Law School Admissions
Do Online JD Graduates Pass the Bar? What the Data Actually Shows in 2026
Lawyers often say you cannot learn to practice law through a screen. We went looking for the bar results to test that. The first finding is that most online JD programs do not publish any. The few that do tell a more mixed story than either side of the debate expects.
The bottom line
The ABA does not publish bar passage results by delivery mode, and most law schools report only one school-wide number. Of the programs that do report their online or hybrid students separately, Syracuse and Dayton are in line with or ahead of the national first-time rate, while Mitchell Hamline’s blended learning graduates trailed its in-person graduates on the July 2023 exam. Before enrolling, ask each program for its online students’ results, how many took the exam, and in which states.
88%
Syracuse online JD graduates who passed on the first attempt (110 of 125)
90%
Dayton hybrid JD first-time pass rate, July 2025 bar
73.96%
Mitchell Hamline blended graduates, July 2023, vs 83.64% in person
84.10%
National first-time pass rate for all ABA law schools in 2025
In this guide
Why this question is so hard to answer
Twenty two law schools now have ABA approval to offer a JD mostly or entirely online, up from seven in early 2022. You would expect a clear record of how their graduates do on the bar exam. There is not one.
Every ABA approved law school files a bar passage report each year, but it covers the whole school. It does not separate online or hybrid students from students who attended in person. In January 2025, the ABA Journal reported that the ABA’s Council of the Section of Legal Education was still “in the process of gathering data from the existing ABA-accredited online programs related to graduation and job placement.”
So for most programs, a prospective student has no public way to know how that program’s online graduates perform. A handful of schools have chosen to share their numbers anyway.
What the programs that report actually show
| Program | Online or hybrid result | Comparison | Source |
|---|---|---|---|
| Syracuse University (JDinteractive, hybrid) | 110 of 125 graduates (88%) passed on the first attempt. 13 of 14 (93%) passed the New York bar on the first attempt. | Cumulative figures as reported in January 2025 | ABA Journal |
| University of Dayton (Online Hybrid JD) | 90% first-time pass rate on the July 2025 bar. 91% first-time since the program launched in 2019 (41 of 45 as of April 2025). | School overall: 88% first-time on the July 2025 bar | University of Dayton |
| Mitchell Hamline (Blended Learning JD, hybrid) | 73.96% first-time pass rate on the July 2023 bar | In-person graduates: 83.64% on the same exam | ABA Journal |
| Northeastern University (FlexJD, primarily online) | “100% bar passage rate for FlexJD students in 2025” | No number of takers or first-time qualifier given | Northeastern |
| St. Mary’s University (fully online JD) | First graduates finished in December 2025 and May 2026. Results for the online cohort have not been published. | Pending | St. Mary’s |
We checked program pages, school news releases, and ABA bar passage disclosures in September 2026. For the other approved programs, we found no public bar results reported separately for online or hybrid students.
Two things stand out. First, the two programs that publish cumulative results are not underperforming. Syracuse’s cumulative first-time rate and Dayton’s July 2025 result both sit at or above the national first-time rate, and Dayton’s hybrid students slightly outperformed the school as a whole on the same exam.
Second, Mitchell Hamline’s comparison went the other way. On the July 2023 bar, Mitchell Hamline’s blended learning graduates passed at a rate nearly ten points lower than its in-person graduates. Mitchell Hamline, then William Mitchell College of Law, was the first ABA approved law school cleared to offer a largely online JD, announced in January 2014, so this is not a new program working out early problems.
The honest summary is that the results are mixed, the samples are small, and most programs are not reporting at all.
The national benchmark
According to the ABA’s March 2026 release, first-time takers from ABA approved law schools passed at an aggregate rate of 84.10% in 2025, up from 83.02% in 2024. Within two years of graduation, 92.15% of 2023 graduates who sat for a bar exam had passed.
The ABA’s accreditation standard sets a floor, not a target. Under Standard 316, at least 75% of a school’s graduates who sit for a bar exam must pass within two years of graduation. Because that standard is measured school-wide, an online program’s results can be diluted by a larger in-person class.
How to read these numbers
- Small groups swing easily. Dayton’s cumulative figure covers 45 graduates. Two or three results can move a small cohort’s rate by several points.
- Cumulative and single-exam figures are different measures. Syracuse’s 88% covers every online graduate who had taken the bar as of early 2025. Dayton’s 90% covers one exam. They are not directly comparable to each other or to a single year’s national rate.
- First-time and ultimate rates answer different questions. First-time rates show how ready graduates are on their first attempt. Ultimate rates show whether they eventually pass.
- Marketing claims deserve follow-up questions. A “100%” figure without the number of takers or whether they were first-time takers is a starting point for a conversation, not a data point.
- Online students are often a different population. Many are working adults and career changers attending part time. Differences in results may reflect who enrolls as much as how the courses are delivered.
The New York factor
For anyone planning to practice in New York, bar passage is only part of the question. Eligibility comes first. New York’s Rule 520.3 counts only 15 credit hours of distance education toward bar eligibility, and none earned before a student completes 28 credit hours.
Graduates of most online and hybrid programs have to petition the New York Court of Appeals for a waiver. Syracuse says that as of April 2026, every JDinteractive graduate who petitioned for a New York bar waiver succeeded. Northeastern’s FlexJD page states that its students cannot currently sit for the New York or Alabama bar because of those states’ distance education limits.
If you plan to practice in New York: ask each program how many of its online graduates have petitioned for a New York waiver, how many were approved, and how many then passed the New York bar.
Five questions to ask before you enroll
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Do you report bar results for online students separately?
If the answer is no, the school-wide rate on the ABA disclosure is the only number you have, and it may mostly reflect in-person students.
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How many online graduates took the exam?
A percentage without a count tells you very little. Ask for the number of takers and passers.
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First-time or cumulative, and which exams?
Ask whether the figure covers one administration or several years, and whether it counts only first-time takers.
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In which states did graduates sit?
Pass rates vary by state. A strong result in one jurisdiction does not guarantee the same in yours, and some states limit online credit entirely.
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What bar preparation does the program provide?
Ask what support online students receive in their final year and after graduation, and whether it matches what in-person students receive.
Considering an online or hybrid JD?
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FAQ
Do online law school graduates pass the bar?
Many do, but public data is limited. Syracuse reports that 88% of its online JD graduates passed on the first attempt, and Dayton reports a 90% first-time rate for its hybrid students on the July 2025 bar. Mitchell Hamline’s blended graduates passed the July 2023 bar at 73.96%, below its in-person graduates at 83.64%.
Does the ABA publish bar pass rates for online JD programs?
No. ABA bar passage disclosures are reported school-wide and do not separate online or hybrid students. As of January 2025, the ABA’s council was still gathering data from online programs.
What is the national bar pass rate?
First-time takers from ABA approved law schools passed at an aggregate rate of 84.10% in 2025. Within two years of graduation, 92.15% of 2023 graduates who sat for a bar exam had passed.
Can online JD graduates take the New York bar?
Usually only by waiver. New York counts only 15 credit hours of distance education toward eligibility, so most online and hybrid graduates must petition the Court of Appeals. Syracuse says every JDinteractive graduate who petitioned succeeded as of April 2026.
Which online JD program has the best bar pass rate?
There is no fair ranking yet, because most programs do not report online results separately and the ones that do use different measures and time periods. Ask each program for its online students’ first-time results, the number of takers, and the states where they tested.
Keep researching
Sources
- Julianne Hill, “Mythbusters: What do we really know about online law schools?” ABA Journal, January 15, 2025
- University of Dayton School of Law, July 2025 bar results, October 28, 2025 and April 29, 2025
- Northeastern University School of Law, FlexJD
- St. Mary’s University, first online JD graduates, April 2026
- Syracuse University College of Law, online legal education and New York waivers
- American Bar Association, 2025 bar passage results, March 11, 2026
- The Bar Examiner (NCBE), Revised Bar Passage Standard 316
- National Jurist, William Mitchell gets ABA approval to offer first hybrid JD, January 8, 2014
- ConnectPrep, ABA Approved Online JD Programs (2026)
- New York Court of Appeals, Rules for the Admission of Attorneys, Part 520
