With David Cameron and Barack Obama currently cementing their special relationship, the focus is very much on the links that bind the UK and US.

Our love of Friends repeats, Big Macs and David Beckham is obvious, but the prevailing notion is of something deep-rooted and intrinsic that brings us together, particularly at times of crisis. Yet on our attitudes to the legal profession, we apparently couldn’t be more different.

The UK, following Australia’s lead, has gambled on the liberalisation of the market, convinced it can boost customer service and reduce costs in one ambitious swoop. This year is likely to resemble the ‘grab a grand’ game from Noel’s House Party, with contestants clasping at every opportunity to clutch the cash prizes that encircle them.

We’ve made our bed, and we’re likely to be sharing it with some major supermarkets, pin-striped investors and indiscriminate claims managers. It remains to be seen who is pushed out and forced to sleep on the floor. In America, the authorities regard an open legal market with all the enthusiasm of an agoraphobic taking a stroll through Central Park.

There is fear, suspicion and outright contempt at the prospect of watering down the profession or exposing the ethics that bind it.

Only last week the New York firm Jacoby & Meyers was thwarted in its attempt to challenge laws preventing non-lawyer investment. Whilst the judge denied the claim on a technicality, he still referred to the idea as a ‘dance with the devil’, giving some indication of the judiciary’s feelings towards any alternative business structure.

The American Bar Association’s (ABA's) Commission on Ethics 20/20 is currently looking into non-lawyers being allowed to own a limited, non-controlling share in a law firm. But it faces an uphill battle to convince the profession as a whole.

The New York Bar Association said it had failed to find a single lawyer in favour during two years of consultation with the profession. Last month president Vincent E Doyle told the commission his group ‘remains opposed’ to non-lawyer ownership, although it conceded the latest proposal was preferable to a less restrictive approach put forward (and defeated) in 2000. In New Jersey, the bar association sees ‘no operational need’ for non-lawyer individuals already working in law firms to gain access to ownership.

It told the ABA consultation it is ‘greatly distrustful of any encroachment on attorneys’ accountability and independent professional judgment, fearful of the temptation to appease non-attorney ownership interests, and concerned about the potential for confusion on the part of those dealing with the firm’s principals.’

Another respondent, Charles Ruffin, simply added: ‘I will make this quick. The law is a profession, not a business.’ And yet, and yet. There is still the feeling this is a bandwagon heading slowly in one direction. There is unrest amongst larger firms who feel their competitiveness is restricted by rules not placed on rivals in other jurisdictions. Smaller firms, keen to expand but without the capital to do so, want the chance to attract investment.

In the ABA consultation, consumer watchdog Responsive Law accuses the authorities of seeking a model that will still leave the US 20 years behind the UK and Australia. It maintains that judicial regulation and public accountability will see off concerns about ethics and conflicts. It claims an open market will boost innovation and drive down costs.

These are the same arguments put forward pre-2007 in the UK, and they’ll grow stronger if our leap in the dark is perceived to be successful the other side of the pond. For a country that spawned Gordon Gecko and Ronald McDonald, the US is curiously reticent about non-lawyer investment. That may be admirable, but it’s probably not a position it can hold forever.

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