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Source: http://www.doksinet The Happy Lawyer The Centerpiece of a Course Every Law School Should Teach By Todd David Peterson 1 Source: http://www.doksinet The Happy Lawyer 1 The Centerpiece of a Course Every Law School Should Teach Todd David Peterson 2 During the past decade a growing number of law professors and psychologists have devoted increasing attention to issues relating to the mental well-being of law students. Although earlier studies have shown higher levels of psychological distress, including elevated levels of depression, stress, and anxiety in law students, compared to medical students and other individuals in their age cohort, 3 these studies did not generate much momentum to address these issues in the law school environment. After the turn of the century, however, law professors and law students began to pay more attention to this issue as a growing number of studies focused on psychological distress among law students, and law professors began to discuss

ways to address this problem. 4 In particular, Florida State law professor Larry Krieger has worked to bring 1 NANCY LEVIT & DOUGLAS LINDER, THE HAPPY LAWYER (2010). Professor of Law, The George Washington University Law School. 3 See Andrew H. Benjamin et al, The Role of Legal Education in Producing Psychological Distress Among Law Students and Lawyers, 11 AM. B FOUND RES J 225 (1986); Marilyn Heins, Shirley N. Fahey & Roger C Henderson, Law Students and Medical Students: A Comparison of Perceived Stress, 33 J. LEGAL EDUC 511 (1983); Stephen B Shanfield & G Andrew H. Benjamin, Psychiatric Distress in Law Students, 35 J LEGAL EDUC 65 (1985) 4 See, e.g, Gerald F Hess, Heads and Hearts: The Teaching and Learning Environment in Law School, 52 J. LEGAL EDUC 75, 75–111 (2002); Nancy J Soonpaa, Stress in Law Students: A Comparative Study of First-Year, Second-Year, and Third-Year Students, 36 CONN. L REV 353, 353-83 (2004). 2 2 Source: http://www.doksinet attention to

these issues and suggested ways for law students to deal with them, 5 and (with psychologist Kennan Sheldon) published a number of influential studies on law student psychological distress. 6 Professor Krieger has also created a “humanizing law school” web page to offer students suggestions on how to deal with issues of psychological distress and provide “some perspectives and advice about the issues of health and life/career satisfaction as a law student and lawyer.” 7 Other legal academics have also begun to focus on this issue both in writing 8 and institutionally. The new Section on Balance in Legal Education of the Association of American Law Schools (AALS) was created to address law student mental health concerns. 9 Law students themselves have also begun to attend to these issues. The Law Student Division of the American Bar Association (“ABA”) recently initiated a Law Student Mental Health Initiative, and it sponsored a “national mental health day” at law

schools across the country. 10 5 See, e.g, Lawrence S Krieger, THE HIDDEN SOURCES OF LAW SCHOOL STRESS (2005), available at http://www.lawfsuedu/academic programs/humanizing lawschool/booklet2html; Lawrence S. Krieger, Human Nature as a New Guiding Philosophy, 47 WASHBURN L J 247 (2008). 6 See Kennon M. Sheldon & Lawrence S Krieger, Does Legal Education Have Undermining Effects on Law Students? Evaluating Changes in Motivation, Values, and WellBeing, 22 BEHAV. SCI & L 261 (2004); Kennon M Sheldon & Lawrence S Krieger, Understanding the Negative Effects of Legal Education on Law Students: A Longitudinal Test of Self-Determination Theory, 33 PERSONALITY & SOC. PSYCHOL BULL 883 (2007) 7 Humanizing Law School, FLORIDA STATE UNIVERSITY COLLEGE OF LAW, http://www.lawfsuedu/academic programs/humanizing lawschool/humanizing lawschoolhtml (last visited Mar. 21, 2012)) 8 See, e.g, Matthew M Dammeyer & Narina Nunez, Anxiety and Depression Among Law Students: Current

Knowledge and Future Directions, 23 LAW & HUM. BEHAV 55 (1999); Hess, supra note 4, at 75; Tim Kasser, Personal Aspirations, The “Good Life” and the Law, 10 DEAKIN L. REV 33 (2005); Soonpaa, supra note 4, at 353 9 See Todd David Peterson & Elizabeth Waters Peterson, Stemming the Tide of Law Student Depression: What Law Schools Need to Learn from the Science of Positive Psychology, 9 YALE J. HEALTH POLY L. & ETHICS 357, 360 (2009) 10 Law Student Division Mental Health Initiative, AMERICAN BAR ASSOCIATION, http://www.americanbarorg/groups/law students/initiatives awards/lshealthhtml (last visited Mar. 21, 2012) On a more local level, the student government at The George Washington University Law School has started a weekly series of “Wellness Wednesday” events devoted to 3 Source: http://www.doksinet Coincidentally, during this same ten-year time span, researchers in the newly recognized field of positive psychology produced numerous books and hundreds of articles

on the traits and conditions that lead to human thriving. 11 Positive psychology began its rapid development as a separate branch of psychological research when Martin Seligman, of the University of Pennsylvania, devoted his first speech as president of the American Psychological Association to the subject and then published a special positive psychology issue of American Psychologist (the official journal of the American Psychological Association) in January 2000. 12 Positive psychology has revolutionized the study of human behavior by balancing the empirical psychological research on the causes of mental illness and distress with new research designed to study “positive emotions, positive character traits and enabling institutions.” 13 As Professor Seligman concluded, “the value of the overarching term positive psychology lies in its uniting of what had been scattered and disparate lines of theory and research about what makes life most worth living.” 14 By helping to explain

what makes people happy and thrive, the field of positive psychology offers a wealth of new empirical research that could be used to address issues of law student mental health and well-being. As Professor Seligman himself recognized, “law schools are themselves a potential breeding ground for lawyer demoralization and that makes them – as well as law firms – candidates for reform. In these ways the relationship between positive issues of student mental health and well-being. 11 See, e.g, A PSYCHOLOGY OF HUMAN STRENGTHS (Lisa G Aspinwall & Ursula M Staudinger eds., 2003); FLOURISHING (Corey L M Keys & Jonathan Haidt eds, 2003); OXFORD HANDBOOK OF METHODS IN POSITIVE PSYCHOLOGY (Anthony D. Ong & Manfred HM van Dulmen eds., 2007); POSITIVE PSYCHOLOGICAL ASSESSMENT (Shane J Lopez & C R Snyder eds., 2003); POSITIVE PSYCHOLOGY IN PRACTICE (P Alex Linley & Stephen Joseph eds, 2004); THE HANDBOOK OF POSITIVE PSYCHOLOGY (C. R Snyder & Shane J Lopez eds, 2002) 12

Martin E. P Seligman & Mihaly Csikszentmihalyi, Positive Psychology: An Introduction, 55 AM. PSYCHOLOGIST 5 (2000) 13 Martin E. P Seligman et al, Positive Psychology Progress: Empirical Validation of Interventions, 60 AM. PSYCHOLOGIST 410, 410 (2005) 14 Id. 4 Source: http://www.doksinet psychology and law becomes a subject for the further study in the legal academy, as well as in the profession at large.” 15 In their wonderful new book, The Happy Lawyer, 16 Professors Nancy Levit and Douglas Linder of the University of Missouri at Kansas City Law School took up the challenge to apply the new learning from the science of positive psychology to the issues that law students and lawyers face in creating happy and fulfilling careers in the law. Although law professors and psychologists (including Levit and Linder themselves) have used principles from the field of positive psychology as the core of articles on law student mental health and well-being, 17 this is the first

book-length effort to apply the new science of happiness and well-being to the issue of law students and lawyers having happier and more meaningful lives and careers. It is far beyond the capacity of one book to assay the full range of positive psychology research and apply it to the entire range of issues related to the happiness of law students and lawyers, but Levit and Linder have done a marvelous job of culling the most significant principles from the latest psychological research and showing both lawyers and law students how they can use this information to improve the quality of their lives and careers. This noteworthy achievement makes The Happy Lawyer essential reading for law students, professors and administrators. Moreover, although The Happy Lawyer seems principally addressed to individual law students and lawyers, it can be the cornerstone of law school courses and programs designed to improve student mental health and well being and help students map the course of happy

and meaningful 15 Martin E. P Seligman, Paul R Verkuil & Terry H Kang, Why Lawyers Are Unhappy, 10 DEAKIN L. REV 49, 54 (2005) 16 LEVIT & LINDER, supra note1. 17 See, e.g, Peter H Huang & Rick Swedloff, Authentic Happiness & Meaning at Law Firms, 58 SYRACUSE L. REV 335 (2008); Peter H Huang, Authentic Happiness, Self-Knowledge and Legal Policy, 9 MINN. J L SCI & TECH 755 (2008); Nancy Levit & Douglas Linder, Happy Law Students, Happy Lawyers, 58 SYRACUSE L. REV 351 (2008); Peterson & Peterson, supra note 9, at 413; Seligman, Verkuil & Kang, supra note 15, at 54. 5 Source: http://www.doksinet future careers. Unfortunately, few law schools now offer such courses or programs. This Article argues that law schools have an obligation to educate law students about how they can achieve meaningful and personally satisfying careers in the law and, in addition, how they can buffer themselves against the stress and depression that far too frequently arise in

both law school and the practice of law. Experience teaches us that law students are unlikely to be able to accomplish these goals effectively on their own. Far too many students suffer through their law school experience only to find that their subsequent legal careers are unrewarding and emotionally stressful. Moreover, as this Article discusses in more detail below, the very legal skills law schools teach to help students become effective lawyers are likely to contribute to mental and emotional distress in their private lives. Fortunately, we now have sufficient empirical psychological research on happiness that we can teach students how to meet the emotional challenges of law school and the legal profession, and identify the kind of legal practice that will make for a happy professional career. This Article proceeds in three main sections. In Part I, the Article discusses why law schools have an obligation to teach students how to find happy and rewarding legal careers and deal

with the emotional well-being issues that so often arise in law school. Ideally, this would involve a course on finding satisfaction in the legal profession, of which The Happy Lawyer could be the centerpiece. The course should be just one part of a larger program that could include presentations and programs relevant to the issue and should involve a law school’s career development office, as well as the student advising office. In Part II, the Article takes a detailed look at the Levit and Linder book and explains why it has the potential to be the keystone of a law school’s student wellness program. Finally, in Part III the Article discusses a number of 6 Source: http://www.doksinet topics that are not discussed at length in The Happy Lawyer, but which should also be a part of any law school student wellness program. I. Why Law Schools Have an Obligation to Teach Students How to Have Happy and Meaningful Legal Careers As an initial matter, it is important to establish why

every law school should have a program that helps law students understand how to have a happy and meaningful career in the law. Although Levit and Linder note that only six law schools offer courses that are even tangentially related to the subject of building a happy legal career, 18 they do not have an extended discussion of how such a course might be structured, or why law schools might have a moral obligation to help their students achieve a more satisfying law school and legal career. They simply rhetorically ask, “How can law schools help students make good career choices if they offer no courses on career satisfaction?” 19 Because The Happy Lawyer clearly would be the cornerstone of any course on that topic, it may just be that the authors are modestly avoiding a sales pitch for their own book. So, this Article will make that pitch for them Law schools should be creating courses on happy lawyering for a wide range of reasons. First, law schools have a moral obligation to

their students to help them deal with the challenges to their subjective well-being because law schools play an active role in creating many of those difficulties. We teach students to be critical and to find flaws in agreements and opinions We teach them to be pessimistic by training them to anticipate problems and bad outcomes, and plan for any negative eventuality. This daily training in negative thinking builds neural pathways in 18 LEVITT & LINDER, supra note 1, at 123. The authors list those courses as Lewis and Clark’s “Lawyering in Society,” Temple’s “Law Happiness and Subjective Well-Being,” University of California at Berkeley’s “Effective and Sustainable Law Practice: The Meditative Perspective,” The University of Missouri-Kansas City’s “Quest for a Satisfying Career in Law,” The University of Virginia’s “Legal Careers and Life’s Satisfaction,” and Yale’s “Happiness and Morality.” Id at 262 n 31 19 Id. at 124 7 Source:

http://www.doksinet students’ brains that will cause them to evaluate themselves much more critically and be much more likely to adopt a pessimistic, explanatory style that sees difficulties as pervasive and permanent, rather than local and temporary. 20 Recent psychological research demonstrates that these ways of perceiving one’s self and one’s personal difficulties are likely to make individuals much more prone to stress and depression. 21 These skills may be necessary for effective lawyering, but they also create problems that law schools must address. It is simply not morally defensible to ignore the problems that are due at least in part to the training we provide. The story of how law schools create conditions that lead to the development of depression begins with a computer game called Tetris. Tetris is a game in which four kinds of shapes fall from the top of the screen and the player can rotate and move them until they hit the bottom. When the block creates an unbroken

horizontal line across the entire screen the line disappears. The object of the game is to complete as many unbroken lines as possible so the blocks pile up and reach the top of the screen, at which point the game ends. As many gamers discovered, Tetris is a deceptively simple and surprisingly addictive game. A group of Harvard researchers studied subjects who were assigned to play Tetris for multiple hours a day, three days in a row. 22 For many days after they participated in the experiment, the subjects saw Tetris like shapes everywhere they went and imagined how they could fit them together in the smallest possible space. This phenomenon is familiar to many who have obsessively played the game, including one who described his experience this way: “Walking through the aisles at the local Acme, trying to decide between Honey Nut or the new frosted Cheerios, I noticed how perfectly 20 See SHAWN ACHOR, THE HAPPINESS ADVANTAGE 92-93 (2010). See id. at 123-24 22 R. Stickgold et al,

Replaying the Game: Hypnagogic Images in Normas &l Amnesics, 290 SCI. 350 (2000) 21 8 Source: http://www.doksinet one set of cereal boxes would fit in with the gap on the row below it. Running doggedly around the track at the Y, bored out of my mind, I find myself focusing on the brick wall and calculating which direction I’d have to rotate those slightly darker bricks to make them fit with the uneven row of dark bricks a few feet further down the wall. Going out to get some fresh air after hours of work, I rub my watery, stinging eyes, look up at the Philadelphia skyline, and wonder, if I flip the Victory building on its side would it fit into the gap between Liberties I and II?” 23 This condition, called the Tetris effect, is just one example of a much larger psychological concept. Consistently training your mind to look at things in a particular way leads the mind to look at the world in this fashion, even after the person leaves the context in which the pattern

developed. 24 So, for example, one Harvard researcher reported that after a marathon session of playing the video game Grand Theft Auto with a group of students in a Harvard dorm, he found himself examining the cars he passed outside the dorm as potential targets for theft and even imagining the theft of a Cambridge police cruiser. 25 It turns out that there is a neurological explanation for the Tetris effect. Repeated actions over a period of time create new neuropathways in the brain, which create channels the mind has a tendency to follow repetitively. Scientists once believed that the brain was fixed after the age of three and that no new brain cells developed thereafter. New research, however, has demonstrated the phenomenon of neurogenesis, the development of new neurons in the brain in response to repeated stimuli. 26 This discovery has led to an understanding of the concept of 23 Annette Earling, The Tetris Effect: Do Computer Games Fry Your Brain?, PHILADELPHIA CITY PAPER,

Mar. 21, 1996, at [need page number] 24 ACHOR, supra note 20, at 89-90. 25 Id. at 87-88 26 See, e.g, Richard J Davidson, Affective Style, Psychopathology and Resilience: Brain Mechanisms and Plasticity, 55 AM. PSYCHOLOGIST 1196 (2000); Richard J Davidson, Daren C Jackson & Ned H. Kalin, Emotion, Plasticity, Context and Regulation: Perspectives From 9 Source: http://www.doksinet neuroplasticity, the idea that the brain can change, grow, and develop new neuropathways. For example, in one famous study, researchers looked at the brain of London taxi drivers, who are required to learn their way around the incredibly complex and disordered structure of the London streets. The researchers discovered that in these taxi drivers the hippocampus, the part of the brain associated with visual memory, was significantly enlarged. 27 The daily exercise of navigating the London streets had created new brain cells to perform the task effectively. Similarly, when one develops a habitual way of

looking for particular patterns, whether it is the way falling blocks fit together in a line or a particular way of analyzing logical problems (thinking like a lawyer), the brain builds neuropathways that tend to channel our thinking through the same pathway, even when we are not engaging in the activity that created the neuropathway to begin with. So, we should ask, what neuropathways do we create in law school? What habitual patterns of thought do we create and reinforce so that, in another example of the Tetris effect, students will be likely to habitually follow that pattern of thinking even when they are outside of the classroom? First, law school classes relentlessly pursue the identification of flaws and problems in legal arguments and opinions. We identify the flaws in the cases we teach and use the Socratic method to help students identify the flaws in their reasoning and understanding. This relentless training in fault-finding inevitably carries over into the way students

look at themselves and their lives outside the classroom. Because of this training they are more likely to emphasize their shortcomings and mistakes and less likely to focus on their achievement and talents. Inevitably, if we train our brains to look for flaws, we will find them wherever we look, Affective Neuroscience, 126 PSYCHOL. BULL 890 (2000) 27 See ACHOR, supra note 20, at 28; ED DIENER & ROBERT BISWAS-DIENER, HAPPINESS: UNLOCKING THE MYSTERIES OF PSYCHOLOGICAL WEALTH 4 (2008). 10 Source: http://www.doksinet and we will be looking for them all the time because that is the neuropathway that we constructed. As countless psychological studies have shown, this kind of fault-finding is a recipe for unhappiness, stress, and depression. 28 Second, law school is a three-year lesson in pessimism. It begins in the first year as students are trained both subconsciously and consciously to anticipate bad outcomes and problems in the future. The torts class is a semester-long exposure

to all the bad things that can happen in life. There is no better illustration of the Tetris effect than the too-familiar stories of law students going home for Christmas and seeing everything around them as a source of a potential negligence action. 29 The pessimism training continues in a more conscious way in other classes, where students are taught to anticipate potential problems and plan for them in advance. 30 Students trained to anticipate problems in their roles as lawyers will inevitably anticipate problems and approach life more pessimistically even when they leave the law school building. Law school tends to build and reinforce neuropathways that make the expectation of problems habitual and difficult to avoid. Once again, numerous psychological studies make clear how destructive such a pessimistic approach is to one’s happiness. 31 Finally, law school courses train students to resolve conflicts and problems through logical argumentation. If a position cannot be logically

argued and justified, then it must be rejected and a more logical argument developed. This conclusion is reinforced by the recent study by Elizabeth Mertz, an anthropologist, law professor, and senior fellow at the America Bar 28 See TAL-BEN-SHAHAR, HAPPIER (2007); BARBARA L. FREDRICKSON, POSITIVITY (2009) See Ann L. Iijima, Lessons Learned: Legal Education and Law School Dysfunction, 48 J LEGAL EDUC. 524, 528 (1998) 30 See Seligman, Verkuil & Kang, supra note 15, at 66. 31 See, e.g, MARTIN E P SELIGMAN, LEARNED OPTIMISM (1992) 29 11 Source: http://www.doksinet Foundation, who published a study of first-year contract courses at eight different law schools. 32 Mertz studied classes taught by professors with very different perspectives and teaching styles, but she found that in all of the classes students were taught to “think like lawyers,” by setting aside their own feelings of empathy and compassion and substituting a strictly analytical and strategic mode of thinking.

33 Such training develops durable neuropathways that will inevitably be applied whenever students deal with conflicts, even if those conflicts are emotional issues with their significant others and other loved ones. Notwithstanding the fact that the application of such an approach to one’s private life is guaranteed to engender only anger in the person who is out-argued but whose emotions are not recognized and acknowledged as legitimate, it will be difficult for law students to escape the training they receive daily in law school, or even to recognize that they are applying that training in their personal life. 34 As a result, personal relationships suffer, and so does the emotional health and well-being of the law student. Law schools need to recognize that the very process of training students to think in particular ways that may be well adapted to professional success is likely to create patterns of thought. These patterns of thought, when inevitably carried over to the

students’ nonprofessional lives, are likely to create unhappiness and the potential for depression. As I will discuss further below, there are ways to mitigate these problems and, happily, empirically-tested exercises that can help students develop more positive ways of looking at their own personal lives. Law students, however, are unlikely to come upon the solutions by themselves, and it rests with law schools to provide them with the information and training to enable them to do so. Law schools have a moral obligation to help students undo the damage that necessarily accompanies training 32 See ELIZABETH MERTZ, THE LANGUAGE OF LAW SCHOOL: LEARNING TO “THINK LIKE A LAWYER” 4 (2007). 33 Id. at 6, 95 34 See Iijima, supra note 29, at 526-27. 12 Source: http://www.doksinet to think like a lawyer. In addition, law schools need to redefine the concept of a successful legal career as much as law students do. Most law schools would acknowledge that they have an obligation to train

their students in a way that helps them achieve a successful legal career, but law schools have not caught on to the notion that a successful career means more than just a job that produces a high income and plenty of prestige. In fact, as Levit and Linder point out, law schools tend to exacerbate this problem because they tend to create an “institutional glide path” that deters students from defining success in terms of their own subjective interests and feelings. 35 Once law schools acknowledge the fact that a happy and satisfying career is the proper goal for their students, they should recognize that they have some obligation to help their students understand what that means for them individually and to understand the underlying psychological principles that are likely to determine whether their career is a happy one or not. Finally, it is clearly in a law school’s own self-interest to help its students find a satisfying career path and have as happy a law school experience

as possible. There is a simmering rage among many recent graduates and current law students over the lack of job opportunities and the perceived indifference of law schools to their career plight. As the ABA Journal recently reported, “an increasingly concerned legal community is paying attention, although its response may not satisfy the angriest bloggers.” 36 For example, one Boston College Law School student wrote an open letter to the school dean asking for a return of his tuition in exchange for a promise to drop out of school without obtaining his degree. He wrote, “with fatherhood impending, I go to bed every night terrified of the thought of trying to provide for my child and paying off my JD, and resentful at the thought that I was convinced to go to law school 35 36 See LEVIT & LINDER, supra note 1, at 125-27. Anna Stolley Persky, Law School? Bag It, Bloggers Say, 97 A.BA J 16 (2011) 13 Source: http://www.doksinet by empty promises of a fulfilling and

remunerative career.” 37 Unhappy law students who go on to be unhappy lawyers do not make for satisfied alumni who wish to maintain any relationship with their alma mater. The more satisfied students are with their education and subsequent career, the more likely they are to maintain the kind of contact with their law schools that will provide both financial and many other benefits to the law school. II. The Happy Lawyer as the Foundation for a Law School Course on Happiness Levit and Linder have stepped up to the challenge of helping law students and lawyers who want to have happier experiences during law school and in their subsequent careers. In this section, I will discuss how the authors address these issues, and how their insights can form the basis for a law school program aimed at educating law students to be more discerning about what will make them happy at school and in their legal careers. Levit and Linder begin with the question, “Are lawyers unhappy?” The focus of

this chapter is entirely on lawyers in practice and does not discuss the data concerning the well- being of law students. This reflects the general orientation of the book toward practicing lawyers, although, as we will see, the authors do not neglect the happiness of law students. The answer to the question posed by this chapter turns out to be a surprisingly complex one. We know how lawyers fare compared with a number of other professions: they are less happy than members of the clergy, travel agents, architects, scientists, engineers, airline pilots, physicians, financial planners, and detectives, but happier with their careers than roofers or gas station attendants. 38 This data suggests that there is surely room for improvement in lawyers’ career satisfaction, but it does not identify either the nature of the dissatisfaction or the depth to which it reaches. Some data suggests that lawyers are reasonably happy, while other data suggests that there are very 37 38 LEVIT &

LINDER, supra note 1, at 17. Id. at 2 14 Source: http://www.doksinet high levels of dissatisfaction in the profession. Levit and Linder sort through the studies and persuasively argue that, “[f]or most lawyers, things could be better.” 39 That is reason enough to pay attention to the issues that the authors address. The authors next move to a chapter called “Happiness: A Primer.” 40 The title of this chapter reflects a significant choice of terminology that is also reflected in the title of the book. This terminological choice has several complications. First, on a technical level the term “happiness” is somewhat ambiguous. Psychologists frequently use the term “subjective wellbeing” instead of happiness because it emphasizes that happiness is inherently subjective; it is about how people think of their lives and what they consider to be important. 41 Psychologists recognize that happiness is an unwieldy and complicated term that embraces many meanings, including

pursuing or maximizing frequent positive feelings, being engaged in the activities of life, and finding meaning in life or cultivating a meaningful life. 42 To their credit, the authors take pains to explain the different nuances of happiness and focus on the aspects of happiness research that are most relevant to lawyers who are searching for a meaningful and satisfying career. 43 The larger problem is that using the terms “happy” and “happiness” runs the risk of 39 Id. at 8 Id. at 18 41 See DIENER & BISWAS-DIENER, supra note 27, at 4. 42 While differing definitions of well-being and happiness abound, positive psychology uses the term to embrace three distinct concepts: pleasure, engagement, and meaning. See Seligman, et al., supra note 13, at 413 In their definitions of happiness, positive psychologists often refer to the Greek term ‘eudaimonia, which Aristotle described as the highest good. Although directly translated as ‘happiness, eudaimonia can be more

accurately defined as ‘human flourishing. It conveys not just pleasurable feelings ("hedonia") but the deeper experience of living in accordance with ones virtues. While positive psychologists recognize that both pleasure and meaning are necessary for happiness, research confirms that people who pursue eudaimonic goals (the route towards meaning) are more satisfied than those who pursue only pleasure. See CHRISTOPHER PETERSON, A PRIMER IN POSITIVE PSYCHOLOGY 78-79 (2006). 43 LEVIT & LINDER, supra note 1, at 18-19. 40 15 Source: http://www.doksinet associating the book with popular and unscientific personal-growth books or what Levit and Linder term “garden-variety self-help vacuity.” 44 Popular books like “The Secret” 45 tend to over-promise and under-deliver on proven knowledge about happiness, and they have, at times, provoked angry responses from those who find the flip side of their positive message to be the implicit assumption that individuals are

responsible for all the negative things they experience. 46 Levit and Linder, however, are aware of these potential pitfalls, and they take pains to avoid them. The book scrupulously adheres to evidence that is drawn from serious empirical research and avoids the temptation to suggest easy answers to complex problems. It is simply hard to come up with a term that works better in this context. Even serious psychology academics wind up depending on the term “happiness” when writing for a general audience, 47 so Levit and Linder can hardly be faulted for following their lead. Readers should not jump to facile conclusions based on the title of the book or this chapter. They should look instead to the substance of the book, which is meticulously researched and scientifically documented. When they get down to describing the scientific research on happiness, Levit and Linder face a daunting task as they lay out the basics of the physiological and psychological research on human happiness.

Even a summary of this research, to be fully complete, would require many volumes, and Levit and Linder attempt to do it in 31 pages. Therefore, it is inevitable that a good deal will be left out. The authors, however, do a good job of summarizing both the neuroscience of happiness and much of the research in the area of positive psychology. The authors lay their foundation by using Sonja Lyubomirsky’s research concerning the extent to which happiness is 44 Id. at 18 See RHONDA BYRNE, THE SECRET (2006). 46 See, e.g, BARBARA EHRENREICH, BRIGHT-SIDED (2008) 47 See, e.g, ACHOR, supra note 20; JONATHAN HAIDT, THE HAPPINESS HYPOTHESIS: FINDING MODERN TRUTH IN ANCIENT WISDOM (2006); SONJA LYUBOMIRSKY, THE HOW OF HAPPINESS (2007); MARTIN E. P SELIGMAN, AUTHENTIC HAPPINESS (2002) 45 16 Source: http://www.doksinet within one’s control. Lyubomirsky suggests that an individual’s happiness is 50 percent determined by genetic factors, 10 percent by circumstances beyond an individual’s

control, and 40 percent by factors that are within an individual’s ability to influence. 48 The authors then spend the remainder of the chapter describing the basics of self-determination theory, a branch of positive psychology that attempts to identify the specific types of experiences that make people thrive. 49 Although this list may be lengthened or shortened depending on the views of a particular psychologist, the authors focus on six factors that have been used by Larry Krieger in discussing the mental health problems students have with law school: security, autonomy, authenticity, relatedness, confidence, and self-esteem. 50 These factors provide a fine foundation for the author’s subsequent analysis of the legal profession. It might have been helpful to add some additional foundational building blocks using some of the well known areas of positive psychology research, such as Martin Seligman’s research on the importance of optimism 51 and Barbara Fredrickson’s research

on the importance of positive emotions in countering the physical and emotional effects of stress and depression as well as their significant impact on broadened and more creative thinking. 52 But choices have to be made, and the authors have made reasonable ones. Moreover, the authors add a number of specific applications of positive psychology principles in their later chapter, The Happiness Toolbox. Levit and Linder build on the foundation laid for their description of happiness research by then exploring what makes lawyers happy and unhappy. 53 The suspects are familiar to any 48 LEVIT & LINDER, supra note 1, at 32-42. See LYUBOMIRSKY, supra note 47, at 27 LEVIT & LINDER, supra note 1, at 44-48. 50 Id. See Lawrence S Krieger, Psychological Insights: Why Our Students and Graduates Suffer, and What We Might do About It, 1 J. ASS’N LEGAL WRITING DIRECTORS 265 (2002) 51 See SELIGMAN, supra note 31. 52 See BARBARA L. FREDRICKSON, POSITIVITY (2009) 53 LEVIT & LINDER,

supra note 1, at 49. 49 17 Source: http://www.doksinet practicing lawyer: the increasing expectations for annual billable hours, 54 the trend toward law becoming more of a business and less of a profession, 55 increasing incivility in the practice of law, 56 the growth of the legal press, which makes it easier for lawyers to make comparisons that increase dissatisfaction with their current situation, 57 the trend toward increasingly large law firms, 58 and the disrespect many lawyers feel in the public’s attitude toward the profession. 59 Things are not, however, all gloomy. Lawyers can make a difference in people’s lives in a way that brings immense satisfaction to a legal career. 60 Moreover, lawyers satisfaction with their careers tends to increase over time. 61 So, while there are many problems that can make lawyers unhappy with their work, there is the potential (achieved by many over time) to develop a happy and satisfying career. So what can be done by lawyers who find

too few of the satisfactions of legal practice and are beset by too many of the problems? Levit and Linder provide a “happiness toolbox” which draws on a number of strains of positive psychology research to provide suggestions for how to improve the 40 percent of happiness that is within our own control. 62 Here the authors put together specific recommendations for applying the principles of positive psychology. First, the authors emphasize how important it is for lawyers to feel that they have some sense of control over their lives. 63 For lawyers, this means finding an appropriate work-life balance, having a sufficiently strong sense of job security, and believing that what you do in your work 54 55 56 57 58 59 60 61 62 63 Id. at 54 Id. at 56 Id. at 58 Id. at 62 Id. at 63 Id. at 64-67 Id. at 68-69 Id. at 70-73 Id. at 78 Id. at 79 18 Source: http://www.doksinet matters. 64 Moreover, money, which we think will have a significant impact on our happiness, turns out not to be

correlated with happiness. On the other hand, comparing ourselves to other people who earn more, have better offices, or who we perceive as being better appreciated does substantially influence our happiness. 65 Comparing ourselves to those who are better off (“comparing up”) makes us unhappy while comparing ourselves to those who are less fortunate (“comparing down”) makes us happy. (This phenomenon explains the initially counter-intuitive conclusion that silver medalists are less happy than bronze medalists at the Olympics. Silver medalists tend to compare themselves to the winner whose gold metal was almost theirs, while bronze medalists tend to compare themselves with the rest of the competitors who did not make it on to the medal stand. 66) Lawyers can also make their work more satisfying by attending to their relationships with other people. The scientific literature demonstrates that relationships matter, and people who have significant and deep relationships with other

people are happier than those who do not. 67 In addition, being able to commit to a job turns out to be an important factor in determining whether one is happy in that job. 68 If one is constantly looking for greener pastures, one will never be happy in the pasture in which one now resides. Finally, lawyers are happier if they are able to find what psychologist Mihaly Csikszentmihalyi has called “flow,” “a dynamic state that characterizes consciousness when 64 65 66 67 68 Id. at 82-83 Id. at 86 Id. at 87 Id. at 90 Id. at 95-96 19 Source: http://www.doksinet experience is attended to for its own sake,” where “action and awareness are merged.” 69 Flow is akin to what athletes report when they are “in the zone,” when the mind is totally focused on the present and no outside distractions interrupt. 70 When we are actively engaged and when we are in the present, we have a more satisfying and, ultimately, happier work experience. Unfortunately, as previously noted, 71

and as the authors point out, anyone trying to improve their own happiness is likely to find, as psychologist Daniel Gilbert demonstrated, 72 that we are utterly inept at identifying what will make us happy and what will not. 73 In order to counter this problem, the authors suggest that the best way for any lawyer, or aspiring lawyer, to determine what might make them happy is to learn from the experiences of other lawyers. 74 Thus, it is crucial to challenge assumptions about what will be a satisfying legal career and find out what actually makes law a satisfying career for those who are actually practicing it. Law students and lawyers can also find more meaningful careers by focusing, as Tal BenShahar suggests, 75 on a job that gives them pleasure, meaning, and aligns with their abilities. 76 Ben-Shahar describes this by drawing a Venn diagram of three circles and suggesting that the point at which these three intersect is where someone is likely to find the most satisfying job. 77

Neglecting any one of these is likely to lead to career dissatisfaction. This of course means understanding oneself better and identifying the specific kinds of work that will satisfy each of 69 Id. at 97 See MIHALYI CSIKSZENTMIHALYI, FINDING FLOW: THE PSYCHOLOGY OF ENGAGEMENT WITH EVERYDAY LIFE 29 (1997). 71 See supra text accompanying notes 62-70. 72 See DANIEL GILBERT, STUMBLING ON HAPPINESS 111-71, 212-33 (2006). 73 LEVIT & LINDER, supra note 1, at 100. 74 Id. at 100-03 75 See TAL BEN-SHAHAR, THE QUESTION OF HAPPINESS: ON FINDING MEANING, PLEASURE, AND THE ULTIMATE CURRENCY 54-57 (2002). 76 Id. at 103-08 77 Id. 70 20 Source: http://www.doksinet these requirements. Armed with these tools for understanding what can make for a happy and satisfying legal career, the authors proceed to examine how both law school and a lawyer’s subsequent legal career can be made happier. In their next chapter, the authors specifically address the problems faced by law students. They break

down the law school analysis into four issues: (1) deciding whether one should go to law school; (2) deciding which law school is likely to lead to a satisfying and happy experience; (3) redefining the meaning of success in law school; and (4) identifying a satisfying career that is most likely to lead to a self-directed and enjoyable law school experience, as well as a meaningful and rewarding career after graduation. The authors make useful suggestions for those planning on attending law school, particularly a set of criteria that may make the law school experience less stressful and more rewarding, but which have nothing to do with the rankings in U.S News and World Report It may, however, be a tall order to persuade prospective law students to consider much beyond the rankings. It should be easier to get law students to attend to the section on defining success in law school. 78 This section is basically a pitch to get law students to develop their own internal motivation and goals

rather than defining their success based on criteria such as grades, interviews with big firms, and making law review. 79 Many students come into law school with an idea of what they want to do with their legal education but then get trapped on the “institutional glide path” that eventually leads all students to pursue the same career goals, regardless of their own individual interests. 80 Indeed, as the authors note, learning research shows that, when students study toward the goal of mastering a particular area, they perform 78 79 80 Id. at 125-37 Id. at 125 Id. 21 Source: http://www.doksinet better than those whose principal motivation is to attain a good grade. 81 Finally, the authors appropriately spend some time on the subject of how to identify a satisfying legal career. 82 The sooner that law students identify career goals that reflect their own personal interests, needs, and competencies, the more likely they are to develop a set of internal motivations and,

therefore, make law school a more satisfying experience. The problem, however, is that many of the skills that students learn in law schoolto analyze rather than explore, to focus on potential problems, to be skeptical and to avoid taking risksare counterproductive in identifying a potential career and committing to that choice. 83 I would suggest that this is yet another example of how the Tetris effect hurts students who unconsciously apply the habits learned in the classroom to a setting where it is personally maladaptive. The authors do a good job of explaining why it is so important to allow yourself to narrow the range of choices in order to be able to select a career path to which you can commit. To facilitate that goal, the authors suggest an exercise in which students draft a two paragraph vision statement for their career, and they offer ten questions around which to organize that statement. 84 The authors conclude their advice for law students by discussing the job interview

process, including the development of personal interview strategies. 85 Here the authors suggest a set of questions students might use during their own interview process in order to identify jobs that will be most meaningful and satisfying to them. 86 The questions the authors propose are all designed to help students identify potential places of employment that, based on the happiness criteria the authors have previously discussed, are most likely to lead to a satisfying and 81 82 83 84 85 86 Id. at 133 Id. at 138 Id. at 142-43 Id. at 147-49 Id. 153-57 Id. at 156-57 22 Source: http://www.doksinet rewarding career. That logically leads Levit and Linder to the next chapter, in which they consider what law firms can do to make lawyers happier. 87 Appropriately, the authors begin with a pitch to law firms about why they should care about making their lawyers happy. 88 One of the most significant developments of modern happiness research is the substantial and empirical support for the

conclusion that happier employees are more likely to fuel success and performance at work. 89 Law firms are not likely to care much about this issue unless they can be persuaded that it relates to their ultimate success as an institution. The authors then spend the rest of this section exploring ten steps that “could make your law firm a happier work place.” 90 These steps, all based on principles introduced previously in the book, include (1) promoting lawyer autonomy, (2) taking off the billable hours straightjacket, (3) building work-life balance, (4) encouraging a positive attitude, (5) valuing employees, (6) promoting social interaction, (7) giving the pro bono bonus, (8) creating a playful workplace, (9) designing law offices to promote lawyer happiness, and (10) asking for feedback. The authors accompany each of these suggestions with an explanation of how law firms might accomplish these goals, some more lengthy than others. Unsurprisingly, improving work-life balance

requires the lengthiest treatment. 91 Many of the suggestions the authors have are strikingly creative and thoughtful, such as their discussion of how the design of physical space can promote lawyer happiness in interaction. 92 Importantly, every suggestion is tied to empirical research that supports the conclusions the authors wish to draw. Ultimately, these suggestions can be a 87 88 89 90 91 92 Id. at 160 Id. at 161-64 See ACHOR, supra note 20. LEVIT & LINDER, supra note 1, at 170. Id. at 173-82 Id. at 199-204 23 Source: http://www.doksinet springboard for law firms to analyze their work environment more creatively and produce a happier and more productive workplace. Finally, the authors add a really nice touch by presenting a series of individual lawyers’ stories about building a happy and satisfying career. 93 These stories are nicely collected and reported in such a way as to give personal context to the abstract principles discussed earlier in the book as well as to

give one confidence that it is actually possible to develop a meaningful life in the law. These stories can provide inspiration to law students and lawyers alike to set their own personal goals for building satisfying careers. The Happy Lawyer is an ideal foundation upon which to build a program to help law students achieve a happy law school experience and a rewarding career. First, the book’s summary of recent positive psychology and neurological research provides an excellent introduction to the happiness literature and lays a good foundation for thinking about issues relating to satisfaction in law school and a subsequent legal career. Second, the book’s thoughtful discussion of the issues faced by law students provides a fantastic basis for an extended consideration of how law students need to define their own future careers while they are in law school. Finally, the discussion of what law firms can do to make the practice of law more satisfying is helpful for several reasons.

It helps law students understand what they should be looking for in deciding where to work, and it also helps them start to think about how they can build better institutions when they are in the position to have some influence over them. If law schools have been waiting for a good cornerstone for a course on how to find a meaningful and satisfying legal career, they need wait no longer. The Happy Lawyer fills that role very nicely indeed. 93 Id. at 208 24 Source: http://www.doksinet III. What More Could be Added to a Law School Program on Professional Well-Being Because the authors could not have been expected to touch on every aspect of positive psychology literature, it might be helpful to offer a few suggestions on other areas to explore, either for the purpose of developing a course or just as a supplement to the fine introduction the book provides. A. Why Attitude Makes a Difference As noted above, Levit and Linder make a point of explaining why forty percent of one’s

happiness and satisfaction with life is subject to one’s control, but law students are a skeptical bunch who may need more persuasion that working on their own outlook on law school and their legal career may make a difference. Fortunately, the positive psychology literature provides a wealth of fascinating empirical studies that support the conclusion that it is possible to remake one’s reality in remarkable ways. It is worth exploring a number of those studies to give concrete reality to the possibility of change. To begin with, psychologists have done some startling research on the extent to which our perceptions influence our physical reality. For example, in 1979, Harvard psychologist Ellen Langer designed a weeklong experiment with a group of seventy-five year-old men. 94 When the men arrived at the retreat center where the experiment was to take place, they were instructed to pretend for the next week that the year was 1959. As part of the experiment, they were required to

dress and act just as they did in 1959 and were even given ID badges with pictures of themselves at that age. The supervisors of the experiment instructed them to discuss people and events that were current in 1959 and act as they did at the time. The experimenters even displayed magazines and other materials from 1959 on the coffee tables at the retreat center. At 94 See ELLEN J. LANGER, COUNTERCLOCKWISE: MINDFUL HEALTH AND THE POWER OF POSSIBILITY (2009). 25 Source: http://www.doksinet the start of the week the men were tested on physical and mental characteristics that typically deteriorate with age, such as physical strength, posture, perception, cognition, and short term memory. In setting up the experiment, Langer hypothesized that by changing the perceived reality of the men’s existence, she could alter the supposedly immutable effects of aging. The results surprised even Langer. After a single week, their memories had improved significantly, they performed better on IQ

tests, their eyesight had improved, they were physically stronger, and even their fingers were longer and less deformed. 95 Even more remarkably, the men appeared younger to those who did not know them. On average, unknown evaluators rated the men in after-photos to be on average three years younger than the same men in photographs taken at the beginning of the week. 96 The illusion of 1959 had become in many respects the physical and mental reality for these men. Researchers found a similar effect ten years later when they tested the eyesight of a number of ordinary individuals and then placed the individuals in flight simulators dressed as pilots. In forty percent of the participants, eyesight actually improved significantly after the time in the flight simulator during which they simply pretended to be pilots. 97 In a 2007 experiment, one of Langer’s students at Harvard devised an experiment that confirmed the effect of mindset on physical reality. 98 The researcher went to four

hotels in the Boston area and met with the cleaning staff. The subjects received a written description of the benefits of exercise and how their daily housekeeping work met the Center for Disease Control’s recommendations for an 95 Id. Id. 97 See Ellen Langer et al., Believing Is Seeing: Using Mindlessness (Mindfully) to Improve Visual Acuity, 21 PSYCHOL. SCI 661 (2010) 98 See Alia J. Crum & Ellen J Langer, Mind-Set Matters: Exercise and the Placebo Effect, 18 PSYCHOL. SCI 165 (2007) 96 26 Source: http://www.doksinet active lifestyle that would burn calories and accompany health benefits. 99 Maids at three other hotels constituted the control group, which was given no such information about the exercise benefits of their job. 100 After four weeks, the informed group showed increases in perceived rate of exercise (although the actual exercise performed by both groups was the same), significant weight loss and lower body fat percentage than the control group, and even reduced

cholesterol. 101 In sum, the researchers concluded, the “results support our hypothesis that increasing perceived exercise independently of actual exercise results in subsequent physiological improvements.” 102 The larger point established by the study was that, as one psychologist later put it, “the mental construction of our daily activities, more than the activity itself, defines our reality.” 103 This principle is reinforced by numerous experiments on the effect of “priming,” in which individuals are primed with the words associated with certain conditions or characteristics and then measured against a control group not so primed. For example, in one experiment, individuals who were primed with words associated with the elderly were tested and compared to a control group on memory and their ability to walk. 104 The primed group showed more evidence of memory loss and a slower gait than the control group. 105 In a similar study with positive priming using words

associated with youth and vigor, the primed group performed 99 Id. at 166 Id. 101 Id. at 168 102 Id. at 170 103 ACHOR, supra note 20, at 71. 104 See John A. Bargh, Mark Chen & Lara Burrown, Automaticity of Social Behavior: Direct Effects of Trait Construct and Stereotype Activation on Action, 71 J. PERSONALITY & SOC BEHAV. 230, 236-37 (1996) 105 Id. at 237 100 27 Source: http://www.doksinet significantly better than the control group. 106 This research is consistent with numerous studies on the so-called placebo effect. An empirical review of placebo studies found that “placebos are about fifty-five percent to sixty percent as effective as most active medications like aspirin and codeine for controlling pain.” 107 Those familiar with the placebo effect would not be surprised to learn that a study of pregnant women with severe nausea showed that their symptoms significantly improved when they were given a placebo, or sugar pill. They might be surprised, however, to

learn that the subjects’ symptoms improved even when the researcher gave them syrup of ipecac (which is typically used to induce vomiting), as long as they were told that it was a medicine that would improve their nausea. 108 In another remarkable study, Japanese researchers rubbed the right arm with a plant the subjects were told (falsely) was poison ivy, and subsequently the arms of all the subjects reacted with the classic symptoms of poison ivy. 109 Then, when the researchers rubbed the left arm of the subjects with a plant they were told was harmless but was in fact poison ivy, only two of the subjects exhibited the symptoms of exposure to poison ivy. 110 The importance of believing in one’s own capacity to improve one’s abilities has been convincingly established by Stanford psychologist Carol Dweck, whose studies have shown that the extent to which someone believes that their intelligence is subject to improvement directly affects their ultimate achievement. 111 Dweck’s

studies have led her to the conclusion that individuals either have a “fixed mindset,” which prompts them to believe that their abilities are 106 Joseph Cesario, E. Tory Higgins & Jason E Plaks, Automatic Social Behavior as Motivated Preparation to Interact, 90 J. PERSONALITY & SOC BEHAV 893, 901 (2006) 107 Sandra Blakeslee, Placebos Prove So Powerful Even Experts Are Surprised; New Studies Explore the Brain’s Triumph Over Reality, N.Y TIMES, Oct 13, 1998, at [need page number] 108 See HERBERT BENSON & MARK STARK, TIMELESS HEALING (1997) [need pincite]. 109 Blakeslee, supra note 107. 110 Id. 111 See CAROL S. DWECK, MINDSET: THE NEW PSYCHOLOGY OF SUCCESS 7 (2006) 28 Source: http://www.doksinet static and not subject to improvement, or a “growth mindset,” which leads them to believe that they can improve their abilities through a concerted effort. As Dweck describes it, the growth mindset operates on the presumption that “although people may differ in every

which way--in their initial talents and aptitudes, interests, or temperaments--everyone can change and grow through application and experience.” 112 Thus, Dweck’s research shows that people with fixed mindsets miss important opportunities to improve themselves and tend to underperform consistently, while those with a growth mindset are consistently able to improve their own abilities. For example, in one study Dweck’s research team divided a large group of students at the beginning of seventh grade into two groups: one made up of those who exhibited a fixed mindset and the other made up of individuals who exhibited a growth mindset. 113 The research team monitored the academic performance of both groups over the next two years and found that the students’ mindsets had an increasingly large impact on math achievement scores as the students progressed through the seventh and eighth grades. Students with a fixed mindset showed no significant increase in math performance, while

those with a growth mindset continually improved over the two-year period. 114 Although the researchers hypothesized that several different reasons could explain why a growth mindset correlated with improved performance, they ultimately believed that the increased motivation associated with the growth mindset is the engine that drives improved performance. Any experienced law professor could see how this research might be usefully applied in 112 Id. See Lisa S. Blackwell, Kali H Trzesnieswki & Carol S Dweck, Implicit Theories of Intelligence Predict Achievement Across an Adolescent Transition: A Longtitudinal Study and an Intervention, 78 CHILD DEV. 246 (2007) 114 Id. 113 29 Source: http://www.doksinet the context of legal education. We have all witnessed the impact of the announcement of first semester grades on law students in our classes. Those who receive high grades are frequently motivated to work even harder because they feel inspired by their success, while students

who perform poorly often assume that they cannot do any better. As their motivation flags, their performance continues to falter. Understanding the importance of continued motivation as explained by Dweck’s research will help students avoid the self-defeating cycle of failure, in which one failure is viewed as so significant that it diminishes future motivation and effort, which leads to further failure. Mindset matters in another way that is crucially important to law students as they plan, and later enter, their legal careers. Yale psychologist Amy Wrzesniewski has identified the importance of mindset in approaching one’s work. According to Wrzesniewski, individuals typically view their work as either a job, a career, or a calling. 115 People who identify their work as a “job” see their work simply as a chore that must be performed to obtain the expected reward of a salary check. These individuals work because they have to support themselves, and they spend their working time

looking forward to their time off when they can pursue more selfconcordant activities. Those who view their jobs as a career work not simply for a paycheck, but also to achieve and advance towards certain long term goals. They care about their work because they want to do well as measured by expected rewards that are based on external evaluations. Finally, those who view their work as a calling see their work as rewarding in and of itself, unconnected to external evaluations and rewards from others. The job may be a calling because it contributes to the well-being of others, or it draws on their own subjective personal strengths and provides them with a sense of meaning and purpose. Unsurprisingly, the latter group turns 115 See Amy Wrzesniewski et al., Jobs, Careers and Callings: People’s Relations to Their Work, 31 J. RES PERSONALITY 21 (1997) 30 Source: http://www.doksinet out to be the happiest. Perhaps Wrzesniewski’s most interesting finding is that how one views one’s

job depends not so much on the particular job but on one’s own mindset. For example, in one study she found that there are many doctors who see their work only as a job and some janitors who see their work as a calling. 116 In another study of administrative assistants, one-third saw their work as a job, one-third as a career, and one-third as a calling; it all depended on the individual mindset of the administrative assistant. 117 The lesson all of these studies is a powerful one for law students. Their experiences in law school and in their subsequent careers are profoundly influenced by their own mindset and how they choose to react to them. It all depends on the attitude with which they approach these experiences. This is exactly why psychologist Sonja Lyubomirsky uses the phrase “creation or construction of happiness,” because research shows that it is in our power to fashion it for ourselves.” 118 Or, as John Milton wrote in Paradise Lost, “The Mind is its own place,

and in itself can make a heaven of hell, a hell of heaven,” a thought echoed by Emerson when he said, “[t]o different minds, the same world is a hell, and a heaven.” It is within the power of law students to create a more meaningful and less stressful law school experience, and it is up to law schools to show them how they can do that. B. Resilience The Importance of Positive Emotions and Their Connection to Emotional Any course on flourishing in law school and in one’s legal career should also include the research on the importance of positive emotions in fostering intellectual creativity and emotional 116 Id. See Amy Wrzesniewski & Jane E. Dutton, Crafting a Job: Revisioning Employees as Active Crafters of Their Work, 26 ACAD. MGMT REV 179 (2001) 118 LYUBOMIRSKY, supra note 47, at 15. 117 31 Source: http://www.doksinet resilience and resources. This research is most closely associated with psychologist Barbara Frederickson, who developed the “broaden and build

theory of positive emotions.” 119 Frederickson’s theory, which is now well established by years of empirical research, suggests that unlike negative emotions, such as fear, anxiety and anger, which narrowly focus the mind and direct the body to a very specific action, positive emotions 120 have the opposite effect on an individual’s cognitive and physical capacity. 121 Positive emotions broaden a person’s thinking by allowing them to exhibit more creativity and improved cognition than individuals experiencing negative emotions. 122 Indeed, one study showed that we literally see more of what is around us when primed with positive feelings. In this study the subjects were divided into two groups, one primed with positive emotions and the other primed with negative. 123 Both groups were shown a series of pictures and asked to identify and recall various aspects of the images. The subjects who were negatively primed missed significant parts of the pictures’ background, while

those positively primed did not. 124 My personal favorite study of the broadening effect of positive emotions involved a group of doctors who were divided into three groups and tested on their ability to make a difficult medical diagnosis. 125 Before the diagnostic exercise, one of the groups was primed to experience a positive emotion by a gift of candy, one group was read a series of statements about 119 See FREDRICKSON, supra note 28. These include “joy, gratitude, serenity, interests, hope, pride, amusement, inspiration, awe and love.” FREDRICKSON, supra note 28, at 39 121 Barbara L. Fredrickson, What Good Are Positive Emotions?, 2 REV GEN PSYCHOL 300, 307 (1998). 122 FREDRICKSON, supra note 28, at 39. 123 See Taylor W. Schmitz, Eve De Rosa, & Adam K Anderson, Opposing Influences of Affective State Valence on Visual Cortical Encoding, 29 J. NEUROSCIENCE 7199 (2009) 124 Id. 125 See Carlos A. Estrada, Alice M Isen &Mark J Young, Positive Affect Facilitates Integration of

Information and Decreases Anchoring in Reasoning Among Physicians, 72 ORGANIZATIONAL BEHAV. & HUM DECISION PROCESSES 117 (1997) 120 32 Source: http://www.doksinet the importance of humanistic medicine, and one was a control group. The diagnostic exercise was designed to test both how quickly the doctors could perform the proper diagnosis and how well they resisted “anchoring,” which is the tendency to focus on the first available data and resist moving off one’s initial analysis. 126 The doctors who were positively primed with candy made the right diagnosis significantly faster (nearly twice as fast as the control group), and showed 60 percent less anchoring than the control group as well. 127 Lawyers equally may benefit from broader and more creative thinking, and positive emotions can help them achieve that goal. The second aspect of the broaden and build theory is the idea that positive emotions also serve to build our emotional and physical resilience and lead to an

upward spiral of additional positive feelings. 128 Researchers have established how negative feelings cause measurable physical changes in a person, including increased blood pressure, increased heart rate, and peripheral vasoconstriction. 129 Positive emotions have the capacity to reverse these adverse physical effects and, in the words of researcher Barbara Frederickson, have an “undoing effect” that returns the body to a more peaceful state. 130 As Fredrickson has concluded, “evidence for the undoing effect of positive emotions suggests that people might improve their psychological well-being, and perhaps also their physical health, by cultivating experiences of positive emotions at opportune moments to cope with negative emotions.” 131 Positive emotions help one become more resilient and “bounce back from stressful experiences quickly and efficiently, just 126 Id. at 119 Id. at 126-27 128 See FREDRICKSON, supra note 28. 129 See Barbara L. Fredrickson et al, The Undoing

Effect of Positive Emotions, 24 MOTIVATION & EMOTION 237 (2000). 130 Id. 131 Barbara L. Fredrickson, The Role of Positive Emotions in Positive Psychology, 56 AM PSYCHOLOGIST 218, 222 (2001). 127 33 Source: http://www.doksinet as resilient metals bend but do not break.” 132 Most importantly, although negative emotions can create a downward spiral that leads to increased stress and depression, positive emotions can have the opposite effect and create an upward spiral of increased mental health and well-being. 133 Fredrickson has “found that what matters most is your positivity ratio. It is a way to characterize the amount of your heartfelt positivity relative to the amount of your heart-wrenching negativity. Stated formally, your positivity ratio is your frequency of positivity over any given time span, divided by your frequency of negativity over that same span.” 134 The key factor in determining whether one begins a downward or an upward spiral is this ratio of positive

emotions to negative emotions. Frederickson has found that if the ratio is below 3 to 1, “people get pulled into a downward spiral fueled by negativity. Their behavior becomes painfully predictableeven rigid They feel burdened; at times, even lifeless. Yet above this same ratio, people seem to take off, drawn along an upward spiral energized by positivity. Their behavior becomes less predictable and more creative. They grow The feel uplifted and alive” 135 Interestingly, Marcial Losada, the researcher who came up with the exact ratio that proves to be the tipping point, 136 developed his theory in the context of studies of successful business teams. 137 Losada examined the interactions within different business teams and recorded the number of positive and negative interactions within the groups. Groups in which the positive-to-negative ratio was above his calculated ratio (now known as the “Losada Line”) 132 Id. Id. 134 FREDRICKSON, supra note 28, at 16. 135 Id. at 16, 128-29

136 The precise ratio as determined by Losada is 2.9012 See Marcial Losada & Emily Heaphy, The Role of Positivity and Connectivity in the Performance of Business Teams: A Nonlinear Dynamics Model, 47 AM. BEHAV SCIENTIST 740 (2004) 137 Id. 133 34 Source: http://www.doksinet were significantly more likely to attain objectively successful business results. 138 Positivity, thus, works not only for individuals, but for groups as well. Lawyers, who frequently must work in teams, would do well to heed the Losada Line and understand the importance of cultivating positive emotions, not only for individual flourishing, but also for success in their team endeavors. 139 Most importantly, individuals can change their positivity ratio, develop more psychological resilience, and broader and more flexible thinking. 140 Frederickson’s own website makes it possible to measure one’s positivity ratio and guide one’s self to experience more positive emotions and minimize the effect of

negative ones. 141 Because of the significant benefits of improving one’s positivity ratio, the broaden and build theory of positive emotions should be a part of any law school course on happiness. C. Using One’s Signature Strengths Levit and Linder briefly discuss the concept of identifying and practicing one’s signature strengths. 142 This brief discussion takes place in the context of a broader discussion of why it is important to identify one’s skills as part of an exercise to help students focus on the type of legal practice that may be most satisfying and meaningful to them. 143 In particular, as previously noted, Levit and Linder discuss Tal Ben-Shahar’s suggestion that students draw a Venn diagram with three circles, one representing things that give the student pleasure, the second, things that 138 Id. For what it’s worth, a similar positivity ratio predicts the success or failure of marriages and long-term relationships. See FREDERICKSON, supra note 28, at

131-32 140 FREDERICKSON, supra note 28, at 146-47. 141 Id.; see POSITIVITY RATIO, http://wwwpositivityratiocom (last visited Mar 27, 2012) 142 See Levit & Linder, supra note 1, at 146-147. 143 Id. at 145-49 139 35 Source: http://www.doksinet give the student meaning, and the third, things at which the student excels. 144 The problem with discussing the concept of signature strengths in the context of identifying one’s abilities is that readers are likely to equate the concept of signature strengths with the identification of one’s abilities even though the two concepts are significantly different. The idea of strengths as discussed in Ben-Shahar’s Venn diagram, as well as in the colloquial meaning of the term, focuses on an individual’s performance and how that performance might be measured by other people. Psychologists generally refer to this conception of strength as “extrinsic strengths” because they focus on how others measure one’s abilities and performance.

145 As two of the leading researchers on the subjects of extrinsic strengths put it, “[a] strength is the ability to provide consistent, near-perfect performance in a given activity. An individual strength might be the person’s ability to manage several activities at the same time flawlessly, or an organizational strength might be its capacity for constant innovation . Once dominant talents are refined with knowledge and skills, they can become strengths.” 146 It is certainly important to understand one’s extrinsic strengths in order to identify the kind of work that may be the core of a satisfying career, and there are methods for students to identify and understand where they have such extrinsic strengths. 147 The positive psychology concept of signature strengths, however, is quite different from the notion of extrinsic strengths. The concept of signature strengths, which may be called intrinsic rather than extrinsic 144 See BEN-SHAHAR, , supra note 75, at 54. The place

where these three circles intersect is likely to be the most promising area of work. In the context of this suggestion, it is clear that Tal Ben-Shahar is discussing strengths as one’s abilities. 145 See MARCUS BUCKINGHAM & DONALD O. CLIFTON, NOW, DISCOVER YOUR STRENGTHS (2001). 146 Id. at [need pincite] 147 For example, students can use the Gallop Organization’s strength-finder survey in order to identify these kinds of extrinsic strengths. See CLIFTON STRENGTHS FINDER, http://www.strengthsfindercom (last visited Mar 27, 2012) 36 Source: http://www.doksinet strengths, is more akin to the idea of subjectively meaningful personal virtues. William James, the father of American psychology, captured this concept when he wrote, “I have often thought that the best way to define a man’s character would be to seek out the particular mental or moral attitude in which, when it came upon him, he felt himself most deeply and intensively active and alive. At such moments, there is

a voice inside which speaks and says, “‘This is the real me’” 148 Christopher Peterson of the University of Michigan and Martin Seligman of the University of Pennsylvania developed a list of twenty-four cross-cultural character strengths that most contribute to human flourishing. 149 This classification, called Values In Action (“VIA”), is intended to be the counterpart of the American Psychological Association’s Diagnostic and Statistical Manual of Mental Disorders (“DSM”). 150 While the DSM catalogs the range of psychological problems, the VIA describes and classifies “strengths and virtues that enable human thriving.” 151 The VIA sets forth six categories of virtues that meet a series of criteria and are recognized in nearly every culture across the globe: Wisdom, Courage, Humanity, Justice, Temperance, and Transcendence. 152 Peterson and Seligman identify in the VIA twenty-four strengths or virtues that fall within these six broad categories. 153 These

intrinsic character 148 ROBERT D. RICHARDSON, WILLIAM JAMES: IN THE MAELSTROM OF AMERICAN MODERNISM 181 (2007). 149 See CHRISTOPHER PETERSON & MARTIN E. P SELIGMAN, CHARACTER STRENGTHS AND VIRTUES: A HANDBOOK AND CLASSIFICATION (2004). 150 Id. 151 Seligman, supra note 13, at 411. 152 Id. 153 As described by Seligman, the criteria for inclusion in the VIA are (1) ubiquitywidely recognized across cultures, (2) fulfillingcontributes to individual fulfillment, satisfaction, and happiness broadly construed, (3) morally valuedvalued in its own right and not as a means to an end, (4) does not diminish otherselevates others who witness it, producing admiration, not jealousy, (5) non-felicitous oppositehas obvious antonyms that are “negative”, (6) traitlikean individual difference with demonstrable generality and stability, (7) measurablehas been successfully measured by researchers as an individual difference, (8) distinctivenessnot redundant (conceptually or empirically) with other

character strengths, (9) paradigmsstrikingly 37 Source: http://www.doksinet strengths are identified as follows. Virtue and strength Definition 1. Wisdom and Knowledge Creativity Curiosity Open-mindedness Love of learning Perspective Cognitive strengths that entail the acquisition and use of knowledge Thinking of novel and productive ways to do things Taking an interest in all of ongoing experience Thinking things through and examining them from all sides Mastering new skills, topics, and bodies of knowledge Being able to provide wise counsel to others 2. Courage Authenticity Bravery Persistence Zest Emotional strengths that involve the exercise of will to accomplish goals in the face of opposition, external or internal Speaking the truth and presenting oneself in a genuine way Not shrinking from threat, challenge, difficulty, or pain Finishing what one starts Approaching life with excitement and energy 3. Humanity Kindness Love Social Intelligence Interpersonal strengths

that involve “tending and befriending” others Doing favors and good deeds for others Valuing close relations with others Being aware of the motives and feelings of self and others 4. Justice Fairness Leadership Teamwork Civic strengths that underlie healthy community life Treating all people the same according to notions of fairness and justice Organizing group activities and seeing that they happen Working well as members of a group or team 5. Temperance Forgiveness Modesty Prudence Strengths that protect against excess Forgiving those who have done wrong Letting one’s accomplishments speak for themselves Being careful about one’s choices; not saying or doing things that might later be regretted Regulating what one feels and does Self-regulation 6. Transcendence Strengths that forge connections to the larger universe and provide meaning Appreciation of Noticing and appreciating beauty, excellence, and/or skilled Beauty and Excellence performance in all domains of life

Gratitude Being aware of and thankful for the good things that happen Hope Expecting the best and working to achieve it Humor Liking to laugh and tease; bringing smiles to other people 154 Religiousness Having coherent beliefs about the higher purpose and meaning of life embodied in some individuals, (10) prodigiesprecociously shown by some children or youth, (11) selective absencemissing altogether in some individuals, and (12) institutionshe deliberate targeting of societal practices and rituals to try to cultivate it. Id 154 PETERSON & SELIGMAN, supra note 149, at 29-30. 38 Source: http://www.doksinet Which particular strengths from this list are most meaningful to a particular individual is a subjective and intrinsic matter, and the importance of any particular intrinsic strength varies from person to person. Peterson and Seligman developed a survey instrument that helps an individual identify those strengths that are most meaningful and important to their own lives. This

instrument, called the VIA inventory of strengths, does not identify the virtues or strengths that an outside evaluator would identify as an individual’s abilities, but rather it identifies those strengths that are most meaningful and subjectively important to an individual. These “signature strengths” remain relatively fixed over time, although they can be influenced by outside events and focused efforts to change one’s lifestyle. 155 Thus, the concept of signature strengths, or intrinsic strengths, helps to identify a “preexisting capacity for a particular way of behaving, thinking, or feeling that is authentic and energizing to the user, and enables optimum functioning, development, and performance.” 156 Intrinsic strengths provide meaning and focus to one’s life, and using them frequently contributes to a sense of authenticity that leads to greater energy, 157 goal attainment, 158 and well-being. 159 Identifying one’s signature strengths can have important benefits

for law students. First, it can aid the identification of the particular jobs that may provide the most satisfying career for a particular law student. This is the context in which Levit and Linder discuss the concept, and it is clearly relevant to achieving that goal. In addition, however, it is equally important for law students to identify their signature strengths for a more immediately pressing reason: using 155 See id. at 643; Christopher Peterson & Martin E P Seligman, Character Strengths Before and After September 11, 14 PSYCOL. SCI 381 (2003) 156 ALEX LINLEY, AVERAGE TO A+: REALIZING STRENGTHS IN YOURSELF AND OTHERS 9 (2008). 157 Id. at 12 158 Id. at 45-47 159 Id. at 154 39 Source: http://www.doksinet signature strengths on a daily basis may help to buffer them against stress and depression. One study showed that individuals who identified their top five strengths and used them in a new and different way every day for one week were significantly happier and less

depressed than those using a placebo exercise. 160 In addition, these benefits persist even after the exercise has been completed, up to six months after the one week exercise. 161 In addition, a study of law students showed that students who found ways to use their top strengths were less likely to suffer from depression and stress and more likely to report satisfaction with their life. 162 Thus, identifying and using one’s signature intrinsic strengths is an important addition to the list of positive psychology interventions that should be a part of any law school course on happiness in one’s legal career. D. The Importance of Teaching Specific Positive Psychology Interventions Levit and Linder focus most of their attention in the book on how lawyers can build more satisfying careers. When they discuss law students, they similarly focus on how law students can direct their education towards finding careers that are more satisfying and fulfilling. They do not, however, spend much

time examining specific positive psychology interventions that might help law students avoid the stress and depression associated with law school. It is important for any course on happiness in law school and in one’s subsequent career to explore certain key positive psychology interventions that are expressly designed to counter the kinds of problems that, as discussed above, law school tends to create. A few key positive psychology principles drawn from recent research are discussed below. 1. 160 161 162 The ABCD Model of Interpretation Seligman et. al, supra note 13, at 415-16 Id. at 418-19 See Peterson &Peterson, supra note 9, at 413. 40 Source: http://www.doksinet As discussed above, the Tetris effect created by legal education causes law students to focus inordinately on their own flaws and perceived shortcomings, as they tend to see problems as pervasive and permanent rather than local and temporary. 163 One way to help students counteract that tendency is to teach

them the ABCD model of interpretation, which is a cognitive exercise that allows students to challenge the negative assumptions they may bring to their own self assessment. The ABCD model “has a long and rich history starting with Albert Ellis, father of cognitive therapy, then adapted by Martin Seligman (see Learned Optimism and Authentic Happiness) and also put to great use by Karen Reivich and Andrew Shatte in their excellent book, The Resilience Factor. 164 In this model, “A” stands for adversity, the event that students cannot change, whether it is a bad performance in class, a bad grade in the course, a series of bad grades in one semester, or an entire law school career of sub-par grades. The B stands for one’s belief or reaction to the event, why we think it happened and what we believe it means for our future. It is this belief, often not consciously identified by students, that leads them to conclude the setback is either local and temporary or permanent and pervasive

and permanent. The belief one holds leads to C, the expected consequencewhat is the likely result of the negative event. A bad day in class means that the student has no aptitude for legal analysis and will never become a good lawyer. A bad grade means that the student will not be able to get a job. A bad semester means that the student will never be able to recover and earn better grades. A bad law school GPA means that the student might as well quit because he or she will never become a successful lawyer. The answer to these negative thoughts (thoughts that are likely to be accentuated by the negative Tetris effect of law school education) is D or disputation, which involves first 163 164 See supra text accompaying notes 28-34. ACHOR, supra note 20, at 219 n. 27 41 Source: http://www.doksinet identifying the belief as a subjective determination and not an immutable fact that inevitably leads to a bad consequence. Psychologists suggest that we can effectively dispute our belief

and change the perceived consequence by externalizing the negative voice (by pretending to hear it from another person) and then arguing against that voice on behalf of a more optimistic and less negative belief. 165 So, in this mode of analysis, students would respond to a bad day in class by disputing the negative conclusion and arguing to themselves that a bad day in class is simply one bad day in class that will not necessarily reoccur and does not necessarily predict anything about their success in law school. Everyone has bad days; everyone makes mistakes; everyone can recover and do better the next time around. In the case of a bad grade, it is simply one grade out of many in law school and does not predict failure in other courses or in a job search. Few people have perfect law school records, and it is simply not reasonable to aspire to one. Similarly, one bad semester does not necessarily mean that a student who remains committed to the legal education process and continues

to work hard cannot improve one’s grades over the rest of law school. Finally, even an entire law school career of bad grades does not mean that one cannot become a successful lawyer. Law school teaches only a small slice of the skills necessary to become a successful lawyer, and there are plenty of students with poor law school records who have gone on to brilliant legal careers. It is simply a matter of developing those skills in areas where a student has a particular aptitude, and pursing a legal career that will take advantage of those particular skills. 2. The Gratitude Exercise The tendency of law school to create pessimistic approaches to life that look for and anticipate problems and faults can also be countered through exercises that build alternative 165 See id. at 125 42 Source: http://www.doksinet neuropathways, which make it easier for law students to identify and value the many good things in their lives. The best-known positive psychology intervention is an

exercise that requires students at the end of each day to write down in a journal three to five things that happened during the day for which they are grateful. As Sonja Lyubomirsky argued, “adaptation to all things positive is essentially the enemy of happiness, and one of the keys to becoming happier lies in combating its effect, which gratitude does quite nicely. By preventing people from taking the good things in their lives for granted--from adapting to their positive life circumstances, the practice of gratitude can directly counteract the effects of hedonic adaptation.” 166 This exercise has a remarkable record of producing positive results, including reduced stress and depression, compared to control groups who do not use the exercise. 167 In one study participants were asked to write down three things that went well each day for a one week period and “asked to provide a causal explanation for each good thing.” 168 The result of the exercise was “increased happiness

and decreased depressive symptoms for six months.” 169 The key finding of this study, and numerous other studies with similar results, is that the daily identification of good things in one’s life does not simply provide an immediate infusion of happiness. Eating a chocolate bar would do that, but it would provide no lasting benefits The gratitude exercise forces individuals to develop a habit of looking for good things in their own lives. This habit builds a new neuropathway to compete with the neuropathways generated by law school education. When this competing neuropathway is habitually developed and exercised, individuals are more likely to think of their lives in a positive way and more likely to 166 LYUBOMIRSKY, supra note 47, at 95. See Seligman et al., supra note 13; see also Sonja Lyubomirsky, Kennon M Sheldon & David Schkade, Pursuing Happiness: The Architecture of Sustainable Change, 9 REV. GEN PSYCHOL. 111 (2005) 168 Seligman et al., supra note 13, at 416 169 Id.

167 43 Source: http://www.doksinet resist the negative Tetris effect of their law school education. 170 The key to the usefulness of this exercise in law school is that it uses the principle of the Tetris effect to directly counteract the negative training that students receive in their legal education. 3. Goal Setting Students could be taught a whole series of well-validated techniques for managing the work of their legal education, but one in particular stands out because of its extensive empirical testing. It is well-established that individuals who develop self-concordant goals can increase their happiness in ways that are not only immediately noticeable but persist over long periods of time. 171 Psychologists who have studied goal-setting theory have established a number of important conclusions that can usefully guide law students in their legal careers. First, goals serve an important “directive function; they direct attention and effort toward goal-relevant activities

and away from goal-irrelevant activities.” 172 Second, goals serve to energize people and lead them to greater efforts. 173 Third, goals have an influence on persistence and one’s ability to stay with a difficult task. 174 Finally, goals help people focus on the specific tasks that need to be performed in order to reach a desired result. 175 Psychologist Sonja Lyubomirsky not only documented the important benefits of “committed goal pursuit,” but also identified a series of important variables affecting the kinds of 170 See Robert A. Emmons & Michael E McCullough, Counting Blessings Verses Burdens: An Experimental Investigation of Gratitude and Subjective Well-Being in Daily Life, 84 J. PERSONALITY & SOC. PSYCHOL 377 (2003) 171 See Kennon M. Sheldon & Linda Houser-Marko, Self-Concordance, Goal Attainment, and the Pursuit of Happiness: Can There Be an Upward Spiral?, 80 J. PERSONALITY & SOC PSYCHOL. 152 (2001) 172 Edwin A. Locke & Gary P Latham, Building a

Practically Useful Theory of Goal Setting and Task Motivation: A 35-Year Odyssey, 57 AM. PSYCHOLOGIST 705, 706 (2002) 173 Id. at 707 174 Id. 175 Id. 44 Source: http://www.doksinet goals that are most likely to bring positive lasting benefits to individual happiness. 176 Lyubomirsky argues that goals need to be intrinsic, authentic, positive (in the sense of seeking a desirable outcome rather than avoiding an undesirable outcome), harmonious, flexible and appropriate, and focused on activities rather than changed circumstances. 177 Full exploration of these principles would enable law students to achieve a happier law school and, ultimately, career experience. IV. Conclusion The Happy Lawyer is a tremendous boon for law students, and law schools should jump at the chance to use it to introduce law students to the important new psychological research on happiness and how it impacts students’ careers. The case for the creation of courses on how to find a satisfying career in the

law is too strong to dispute. Law schools teach skills that are essential for any lawyer, but leave law students more likely to suffer from stress and depression. We need to balance the analytical skills we teach with skills that will help students to find greater happiness in their personal lives and more rewarding careers as lawyers. Fortunately, The Happy Lawyer provides an excellent foundation for a course on how to accomplish those goals. The authors have done the hard work of scouring the scientific literature on happiness to lay out a solid understanding of what the latest research tells us about what makes individuals thrive in their personal and professional lives. They have thoughtfully applied this literature to a wide range of issues faced by law students and lawyers as they struggle to build satisfying careers. Every law student would benefit from the research and important insights the book presents, and every law school should see to it that their students learn from it

and the other positive psychology research. Together, the book and the positive psychology 176 177 LYUBOMIRSKY, supra note 47, at 208-15. Id. 45 Source: http://www.doksinet research has the potential to make every student’s law school experience and subsequent legal careers much happier and more meaningful. 46