## Facts

- Gregory C. Osakwe earned an LL.B. from the University of Nigeria in 1990.
- He attended the Nigerian Law School in Abuja, passed the Nigerian bar examination, and was called to the bar of the Federal Republic of Nigeria in December 1990.
- Osakwe later completed additional legal training at Hugh Wooding Law School and was admitted to practice in Trinidad and Tobago in 1996.
- After moving to Connecticut, he earned an LL.M. from the University of Connecticut School of Law in May 2001.
- He was permitted to sit for and passed the New York bar examination and was admitted to practice in New York in February 2003.
- He was admitted to practice before the U.S. District Court for the District of Connecticut in June 2003 and practiced federal immigration law in Connecticut and New York.
- In June 2004, Osakwe applied to sit for the Massachusetts bar examination under S.J.C. Rule 3:01, § 3.4, which permits applicants without an ABA-accredited J.D. to sit if they have a “legal education equivalent, in the Board’s opinion, to that provided” by ABA-approved law schools.
- The Massachusetts Board of Bar Examiners concluded that Osakwe lacked the necessary academic qualifications under the rule and informed him he would need to obtain a J.D. degree before being allowed to sit for the examination.
- Osakwe’s effort to obtain administrative review was dismissed. He then petitioned a single justice of the Supreme Judicial Court, who dismissed the petition and denied reconsideration.
- Osakwe appealed to the full Supreme Judicial Court.

## Issues

1. Under S.J.C. Rule 3:01, § 3.4, did Osakwe’s combined foreign legal education, U.S. LL.M., and U.S. bar admissions/practice qualify as a legal education equivalent to that provided by ABA-approved law schools, entitling him to sit for the Massachusetts bar examination?

## Decision

- The Supreme Judicial Court reversed the single justice’s dismissal.
- The Court reviewed Osakwe’s educational and professional record and concluded that he possessed a legal education sufficient to satisfy S.J.C. Rule 3:01, § 3.4.
- The Court directed the Board of Bar Examiners to allow Osakwe to sit for the Massachusetts bar examination.

## Legal Principles

- S.J.C. Rule 3:01, § 3.4 allows an applicant without an ABA-accredited J.D. to sit for the Massachusetts bar examination if the applicant has obtained a legal education equivalent (as determined under the rule) to that provided by ABA-approved law schools.
- “Equivalency” turns on the substance of the applicant’s education and training, not on whether the applicant holds a J.D. by name.
- A foreign legal education from a common-law system, together with coursework comparable to the core curriculum taught at ABA-approved schools, may satisfy the rule’s educational component.
- Meaningful education in and familiarity with U.S. law—such as graduate legal study in the United States—supports a finding of equivalence.
- Admission to practice and actual practice in U.S. jurisdictions may be considered in evaluating whether an applicant’s background satisfies § 3.4.

## Conclusion

The Supreme Judicial Court held that Osakwe met S.J.C. Rule 3:01, § 3.4 because his common-law legal education abroad, further legal training, U.S. LL.M., and subsequent U.S. bar admissions and practice together amounted to an education equivalent to that provided by ABA-approved law schools, and it ordered the Board to permit him to sit for the Massachusetts bar examination.


Osakwe v. Board of Bar Examiners, 448 Mass. 85 (2006)