PRO BONO: WHAT’S IN IT FOR LAW STUDENTS? THE STUDENTS’ PERSPECTIVE

In England and Wales, there is an increasing need for the provision of pro bono legal services. Law students may be a resource that can help fill the access to justice gap, whilst at university and onwards in their future careers. Whilst some students are intrinsically motivated towards altruistic behaviour, many are not. This article will consider what motivates students to undertake pro bono work whilst at law school. The article will explore the range of intrinsic and extrinsic motivating factors for student participation in pro bono programmes and consider how students can be encouraged to engage in such activities. The article will also consider whether exposure to pro bono experience can instil a public service ethos in students. In conclusion, the article will highlight experience as an influential factor in encouraging initial participation in pro bono work but also instilling a willingness to undertake pro bono work in the future. Introduction Many would argue that lawyers have a moral obligation to promote access to justice.2 It is also arguable that it is more than a moral obligation and is in fact a professional 1 Paul McKeown is an Associate Professor and the Director of the Student Law Office at Northumbria University, Newcastle upon Tyne, UK 2 For discussion on the role of lawyers in promoting access to justice, see Alice Woolley, ‘Imperfect Duty: Lawyers' Obligation to Foster Access to Justice’ (2008) 45:5 Alberta Law Review 107 Reviewed Article – Teaching and Learning in Clinic 44 obligation. The International Bar Association states that a lawyer is ‘an indispensable participant in the fair administration of justice.’3 Further, the United Nations also recognise this duty stating that ‘[l]awyers shall at all times maintain the honour and dignity of their profession as essential agents of the administration of justice.’4 Pro bono work may be considered as one of the methods for fulfilling this obligation.5 The Law Society of England and Wales reports that 63% of solicitors had conducted pro bono work (undefined6) at some point in their career.7 In 2015, 37% of solicitors reported that they had undertaken at least one hour of pro bono work (as defined by 3 International Bar Association, ‘International Principles on Conduct for the Legal Profession’ (2011) Available at file:///C:/Users/intel_000/Downloads/IBA_International_Principles_on_Conduct_for_the_legal_prof%2 0(4).pdf (accessed 10 October 2016) 4 OHCHR, ‘Basic Principles on the Role of Lawyers’ (1990) Available at http://www.ohchr.org/EN/ProfessionalInterest/Pages/RoleOfLawyers.aspx (accessed 10 October 2016) 5 See Debra D. Burke; George W. Mechling; James W. Pearce, ‘Mandatory Pro Bono: Cui Bono’ (1996) 25:4 Stetson Law Review 983; Deborah L. Rhode, ‘The Pro Bono Responsibilities of Lawyers and Law Students’ (2000) 27:2 William Mitchell Law Review 1201; Douglas L. Colbert, ‘Clinical Professors' Professional Responsibility: Preparing Law Students to Embrace Pro Bono’ (2011) 18:3 Georgetown Journal on Poverty Law and Policy 309 6 There is no universally accepted definition of ‘pro bono’. Evans highlights that ‘some lawyers consider work done for legal aid as pro bono because of the low level of remuneration, while other would also include matters in which that have substantially reduced, but not waived, their fees.’ (Adrian Evans, ‘Recognising the Conditional Nature of Pro Bono Motivation: Avoiding ‘Aspirational’ Compulsion and Developing an Appropriate Pro Bono Ethic in New Lawyers’ Available at http://www.nationalprobono.org.au/conference/pdf/2003_papers/3a_evans.pdf (accessed 23 September 2016)) 7 The Law Society of England and Wales, ‘The pro bono work of solicitors: PC Holder Survey 2015’ Available at http://www.lawsociety.org.uk/support-services/research-trends/solicitors-pro-bonowork-2015/ (accessed 23 September 2016) Reviewed Article – Teaching and Learning in Clinic 45 the Pro Bono Protocol8) in the preceding 12 months.9 This is a statistically significant decline on the 42% reported in the 2014 survey.10 Interestingly, 43% of solicitors who did not provide pro bono services suggested that there were not adequate opportunities to do so.11 Unfortunately, it is not clear what is meant by the lack of opportunities. This phrase could be interpreted to mean that solicitors did not believe there was a need for pro bono work which seems unlikely. An alternative interpretation for this phrase is that their firm did not support pro bono opportunities. Reasons cited for not undertaking pro bono work include transactional lawyers stating that they are not litigators, lack of time, cost to the firm in terms of time and money, lack of knowledge in relation to relevant laws affecting the indigent, and not knowing how to get involved in an area of pro bono that interests the individual.12 Some lawyers also express concern about a perceived conflict of interest.13 All these reasons have been recognised as barriers to solicitors undertaking pro bono in England and 8 The Pro Bono Protocol defines pro bono as ‘legal advice or representation provided by lawyers in the public interest including to individuals, charities and community groups who cannot afford to pay for that advice or representation and where public and alternative means of funding are not available.’ Further, ‘[l]egal work is pro bono legal work only if it is free to the client, without payment to the lawyer or law firm (regardless of the outcome) and provided voluntarily either by the lawyer or his or her firm.’ The Joint Pro Bono Protocol for Legal Work available at http://www.lawsociety.org.uk/Supportservices/Practice-management/Pro-bono/The-pro-bono-protocol/ (accessed 23 September 2016) 9 Ibid 10 Ibid 11 Ibid 12 Robert S. Gerber, ‘The Top Five Excuses for Not Doing Pro Bono Work, and Why They’re All Bad’ San Diego Daily Transcript 4 May 2005 Available at https://www.sheppardmullin.com/media/article/324_pub388.pdf (accessed 2 December 2016) 13 For example, see Elisabeth Wentworth, ‘Barriers to Pro Bono: Commercial Conflicts of Interest Reconsidered’ (2001) 19 Law in Context: A Socio-Legal Journal 166 Reviewed Article – Teaching and Learning in Clinic 46 Wales.14 Kutik however identifies one of the biggest barriers preventing pro bono work as ‘inertia’, explaining that lawyers ‘haven’t done it, [they] don’t know how to do it, and [they] won’t make the effort to learn.’15 Part 1 of the Legal Aid, Sentencing and Punishment of Offenders Act 2012 made significant cuts to the scope of legal aid in England and Wales as of 1 April 2013. As a consequence of these cuts, the number of unrepresented individuals in the family courts has increased. The National Audit Office reports an increase of 30% of family court cases in which neither party had legal representation in 2013-14 compared with 2012-13.16 The number of litigants in person appearing before the civil courts is also likely to have increased but there is not sufficient data in relation to this.17 The Master of the Rolls, Lord Dyson, in giving evidence to the House of Commons Justice Committee summed up the issue stating: “It is impossible to prove but it would be extraordinary, frankly, if there were not some cases that are decided adversely to a litigant in person which would have been decided the other way had that litigant in person been represented by a competent lawyer. It is inevitable.”18 14 LawWorks, ‘The Case for Pro Bono and Getting Started’ Available at file:///C:/Users/intel/Downloads/lawworks-pro-bono-mini-guide-the-case-for-pro-bono-and-gettingstarted.pdf (accessed 2 December 2016) 15 David A. Kutik, ‘Pro Bono: Why Bother’(2005) 22:7 GPSolo 44, 46 16 National Audit Office, ‘Implementing reforms to civil legal aid’ (2014) HC 784, Session 14-15 para. 1.25 Available at https://www.nao.org.uk/wp-content/uploads/2014/11/Implementing-reforms-tocivil-legal-aid1.pdf (accessed 23 September 2016) 17 Ibid, para. 1.24 18 House of Commons Justice Committee, ‘Eighth Report of Session 2014-15, 4 March 2015: Impact of the changes to civil legal aid under Part 1 of the Legal Aid, Sentencing and Punishment of Offenders Reviewed Article – Teaching and Learning in Clinic 47 A further issue, as noted by Steven Matthews of the Magistrates’ Association, was: “[individuals would be] put off making what may be a legitimate application because of the fact that they cannot get legal representation, have been unable to get advice and are put off by the forms and the process and so on.”19 It is difficult to quantify the numbers of individuals who decide not to pursue a legitimate legal claim because they are put off by the process. However, one Australian report estimated that not knowing what to do was cited as the reason for inaction in 30% of substantial civil legal problems not acted upon in 2008.20 A depressing picture is therefore emerging that at a time when demand, or at least a need, for pro bono legal services is increasing, the percentage of solicitors providing such services is decreasing. There is perhaps a need to consider what steps can be taken to increase the provision of pro bono services by the legal profession, or indeed whether the provision of pro bono should be increased. It has been argued that increasing the provision of pro bono encourages more legal aid cuts.21 However, these Act 2012’, para.137 Available at http://www.publications.parliament.uk/pa/cm201415/cmselect/cmjust/311/31102.htm (accessed 23 September 2016) 19 Ibid 20 Productivity Commission, ‘Access to Justice Arrangements’ Volume 1, 133 Available at http://www.pc.gov.au/inquiries/completed/access-justice/report/access-justice-volume1.pdf (accessed 29 June 2017) 21 For example, Michael Gove MP stated that ‘[w]hen it comes to investing in access to justice then it is clear to me that it is fairer to ask our most successful legal professionals to contribute a little more rather than taking more rather than taking more in tax from someone on the minimum wage.’ (The R


Introduction
Many would argue that lawyers have a moral obligation to promote access to justice. 2 It is also arguable that it is more than a moral obligation and is in fact a professional Reviewed Article -Teaching and Learning in Clinic 45 the Pro Bono Protocol 8 ) in the preceding 12 months. 9 This is a statistically significant decline on the 42% reported in the 2014 survey. 10 Interestingly, 43% of solicitors who did not provide pro bono services suggested that there were not adequate opportunities to do so. 11 Unfortunately, it is not clear what is meant by the lack of opportunities. This phrase could be interpreted to mean that solicitors did not believe there was a need for pro bono work which seems unlikely. An alternative interpretation for this phrase is that their firm did not support pro bono opportunities.
Reasons cited for not undertaking pro bono work include transactional lawyers stating that they are not litigators, lack of time, cost to the firm in terms of time and money, lack of knowledge in relation to relevant laws affecting the indigent, and not knowing how to get involved in an area of pro bono that interests the individual. 12 Some lawyers also express concern about a perceived conflict of interest. 13 All these reasons have been recognised as barriers to solicitors undertaking pro bono in England and 8 The Pro Bono Protocol defines pro bono as 'legal advice or representation provided by lawyers in the public interest including to individuals, charities and community groups who cannot afford to pay for that advice or representation and where public and alternative means of funding are not available.' Reviewed  Wales. 14 Kutik however identifies one of the biggest barriers preventing pro bono work as 'inertia', explaining that lawyers 'haven't done it, [they] don't know how to do it, and [they] won't make the effort to learn.' 15 Part 1 of the Legal Aid, Sentencing and Punishment of Offenders Act 2012 made significant cuts to the scope of legal aid in England and Wales as of 1 April 2013. As a consequence of these cuts, the number of unrepresented individuals in the family courts has increased. The National Audit Office reports an increase of 30% of family court cases in which neither party had legal representation in 2013-14 compared with 2012-13. 16 The number of litigants in person appearing before the civil courts is also likely to have increased but there is not sufficient data in relation to this. 17   It is difficult to quantify the numbers of individuals who decide not to pursue a legitimate legal claim because they are put off by the process. However, one Australian report estimated that not knowing what to do was cited as the reason for inaction in 30% of substantial civil legal problems not acted upon in 2008. 20 A depressing picture is therefore emerging that at a time when demand, or at least a need, for pro bono legal services is increasing, the percentage of solicitors providing such services is decreasing. There is perhaps a need to consider what steps can be taken to increase the provision of pro bono services by the legal profession, or indeed whether the provision of pro bono should be increased. It has been argued that increasing the provision of pro bono encourages more legal aid cuts. 21 However, these Act 2012', para.137 '[w]hen it comes to investing in access to justice then it is clear to me that it is fairer to ask our most successful legal professionals to contribute a little more rather than taking more rather than taking more in tax from someone on the minimum wage.' (The Rt Hon Michael Gove MP, 'What does a one nation justice policy look like? 23 June 2015 Available at https://www.gov.uk/government/speeches/what-does-a-one-nation-justice-policy-look-like (accessed 6 March 2017)). The Law Society of England and Wales maintains that 'pro bono is never a substitute for a properly funded system of legal aid, which needs skilled and experienced solicitors to provide Reviewed  issues are beyond the scope of this article which will focus upon the provision of pro bono services by law students.
The opportunities for students to undertake pro bono work at law school in the UK is good with at least 70% of all law schools offering pro bono opportunities to their students. 22 However, the evidence as to whether participation in pro bono programmes impacts upon a student's desire to undertake public service work in their future career is somewhat mixed. Some quantitative studies show little or no impact of clinical and pro bono programmes on students' desire to continue in pro bono/public service work in their future careers 23 whilst other studies suggest clinical expert legal advice to those who need it.' (The Law Society, 'Law Society statement on 'one nation justice system' 23 June 2015 Available at http://www.lawsociety.org.uk/news/press-releases/lawsociety-statement-on-one-nation-justice-system/ (accessed 6 March 2017)). See also Richard Abel, 'The  Reviewed Article -Teaching and Learning in Clinic 50 profession as a whole. From an ethical perspective, it has been argued that lawyers should undertake pro bono work because they are under a moral obligation to do so due to the privileged position the legal profession occupies in society. 27 Further, the motivating factors to undertake pro bono work may also be categorised as intrinsic or extrinsic. Intrinsic motivation can 'be defined as the doing an activity for its inherent satisfactions rather than for some separable consequence.' 28 Within the context of pro bono work, those who undertake such work due to their own 'personal characteristics, values and attitudes' 29 are intrinsically motivated. Extrinsic motivation 'is a construct that pertains whenever an activity is done in order to attain some separable outcome.' 30 If pro bono work is carried out to improve skills, enhance reputation or for some other reward, this is extrinsically motivated behaviour.
Alternatively, extrinsic motivation also encompasses behaviour motivated to avoid adverse consequences such as failing a programme of study if a pro bono requirement is mandated.
Extrinsic motivation has been criticised within education as: 'the more we reward people for doing something, the more likely they are to lose interest in whatever they had to do to get the reward. Within clinical legal education it has been argued that extrinsic motivation is 'less effective than, and may actually erode, intrinsic motivation.' 32 However, the fundamental problem is that 'intrinsic motivation will occur only for activities that hold intrinsic interest for an individual' 33 and therefore if a student has not previously experienced any form of voluntary work, they may hold no interest in the subject matter. If it is envisaged that law schools can instil a pro bono ethos in students then it is necessary to look beyond intrinsic and towards extrinsic motivation to attract and encourage students to participate and value the activity. Within the context of pro bono work, as identified earlier, students may be motivated to undertake such work for a variety of reasons. If students conduct mandatory pro bono work, or if the work is performed for assessment purposes, this is an example of external regulation and therefore the behaviour is perceived as controlled and lacking autonomy. However, if students engage in pro bono work because they recognise it will enhance their legal skills and improve their employability, they will identify with the value of the activity in relation to their own career objectives. If this is taken a step further, and through reflection, the value of pro bono work is brought into congruence with the student's other values and needs, then the pro bono work becomes assimilated and extrinsically motivated actions become autonomous and selfdetermined. Whilst the student may originally become exposed to pro bono work because it is mandated, or they wish to achieve a good grade, they may then experience the intrinsic value of the work in itself thus shifting their own values. For example, Quigley, drawing upon the work of Mezirow, posits that educators can utilise the phenomenon known as the 'disorientating moment' where the student is exposed to a disorientating or disturbing experience to transform their 'societal and and skills development…social justice was not the primary factor in their joining the volunteer activity.' 42 Nicolson, with reference to the Law Clinic at the University of Strathclyde, reports that 'self-centred reasons' ('To gain useful skills' and 'To put into practice theoretical knowledge') ranked higher than 'altruistic reasons' ('To help others' and 'To increase access to justice') as the reason for wanting to join the clinic. 43 However, those students 'who successfully completed the rigorous selection process seemed far more motivated by altruism in their decision to apply for membership compared to general Clinic applicants.' 44 This is probably explained by the fact students are selected on the basis of their commitment to social justice. 45 A study by Evans and Palermo into Australian lawyers' values considered pro bono in the context of professional responsibility. 46 Respondents were fairly equally divided as to whether they would agree to pursue a hypothetical pro bono case. 47 Of those respondents who would accept the pro bono case, access to justice was ranked as the most important motivating factor for taking on the case. However, this is and desires rather than mentioning any professional ethics'. 48 Other motivating factors determining how respondents would act include professional ambition (relating to the high profile nature of the case), employer loyalty (prioritise work for employer) and employment security (if they pursued a case against the will of their employer). 49 An interesting qualitative study was conduct by Behre into student motivations for pro bono following a tornado that devastated Tuscaloosa, Alabama in April 2011. 50 Whilst the circumstances of this study are very specific to the events at the time, the findings are useful. Behre reports that students were initially motivated through the 'need to help' and 'as a natural response to the shock of witnessing the tornado's destruction.' 51 '[S]urvivor guilt' and the 'need to give back to the community' were also cited as initial motivating factors to volunteering. 52 These motivating factors are intrinsic and 'as a direct response to witnessing a natural disaster.' 53 However, the student's rationale for their continued volunteer effort provides a good level of insight into student motivation. 'Meaningful volunteer experiences' such as 'personal, meaningful interaction with strangers', 54 organisation, 55 'opportunities for students to 48  in general were more concerned about how they could help people and less concerned about how the experience would benefit them.' 58 Finally, 'membership in the community' was also cited as a motivating factor for volunteering and the students 'valued the experiences they had connecting to people from diverse backgrounds.' 59

Methodology
Law students at Northumbria University were invited to enter an essay competition entitled 'Pro Bono: What's in it for law students?' The writer of the winning essay was awarded £125 voucher and the publication of their essay in the International Journal of Clinical Legal Education. 60 A representative of the International Journal of Clinical Legal Education adjudicated the competition. The students were not provided with any guidance as to the definition of 'pro bono' and therefore the essays reflect the students' own interpretation of this term. Further, the competition was open to all law students at Northumbria University regardless of whether they had any pro bono or clinical legal education experience. This is not a comparative study, merely a study considering the student perspective. The essays were analysed using NVivo software. 56 Ibid, 34 57 Ibid 58 Ibid 59 Ibid, 34-38 60 The decision was also taken to publish three High Commended essays at the conclusion of the competition. The writers of these essays also received a voucher to the value of £25.

57
The competition was arguably subjective; no criteria was set to determine the winning essay. This was deliberate to encourage honest views as to the motivating factor for undertaking pro bono work. The decision was taken to avoid pre-defined criteria as this may have resulted in essays becoming formulaic.

What the students say:
The essays reveal that the reasons students believe they should undertake pro bono work are varied.
The article will explore the various reasons and motivations for undertaking pro bono work in more detail below. Before these reasons and motivations are considered, I will first look at the students' understanding of pro bono.

Understanding Pro Bono
As stated above, there is no settled definition of pro bono work and this article is not intended to consider what type of work should or should not be included. Further, it is beyond the scope of this article to consider whether clinical type activities fall within the definition. Pro bono is shortened from the Latin term 'pro bono publico' meaning 'for the public good'. There is no requirement, at face value, for the work to be carried out for a particular group or individual, or indeed without charge, for it to be classified as pro bono. However, it is typically expected that work will only qualify as pro bono Reviewed Article -Teaching and Learning in Clinic 58 work if it is carried out for free and on behalf of individuals, charities and community groups who cannot afford to pay for advice and representation. 61 The consensus amongst the students is that pro bono work should be carried out for low income and vulnerable members of society with statements such as: There is also explicit recognition that pro bono work is carried out for reputational advantage, in other words, for tactical reasons. The essays suggest that students understand pro bono to be an important aspect of the legal profession and further, it involves working for the benefit of vulnerable and indigent clients thus supporting access to justice. The students demonstrate that whilst there are conflicts arising as to where the responsibility lies for ensuring access to justice, there is recognition that the legal profession shares that responsibility. 65  Further, the legal profession as a whole benefits from pro bono work due to the positive image it portrays. 67

Why should students undertake pro bono?
We can broadly categorise the reasons cited by the students for undertaking pro bono as: There are areas of natural overlap in the reasons cited by the student. For example, enhancing skills and experience are likely to improve employability. However, within the analysis, the focus has been on the primary motivating factor.

 Public Service
Public service was the only reason cited by every student as a reason to undertake pro bono work. However the weight given to public service among the essays varied The essays support the notion that law students see themselves as part of the wider community saying, for example, that:

"by participating in pro bono work, law students contribute constructively to the community around them in a most unique way." 70
It may be questioned as to how engagement with the wider community is a benefit to the student. In response to this question, the law school is about more than teaching students' knowledge and skills; indeed it is a 'professional socialization experience '. 71 This wider role is also recognised by The Quality Assurance Agency for Higher Through exposure to a wide variety of people, especially those from backgrounds that the students may not have ordinarily been exposed to, the student becomes a more rounded individual and thus develops as a professional. This is explained by one student as follows:

"Clients that students experience in [p]ro [b]ono work tend to come from a variety of social backgrounds. This helps to break down any unconscious social bias they may have, to ensure that in practice they approach each case with an open mind and with the necessary social awareness and empathy required of a lawyer. Working in [p]ro [b]ono
work prior to going in [to] practice helps students to develop as lawyers whose primary concern is to help their clients rather than being purely motivated by money and career

advancement." 73
There is further recognition within the essays that this engagement with the community can place the law into context for the student and add perspective to their aspirations as a lawyer that is unachievable in the classroom environment. would not have an effect on student attitudes. 74 It is therefore important for students to experience pro bono so they can therefore feel the intrinsic benefit of pro bono work, a notion summarised as follows: "It is imperative to understand that the benefits of [p]ro [b]ono are not limited to professional applications; legal involvement within the community allows one to make meaningful contributions to those in need, and in doing so allows the student to appreciate the "vital role the law plays." Legal [s]ervice has been denoted as being "unaffordable and out of reach." The common view held is that "one of the most perplexing facts about our perplexing legal market is its failure to provide affordable services for just about anyone but the rich and corporations." Thus, by providing legal aid to those who lack financial stability, the student is able to experience "intrinsic morale" and self-worth, something that all lawyers must be familiar with, and something that extends beyond the walls of the classroom." 75 The students' also demonstrated awareness that the altruistic value of pro bono work also improved the often-tarnished reputation of lawyers and therefore whilst the work 74  Reviewed Article -Teaching and Learning in Clinic 66 coherent learning structure so that they make sense to the student.' 82 There is an appreciation of this from one student who states: "Pro bono volunteers are generally supported and supervised throughout their volunteering enabling them to receive feedback for self-development." 83 This is further supported through students reflecting as an important part of this development:

"[U]ltimately it provides an opportunity for students of law to reflect upon their own weaknesses and strengths, to better their own legal skills, to engage with real clients" 84
In enabling this self-development, there must be clear boundaries as to the role of the supervisor. Cozens sets out two levels of supervisor intervention; the first is guidance thus allowing the student to act in the role of the lawyer and accept responsibility for that role; the second is direct intervention whereby the supervisor will replace the student's control of the situation. 85 The latter intervention meant there is little educational value in the experience. 86 Whilst the supervisor is important within the student's educational development, the student must assume responsibility for their own learning. As cited earlier, a significant motivating factor to undertake pro bono work is the experience of practise. 87 "The ideals of [pro bono] give students the fundamental opportunity to experience the expectations of a prospective lawyer" 88 There is also a perception that the experience afforded by pro bono work is different to any other experience a law student may have through their university career. The students stated that the practise of law is different to how it is taught in the classroom.
Further, the experience is more beneficial than work experience within a law firm as it is hands on.
"There is a definitive difference between being taught the law and practicing the law. Further, the students also perceive that pro bono work will help them stand out from the crowd.
"To the careerist, it offers necessary work experience to compliment applications for training contracts and pupillages. With attrition rates for career progression being as gruelling as ever (most notably in the case of the bar), pro bono work offers the aspiring lawyer a chance to apply their academics to real problems. In the current recruitment climate, work experience and a commitment to the legal profession has become a prerequisite, not a bonus. Fortunately, pro bono work offers both, and is a valuable asset to any pragmatic law student." 91 On a final note regarding experience, some of the students cited personal experience of engaging in pro bono work and the effect it has had on them. For example, one student stated: Further, another student considered the issue of pro bono from the perspective of potential employers and satisfying their own pro bono initiatives: "More and more law firms see the need for pro bono work and expect their lawyers to contribute. Why wait until it's expected of you? Impress them by having made a start on your own initiative" Whilst the students suggest that pro bono will assist them in securing employment, interestingly, graduate recruitment is also cited as a reason for law firms to have pro bono programmes. The Law Society of England and Wales report that: 'New graduates expect much more than just a healthy remuneration package and good career prospects; many law firms report that students being interviewed for vacation schemes ask detailed questions about their firm's pro bono programme and the opportunities available to them.' 96 It appears that law firms, in part, will offer a pro bono programme to attract highcalibre graduates while students will undertake pro bono opportunities to secure employment. This suggests that pro bono capacity is potentially increased by both law firms and students desire to stand out to each other.

 Academic
Four of the students identified enhancing a student's academic understanding of the law as a motivating factor to undertake pro bono work. 97 The theme of this motivation is that pro bono work improves their academic understanding of the law by placing it into context as shown in the quote below:  There was also an appreciation from these students that the academic law can be different to the practical law with one student stating: " [Although] it's easy to get lost in the intricacies of implied terms and the construction of contracts, practical law is often very different to academic law. Therefore, for the enthusiast, exposure to real cases and the ability to assist and advise both collaboratively and autonomously is an excellent learning tool and will invariably help cement essential legal principles in the context of tangible problems." 99

 Satisfaction
Personal and job satisfaction is often cited as a reason to undertake pro bono work.
There is an inherent satisfaction in doing a good deed and doing a good job for someone. Dinovitzer and Garth report that engaging in some pro bono work provided a sense of satisfaction for respondents although more pro bono hours significantly decreased satisfaction. 100 This supports the notion that doing some altruistic work is

Limitations
As with all studies, the conclusions of this study are subject to its limitations. In particular, this was a small-scale study considering the opinions of students based at a one university. It is likely that the students who participated in the study had a predisposition to pro bono and altruistic behaviour, thus were interested in the subject matter of the study. However, the incentive of a prize may have mitigated this factor and attracted the views of those individuals who are more extrinsically motivated.
However, I suggest we can learn from the students and assist in the development of future pro bono programmes.

Student Motivations
The students who participated in this study clearly demonstrated mixed motivations for undertaking pro bono work. Whilst many of the motivations were for personal benefit such as enhancing their skills, knowledge and employability, there was also recognition amongst all the students that pro bono work has wider social benefits including the promotion of access to justice and enhancing the community in which they live. One student expressed this as follows: Reviewed Article -Teaching and Learning in Clinic 76 "Pro Bono work operates to defend the vulnerable in society… [t]his alone means pro bono is well worth the time and effort for students, regardless of the useful personal skills and confidence they will also develop in the process." 106 Whilst another student stated: "You may be able to do some good, and that will be of benefit to you as well as society: we all have to play in social responsibility" 107 There is a link between the students cited motivations for undertaking pro bono work and Adult Learning Theory. As such, there is a theoretical basis as to why the provision of pro bono opportunities in law schools will enhance student skills, legal knowledge and consequentially, employability. Pro bono work is therefore an educational experience for the students.
Firstly, it is necessary to engage the students in the culture of pro bono work, recognising that the motivation for each student will be different. As such, perhaps there we should not isolate individual motivators but instead recognise the holistic nature of motivation. The Andragogical Model assumes that adults, when undertaking to learn something on their own, will invest considerable time into investigating the benefits of the activity. 108 As educators, we can draw the student's attention to an array of benefits that they can evaluate and align with their own objectives. Further, if a student opts to undertake pro bono work, they will feel a sense of autonomy thus aligning with the notion of 'self-concept'. 109 Knowles at al. state that '[t]he minute adults walk into an activity labelled "education," "training," or anything synonymous, they hark back to their conditioning in their previous school experience, put on their dunce hats of dependency, fold their arms, sit back, and say "teach me."' 110 Through engagement in pro bono activity, students are engaged in self-directed learning and less likely to resent or resist the learning activity.
The pro bono experience in itself aligns with the Androgogical Model as the emphasis 'is on experiential techniques -techniques that tap into the experience of the learners.' 111 Students also develop a 'readiness to learn' 112 because they are dealing with real life legal problems that require them to seek out and assimilate the relevant knowledge and skills.
Adults also have a life-centred orientation to learning and therefore learn 'new knowledge, understanding, skills, values and attitudes most effectively when they are presented in the context of application to real-life situations.' 113 Assisting a pro bono client with a real legal problem will therefore assist student in acquiring legal 109  Reviewed Article -Teaching and Learning in Clinic 78 knowledge and skill but also will influence their values and attitudes through exposure to new people and situations. 114 Finally, the most important motivators for adult learning are 'internal pressures' such as a desire for increased job satisfaction and self-esteem. 115 We can see that the students are exhibiting such motivation. 116 The question then becomes how we capitalise on these motivations to instil a culture of pro bono and volunteering within the law school whilst providing a rewarding educational experience for the students.

Pro bono in law school
As outlined above, Adult Learning Theory means there is an educational basis for incorporating pro bono programmes in law schools. However, it is important that such programmes are well designed to engage students and achieve the desired outcomes.
Extrinsic motivation means that students are likely to engage with the programmes.
The students value the skills development, the experience that they will acquire and, as a consequence the enhanced employability. The supervision of the programme and the students are important to ensure that students achieve the learning outcomes, and 114 For example, Behre, n.50; Maresh, n.24; Schmedemann, n.24 115 Knowles, n.108, 67 116 See n.102 and n.103 Reviewed Article -Teaching and Learning in Clinic 79 do not become merely observers but are responsible within the role of a lawyer creating an environment of autonomy and self-directed learning.
It is also important that pro bono programmes expose students to new people from different backgrounds. Intrinsically, students often value meeting strangers and this has the potential to create the 'disorientating moment'. Again, through guidance from their supervisor, students can reflect upon the situation, challenging their own perceptions of the world. Through such self-examination, students can achieve 'integration' on the 'taxonomy of human motivation' and internalise thus an extrinsically motivated experience will hold intrinsic interest.

Conclusion
We do not have the necessary evidence to draw any conclusions as to whether students will become intrinsically motivated to engage in public service after university as a longitudinal study would be required. However, on a theoretical basis, there is evidence to suggest that students can be extrinsically motivated to engage.
Through mere experience, some students may experience the inherent satisfaction of pro bono activity and therefore wish to continue. Others however may 'identify' the personal importance of the activity through an appreciation of its application to their own life and career goals, thus beginning the process of internalisation. As educators we can guide our students through the reflective process, help them make sense of their experiences and integrate the pro bono experience with their sense of self. Whilst the students are still extrinsically motivated, the perceived locus of causality will Reviewed Article -Teaching and Learning in Clinic 80 become more internalised thus, hopefully, instilling a continuing commitment to pro bono work in the future.
There are numerous reasons why students may wish to undertake pro bono work whilst at law school. Of these, experience is a highly influential factor as it not only provides a strong extrinsic motivation to participate in pro bono work initially, but the pro bono experience may also facilitate a deep intrinsic motivation to continue with the work into the future. Through experience, students can develop skills and improve their employability but they can also feel the inherent satisfaction of helping others and making a difference.
The development of pro bono initiatives in law schools benefits students personally and the students recognise this. Pro bono schemes will also benefit the community through the assistance offered by the students whilst engaging in the programme. As such, the University may also benefit from an enhanced reputation amongst the student body and the wider community.
As a consequence of providing pro bono programmes, students may reflect upon their experience and assess their own values and attitudes towards society, which may have a transformative impact upon their lives and their continuing participation in such as activity. However, to achieve this, the students must be provided with not only the experience but also the ability to reflect upon that experience.