At minimum, every case result page needs “Past results do not guarantee similar outcomes” combined with practice-area context that explains why outcomes vary in your specific area of law. The exact wording, placement, and prominence depend on your state. New York, Florida, and Arizona each have specific requirements that go beyond the ABA Model Rule 7.1 baseline. The bigger mistake most firms make isn’t using the wrong disclaimer — it’s using a blanket footer disclaimer instead of a contextual one tied to each result.
The ABA Model Rule 7.1 baseline
Model Rule 7.1 prohibits false or misleading communications about a lawyer’s services. A statement is misleading if it omits a fact necessary to make the communication not materially misleading — and the standard example is publishing past case results without context that would prevent a reasonable reader from forming an unjustified expectation about their own case.
The baseline disclaimer language that meets this floor is some variant of “Past results do not guarantee, warrant, or predict a similar outcome in your case.” Some firms add “Each case is unique and must be evaluated on its own merits.” Both lines are common and defensible.
What the rule doesn’t dictate is placement, prominence, or whether the disclaimer can be a single footer line covering an entire site. That’s where state interpretations diverge.
State-by-state additions worth knowing
New York. Rule 7.1 in New York is more specific than the ABA model. New York requires disclaimers about prior results to be “prominent” — interpreted by ethics opinions to mean visible without scrolling away from the result itself, in the same font size or close to it, not buried at the bottom of the page or in a footer. The phrase typically used is “Prior results do not guarantee a similar outcome” and many New York firms add their full firm-attorney disclaimer block as well.
Florida. Florida historically had the strictest lawyer advertising rules in the country. Rule 4-7.13(b) of the Florida Rules of Professional Conduct treats statements characterizing the quality of legal services as inherently deceptive, and Rule 4-7.14 covers misleading statements specifically. Florida firms publishing case results have to be exceptionally careful about how outcomes are framed — and the disclaimer language is often required to be more elaborate than the ABA baseline. If you practice in Florida, do not rely on this page. Read 4-7.13 and 4-7.14 directly and consider an ethics opinion.
Arizona. Arizona follows ABA Model Rule 7.1 reasonably closely, but the State Bar of Arizona has issued ethics opinions reinforcing that “past results” disclaimers should appear with the result, not just in a footer, and that the disclaimer should reflect the actual variability in the practice area. A $3 million PI verdict and a single dismissed DUI need different contextual notes, not the same generic footer line.
California. California Rule 7.1 and the related Standards require disclaimers to be in the same font, size, and prominence as the underlying communication. A 4-point disclaimer under a 24-point headline of “$5,000,000 VERDICT” is not compliant.
Texas, Pennsylvania, and Illinois have variations of their own — generally requiring the disclaimer to be present, conspicuous, and not separated from the result by intervening content. Each state’s rule should be read directly. None of this constitutes legal advice.
The contextual-vs-blanket-footer debate
The most common compliance mistake I see on law firm sites: a single line in the global footer reading “Past results do not guarantee similar outcomes,” followed by case result pages or homepage headlines bragging about specific verdicts and settlements with no disclaimer next to them.
That setup is risky for two reasons. First, in most stricter states the footer-only approach probably doesn’t meet the “prominent” or “conspicuous” standard. A reader can absorb the verdict number and form an expectation without ever scrolling to the footer. Second, in any state, a blanket disclaimer doesn’t address the specific reasons your outcome wouldn’t translate to a reader’s case — and the omission of those specifics is itself part of what makes the communication potentially misleading under 7.1.
The safer pattern is contextual disclaimers placed with each result. A short paragraph immediately adjacent to the verdict or settlement that says something like: “This case involved a [practice area] matter with [briefly noted factors]. The outcome reflected the specific facts of this case. Past results do not guarantee similar outcomes in your matter.” Plus the global footer disclaimer as belt-and-suspenders.
A footer disclaimer is a fire extinguisher. A contextual one is a smoke alarm. Most firms only have the extinguisher and wonder why they keep getting burned by ethics complaints.
Placement and prominence — the practical version
On a case result page, place the disclaimer in three locations. First, immediately under or next to each headline result, in a font size at least 75% of the result number itself. Second, in a closing block at the bottom of the case results section. Third, in the site-wide footer.
For visual treatment, do not gray the disclaimer out to the point of near-invisibility. Light gray on white at 10px is the kind of cosmetic burying that ethics opinions specifically call out. The disclaimer doesn’t need to scream — it just needs to be legible to a normal reader without effort.
On a homepage where you display “Over $50M recovered for clients,” the disclaimer needs to be on that screen — not on a separate page. The reader who absorbs the headline and bounces never saw your disclaimer page.
Practice-area-specific notes
The disclaimer language should reflect the actual variability of outcomes in your practice area. For personal injury, “Each personal injury case depends on the specific facts, jurisdiction, applicable insurance coverage, and the parties involved.” For criminal defense, “Each criminal matter depends on the specific charges, evidence, jurisdiction, and the defendant’s prior history.” For estate planning, the context is different — you’re often disclaiming the educational nature of content rather than past-result expectations.
For criminal defense in particular, watch the language. “Won” and “dismissed” can be true descriptions of outcomes, but the framing matters. A representative-engagement narrative (“Representative matter: client charged with X; result: Y, after Z motion”) is harder to challenge than a billboard-style claim.
The one-page case result template I recommend
Every result should have four elements. The result itself, stated clearly. A 2-to-4-sentence factual context — what kind of matter, what made it the kind of case it was, without identifying the client. The contextual disclaimer, in legible type next to the result. And a closing paragraph that summarizes the principle — your firm handled the matter through a specific approach, but every case is different and outcomes vary.
That structure is more work than slapping a footer line under twenty verdict numbers. It’s also the structure least likely to draw a bar complaint and most likely to actually convince a sophisticated reader that you’re a serious firm. The ethics rule and the marketing instinct point in the same direction here.
For more on case result page structure, see case result pages and SEO and should I list case results on my site. For the related disclaimer discussion on testimonials, see can I use client quotes on my website and the main guide reviews, reputation and trust.