ABSTRACT

The American Bar Association has a rule entitled "Professional Independence of a Lawyer" but it concerns independence from nonclients, dealing with fee-splitting with nonlawyers, partnerships with nonlawyers, payment of fees by nonclients, and ownership by nonlawyers of stock in law firms. Although ovocats conceive their independence from clients in an unusual way, lawyers in other countries also prize that kind of independence. As envisaged in France independence from clients goes well beyond anything proposed in the United States or England, and reflects a radically different lawyer ideal. English barristers diverge from the French pattern in another way: unlike avocats, lawyers in the United States, or indeed solicitors, barristers may not reject clients willing to pay except for conflict of interest or lack of time or knowledge. The disdain for commerce that avocats expressed by spurning fee suits, barristers implemented through the system of self-segregation.