorable...? She's friggin' hot!
Posted by: anon | July 17, 2007 11:55 AM
Looks like Lat passed the NY bar:
http://www.nylawyer.com/display.php/file=/exam/names/7993ip
(Darn. It would have been made for good schadenfreude if he hadn't.)
Posted by: Anonymous | July 17, 2007 11:57 AM
Did you guys catch the last paragraph of the article? The compton lawyer who failed the CA bar 47 times before finally passing.
You should run a piece on him Lat. He sounds like a real winner.
Posted by: Anonymous | July 17, 2007 12:01 PM
Antonio Villaraigosa failing 4 times isn't unusual -- he went to PCL.
Posted by: anon | July 17, 2007 12:06 PM
Compared to this guy, Bandy is a genius!
---
Ms. Sullivan is unlikely to need as many attempts as Maxcy Dean Filer, who may hold the California bar endurance record, having passed in 1991 after 47 unsuccessful tries. The Compton, Calif., man, who says he'll practice any kind of law that "comes through the door -- except probate and bankruptcy," says he always tried to psych himself up before taking the test by repeating, "I didn't fail the bar, the bar failed me."
---
Posted by: amused | July 17, 2007 12:09 PM
Luckily I passed and am now working. But while studying I was told that "no incoming associate at this firm has ever failed the bar." Talk about putting the pressure on. But seriously, I work at a large firm where there are easily over 50 people taking the bar each summer, I find it hard to believe that no one ever fails. But my question is, what do the large firms do with people that fail? Most firms let you start work before results, do they get a second chance? Do they have to work while studying again? Anyone have info???
Posted by: biglaw anon | July 17, 2007 12:10 PM
Usually law firms give you time off to study and take it again in February. If you fail a 2nd time, usually that's it.
Posted by: Anonymous | July 17, 2007 12:15 PM
I'm taking the bar this summer. My firm's policy is to keep you on through the February bar. If you fail twice, you're fired.
Posted by: Anonymous | July 17, 2007 12:17 PM
Certain commenters are missing the point re Emily Pataki. While I do believe that it's unfair for her failure to receive such a high degree of attention simply because her father is a prominent political figure – her ridiculously dumb decision to send a firm-wide email expressing her regrets and offering her apologies makes her fair game.
On a somewhat related note, I agree that she’s extraordinarily cute.
Posted by: Anonymous | July 17, 2007 12:19 PM
Plenty of people fail on a fluke--a bad day, a bad question, a bad lunch... It's time to start worrying when you don't pass the second time.
Lat--it might be time to make those taking the CA and NY bar feel better and post the July 2006 Guam results:
http://www.guamsupremecourt.com/BrdLawExam/images/July2006Results.PDF
Posted by: rex | July 17, 2007 12:21 PM
c'mon folks -- she's not "adorable" or "extremely cute." She's hot, plain and simple.
Posted by: anon | July 17, 2007 12:21 PM
c'mon folks -- she's not "adorable" or "extraordinarily cute." She's hot, plain and simple.
Posted by: anon | July 17, 2007 12:22 PM
Those studying for the bar - try not to think about the line you are on. On one side is a quagmire of debt which you will never be able to pay off (hey look, there's Bandy and she even passed!!!!11) and the historical respect of your peers. On the other side is a nice 160k income (possibly more if you're an EE) and the schadenfreude (at least those of you in NY) of knowing at least a few assholes who failed. In other words, don't look down.
And if you fail the bar, at least you don't have cancer (hopefully)!
Posted by: Anonymous | July 17, 2007 12:26 PM
no, she is cute. don't inflate her ego.
Posted by: Anonymous | July 17, 2007 12:28 PM
Assistant Prosecutor William P. Fisher, III, of Mercer County, New Jersey, failed the New Jersey Bar exam in February 2003.
Posted by: Anonymous | July 17, 2007 12:30 PM
Justice Cardoza - 6 times I think!
Posted by: NY Bar | July 17, 2007 12:31 PM
I wonder if that UGA student arrested in LA has access to his Barbri materials in the slammer?
Too bad solicitation of minors is not an MEE subject. He'd be golden.
Posted by: Anonymous | July 17, 2007 12:34 PM
Yeah, but none of those people had 6 figure student loans...
Sweet, chubby little baby Jesus...let me pass...amen dot com
Posted by: I'm generally not a religious man, but SAVE ME SUPERMAN | July 17, 2007 12:39 PM
11:18: Accord. Mr. Lat - please some more strip-teasing law students - or professors.
Posted by: Anonymous | July 17, 2007 12:42 PM
extraordinarily cute?!?!?
too much time around the office i suppose
Posted by: Anonymous | July 17, 2007 12:44 PM
Emily Pataki is Hot! Anyone know how tall she is?
Posted by: Emily is Hot | July 17, 2007 12:59 PM
EP's looks have been discussed THOROUGHLY in previous comments sections, such as http://www.abovethelaw.com/2007/05/congratulations_to_emily_patak_1.php#comments
Posted by: anon | July 17, 2007 12:59 PM
11:34 gets it. But God help you if you fail twice in biglaw.
"Oh, I see you were at Biglaw #1 for almost a year, why did you leave?"
"I failed the bar"
"Twice?"
"Twice."
"Oh. Thanks."
Posted by: Anonymous | July 17, 2007 01:00 PM
this guy never passed the bar and he won a really important case--and got his girlfriend an Oscar:
http://imdb.com/title/tt0104952/
Vinny Gambini: Well, I got a bullshit traffic ticket. I went to court, I got the cop on the stand, and I argued with him until he admitted he was wrong. And the judge, this Judge Malloy. All the while he's laughing and smiling. And then afterwards, he asks me to go to lunch with him. Then he says to me, "you know what? You'd be a good litigator." I didn't know what the hell he was talking about, I don't know what a litigator is. I never thought of becoming a lawyer. But this Judge Malloy, who's from Brooklyn, too? He did it, so all of a sudden, it seemed possible. So I went to law school.
Take heart, L2L!
Posted by: Anonymous | July 17, 2007 01:01 PM
anon (12:06): I find it humorous that you believe you can get away with the acronym PCL for People's College of Law and actually expect anyone on this site to know what the hell you are talking about.
Posted by: Anonymous | July 17, 2007 01:02 PM
Assistant Prosecutor William P. Fisher, III, of Mercer County, New Jersey, failed the New Jersey Bar exam in February 2003.
Was that his second failure? He would have initially taken it in July, correct?
Posted by: NJ Here | July 17, 2007 01:04 PM
Peoples College of Law? Wow. That's not even a fourth-tier school - more like Tier Z. I just love those unaccredited California J.D. mills.
http://peoplescollegeoflaw.edu/index.php?option=com_content&task=view&id=5&Itemid=4
Peoples College of Law was founded in 1974 as a non-profit, community-run law school to bring legal resources to under-represented communities and train legal advocates to secure progressive social change and justice in society.
We only admit those students who, regardless of their quite varied political, spiritual, cultural or social backgrounds, have demonstrated a commitment to progressive social change, have an awareness of working class issues and will employ the skills gained at the school to further these goals in their own way. Thus, if you want to be a prosecutor or a corporate attorney, don't waste our time applying; there are plenty of other schools out there for you!
Posted by: Anonymous | July 17, 2007 01:27 PM
Gerry Spence, "America's Finest Trial Lawyer" also failed the bar first time...in Wyoming I believe!
What I find interesting about fails like Pataki anf JFK Jr. is that they get into these oprestigious schools/firms...obviously with help from their family name.
But when they are an anonymous candidate with a #, they can't cut make the cut.
Posted by: in debt | July 17, 2007 01:30 PM
Gerry Spence, "America's Finest Trial Lawyer" also failed the bar first time...in Wyoming I believe!
What I find interesting about fails like Pataki anf JFK Jr. is that they get into these oprestigious schools/firms...obviously with help from their family name.
But when they are an anonymous candidate with a #, they can't make the cut.
Posted by: in debt | July 17, 2007 01:31 PM
11:31 -- Are you sure DeVito's character failed the Louisana bar? I thought the movie "Rainmaker" took place in Memphis Tennessee.
Posted by: Anonymous | July 17, 2007 01:46 PM
people fail the bar exam for two reasons: 1) lack of preparation; 2) freaking out.
if you've been reasonably diligent in preparing (i.e., paying reasonable attention in Bar/Bri and spending 3-4 hours/day, Mon-Fri), you've probably prepared enough. now just don't waste that prep by freaking out that you're not prepared enough.
after the first day, go out and have a freakin' beer or two (not twelve).
go to bed early. DO NOT sit in your room and study all night.
bottom line, if some of the folks i know passed...then you can pass as well.
(unless you're in Mass. and hate same-sex marriage. then you're screwed, apparently.)
Posted by: Anonymous | July 17, 2007 02:07 PM
To everyone who is taking the bar in a couple of weeks, you are all going to do great! Don't freak and think about getting points not about losing points.
Good Luck!
Posted by: Rilely | July 17, 2007 02:08 PM
I failed the bar while working for a Biglaw firm. I was also told no one failed the bar but discovered a secret (actually not so secret) club of associates who had failed. Misery loves company. October through February really sucked. Good luck to y'all this month.
Posted by: Anonymous | July 17, 2007 02:13 PM
Emily Pataki is NOT HOT. She is cute, at most, on her best day. Those of you who think she's hot are probably married to fatties. LOL.
Posted by: Richie Cunningham | July 17, 2007 02:34 PM
Dear 12:39,
You will pass. I just know it.
Love,
Superman
Posted by: Anonymous | July 17, 2007 02:34 PM
just apply the facts to the law - any law, make up law if necessary. use key words and remember to breathe - it's really not that difficult
Posted by: Anonymous | July 17, 2007 03:01 PM
White & Case doesn't list first-year associates on its website. Ms. Pataki may still be there.
Posted by: Anonymous | July 17, 2007 03:05 PM
A better alternative is to apply the law to the facts. Agree with making up law. I totally did that.
Posted by: Anonymous | July 17, 2007 03:07 PM
I once worked with a partner who was (and still is) a national icon in his specialty area. He later moved to CA and, despite having studied seriously for almost a year, failed the CA bar on his first try.
The bar tests your test-taking skillz as much as anything. If you're having a bad day, things may not always go so well.
Posted by: Anonymous | July 17, 2007 04:55 PM
3:01 and 3:07 must be "constitutional law" types ;)
Posted by: Anonymous | July 17, 2007 04:56 PM
2:07 has it right. Just don't freak out. It's a pass/fail exam, for chrissakes. You biglaw hires have aced most every standardized test you've ever taken, Harvard professors are not grading the essays, and you're not trying to get an "A". Passing shouldn't be that hard.
Over 25 years, I've known about that number of smart people who have failed the bar. (I know plenty of knuckleheads who failed, and plenty who passed on the first try, too.) I think every smart person who failed was overthinking the exam and was trying to prove he was brilliant. The bar exam is not a time for creativity, and trying to get the top grade is a waste of time. Just relax and aim for the middle of the pack or slightly better and you'll do fine.
Posted by: An Old Guy | July 17, 2007 07:07 PM
70 something comments and not one person has mentioned how Kathleen Sullivan looks like The Joker? Or did that get covered in an old post?
Posted by: Anonymous | July 18, 2007 01:03 AM
12:10: Somebody is lying to you. There is no way that nobody's even once failed the bar as an incoming associate. How could somebody know whether an incoming associate failed eight years ago? Seriously?
Posted by: Anonymous | July 18, 2007 12:20 PM
12:20: That was true for roughly the first 35 years of Wachtell Lipton's history (that nobody failed the bar as an incoming associate). Then it wasn't.
If even Wachtell has had a bar failure, I'd like to know which firm has never had one.
Posted by: Anonymous | July 19, 2007 06:08 PM
ONLY RETARDS AND KENNEDYS FAIL THE BAR.
Posted by: Anonymous | July 19, 2007 06:13 PM
William P. Fisher, III.
Posted by: Anonymous | July 24, 2007 10:34 AM
Dear [ ],
If I pass the NY Bar (First Attempt), I shall treat all members on this page to Creme Brulee!
Posted by: Anonymous | September 17, 2007 11:25 AM
For those who failed, I've made a list of the courses and tutors and books that are most recommended (for California at least):
http://unclezeb.blogspot.com/2007/11/hey-new-plan-pass-bar.html
Posted by: Zeb | November 28, 2007 02:01 AM
In my inspiring Nightingale-Conant audio program, THE LAW OF LARGE NUMBERS: HOW TO MAKE SUCCESS INEVITABLE, I retell the Maxcy Flier Story, originally broken in the LA Times.
This is a gent who failed the CA bar more than 40 times. Finally, he passed.
Bless him for his perseverence.
Thankfully, I passed it the first time.
Posted by: Dr. Gary S. Goodman | March 31, 2008 02:34 PM