381 of 606 Law Firms Publishing Case Results Carry No Disclaimer
A law firm that advertises what it won for somebody else is expected to say that the figure predicts nothing about anyone else's case. We went looking for a case results page on all 1,388 firms in this directory and found one on 645. Of the 606 that publish at least one outcome, 225 carry that notice on the page and 381 do not.
What we measured
A case results page is the one piece of a law firm's website that every hiring guide tells you to read. It is also the one page where a firm puts a number next to its own name.
We looked for that page on every firm in this directory and recorded four things about the ones we found: how many distinct outcomes it lists, whether a dollar figure is attached to any of them, whether a court or county is named, and whether the page carries a notice saying that a past result does not predict another one.
The fourth is the only one of the four that is anybody's rule. A firm chooses how many results to publish and how much detail to give. The notice is the part a regulator has an opinion about, which makes it the one measurement here where the absence means something specific.
We count the page, not the money. The amounts these pages carry are what a firm says it recovered, nothing in our records marks any of them verified, and we repeat none of them anywhere on this site.
What the pages carry
The first finding is about the denominator rather than the notice. 743 of the 1,388 firms here publish no case results page we could find.
What we found when we went looking for a case results page
- 225Results published, with the notice on the page16% of firms
- 381Results published, no notice on the page27% of firms
- 39A results page that told us nothing countable3% of firms
- 743No case results page at all54% of firms
Of the 608 pages we could read, 606 publish at least one outcome. 225 of those put the notice on the same page and 381 do not.
Narrowing to the firms the question is sharpest about changes almost nothing. 539 firms print a dollar figure beside an outcome, and 338 of them print no notice with it.
The notice is not a function of how much a firm publishes. The median publishing firm lists 13 distinct figures where the notice is there and 14 where it is not.
Firms carrying the notice beside their results, by state
New York is the one state here whose rule names an exact sentence, and 45 of its 93 publishing firms carry nothing like it on that page. It is also the highest share of the eight, which is the more useful way to read it: the best-covered large market in this directory is not close to unanimous.
Where the sentence actually lives
This is the part that keeps the finding honest, and it needed a second field to establish. Our site crawl records separately whether a firm keeps a disclaimer, legal notice or terms page anywhere on its website, which is a different fact from what is printed beside the figures.
Of the 376 publishing firms with no notice on the results page whose sites we crawled, 242 keep such a page elsewhere and 134 have neither.
So this is mostly a question of placement rather than of candour. The sentence exists; it is one click away from the number it is about, in a footer link most readers will never open.
Two fields that sound like one fact are not one fact, and conflating them is how a page here once published a sentence that was false. We counted both and report both. We counted the rest of what these sites publish in a separate study, where the same disclaimer page turns up as one of five page types.
What the rules say, and about whom
Lawyer advertising is governed by each state's own rules of professional conduct, and they are not the same rules. We have read one of them closely enough to quote it, so one is all this page will name.
New York's Rule 7.1(e)(3) requires a specific disclaimer where an advertisement is reasonably likely to create an expectation about results. The state bar's ethics committee has held that paraphrasing the required wording does not satisfy the rule, which matters for our count: our pattern accepts "results may vary" and "every case is different" alongside the exact phrase, so the figures above are generous.
Elsewhere the picture is a patchwork, and we do not report it as anything else. The Florida Bar's board has adopted guidance treating some past-results advertising as presumptively misleading in short-form media. Nothing on this page asserts what any state outside New York requires, because nobody here has read those rules.
The reader-facing point does not depend on any of that. A number on a marketing page is one firm's account of one case, and whether a state compels the sentence or not, the sentence is true.
What our own score does with it
Sub-factor B3 of the LFL Certification Score is this measurement, worth 4 of 100 points, and it is all or nothing: a firm either has the notice on that page or it does not. The methodology sets out every sub-factor.
Three things about that are worth saying against ourselves.
It marks firms down for results they never published. Of the 1,288 firms scored through this branch of pillar B, 1,064 score zero on B3, and 684 of those publish no case results at all. A firm that advertises nothing cannot fail to disclaim it, and our engine charges it 4 points anyway.
The same sentence is paid for in one pillar and not in another. Sub-factor D1 awards half a point for a disclaimer or terms page existing on the site. So the 242 firms that keep the sentence one click away collect the D1 half point and lose the B3 four, for a difference that is about where a link sits.
Most of the score gap between the two groups is the sub-factor itself. Firms carrying the notice average 49.4 raw points against 42.5, a gap of 6.9. B3 alone accounts for 3.9 of it, which is 57%. Our score says these firms are better and is mostly saying that they carry the sentence we award points for carrying.
What it does not predict
The obvious story would be that the firms making the biggest claims are the ones leaving the caveat off. We computed it before writing it, and it is the other way round.
239 firms publish a firm-wide recovery total of the "more than X recovered for our clients" kind alongside their individual outcomes. 44% of them carry the notice, against 33% of the 367 firms publishing individual outcomes only. The firms advertising hardest are more careful about the disclaimer, not less.
The two groups, on our scale and on Google's
Clients do not appear to notice at all. Mean Google rating is 4.86 for firms carrying the notice and 4.86 for firms without it, a difference of 0.00 of a star across 606 firms.
That is the shape earlier studies here keep finding. Almost everything a firm publishes about itself rises with its search visibility, and the rating its clients gave it does not move with any of it.
The firms that do the whole thing are worth naming, and they are named in one direction only: a firm with no notice beside its figures may keep one in a footer our crawl does not read, and this record cannot tell those apart. The Case Handler publishes 151 distinct figures with both a court named and the notice on the page, and Morgan & Morgan publishes 113. Both sit in New York and Los Angeles, and the court half of that is a fact about our own pattern before it is a fact about any market: it is written around New York's courts, as the limits below say.
What this does not measure
One page, not a website. The notice is counted on the results page and nowhere else. A firm carrying it in a global footer that our crawl reads as navigation rather than as page text is recorded as not carrying it, which is the single largest source of error here and is the reason the section above counts the separate disclaimer page.
A pattern, not a rule. Our check accepts several wordings. New York requires one exact sentence, so the share of firms meeting New York's rule is lower than the share counted here, by an amount we have not measured.
A court named is a New York court. The venue pattern behind the "court named" figure is written around New York's courts and counties, which is why 110 of 606 publishing firms register one. That figure measures our pattern, and no national claim is built on it anywhere above.
Nothing here verifies an outcome. We do not check any published figure against a docket. A firm publishing results carefully, with the notice and a court, is a firm publishing carefully, which is a real thing to know and is not the same as a confirmed record.
If we read the wrong page for a firm, or missed one, every profile links to the page we read. Firms can correct that here, and the companion study on criminal defense firms covers the other half of this question, which is how many firms publish any outcome at all.
Results pages read between September 10, 2026 and October 20, 2026. Disclaimer and terms pages come from a separate site crawl that carries no date, which is a known gap in our own records.