Case results are one of the most powerful conversion elements on a law firm website. They’re also one of the most regulated. Every state bar has rules about how lawyers can publish past results, and almost every state bar has disciplined lawyers for getting it wrong. The good news is the rules are mostly knowable. The bad news is they vary state to state, the enforcement is uneven, and the standard “Past results do not guarantee future outcomes” disclaimer at the bottom of your footer is — in many jurisdictions — not enough. This page walks through what’s actually required, where the rules get sharpest, what specific language has been challenged, and the structural pattern that holds up.
I’ll keep this practical. The point of disclaimers isn’t legalese for its own sake. It’s preventing a reasonable reader from forming an unjustified expectation based on a result you achieved for one client in one specific case. The bar rules exist because, without them, a firm could legally list “$10 million verdict” as a result and let a prospect assume their case would settle for similar amounts. That’s the harm. Everything else flows from that.
The ABA Model Rule 7.1 baseline
ABA Model Rule 7.1 — “A lawyer shall not make a false or misleading communication about the lawyer or the lawyer’s services” — is the foundation. Comment 3 addresses past results specifically: a truthful claim about a past result may still be misleading if it leads a reasonable person to form an unjustified expectation that similar results could be obtained for other clients. The remedy, per the comment, is “an appropriate disclaimer or qualifying language [that] may preclude a finding that a statement is likely to create unjustified expectations.”
That’s the floor. The phrase you’ve seen everywhere — “Past results do not guarantee future outcomes” or variants — is the industry-standard implementation of the comment. It’s appropriate, but it’s not magic. The rule requires that the disclaimer actually function — meaning the reader actually encounters it in connection with the result. A footer disclaimer five scrolls below the case result on a 2,000-pixel page does not function. A disclaimer placed visually with the result does.
Most state bars have adopted Rule 7.1 in some form. Many have added specific disclaimer language, placement requirements, or substantive limitations on what kinds of results can be advertised. The federal-style “this applies everywhere” assumption is wrong. Check your state.
State-by-state — where it gets sharper
Five states are worth knowing about in detail because their rules are stricter or because they’ve been enforced more aggressively.
Florida (Rule 4-7.13 and 4-7.14). Florida is the strictest jurisdiction. Any communication that includes past results must include a specific disclaimer with prescribed language. The disclaimer must be “clearly legible and reasonably prominent” — interpreted to mean visible with the result, not relegated to a separate page. Florida bar has actively disciplined lawyers for case-result advertising that didn’t meet the standard. Any results-based advertising in Florida should be reviewed against the current rule and the bar’s advertising guidelines.
New York (Rule 7.1(d) and 7.1(e)). New York requires that any communication referring to past results include a specific disclaimer: “Prior results do not guarantee a similar outcome.” The disclaimer must be in the same medium as the communication and reasonably visible. New York also has restrictions on what kinds of results can be advertised — specifically, results in cases where the issues are not similar to those a prospective client might face. The Disciplinary Rules have been interpreted to require an inline disclaimer near the specific result, not just a site-wide footer.
Texas (Rule 7.04). Texas prohibits any advertisement that creates unjustified expectations. The Texas bar has interpreted this broadly. Texas requires verification of any specific factual claim about results, and the bar’s advertising review committee actively reviews lawyer advertising for compliance. Disclaimers are required and must be conspicuous.
California (Rule 7.1 + Business and Professions Code). California’s rules are layered — the Rules of Professional Conduct apply, but so do state statutes governing commercial speech. Case results need disclaimers, and California has additional requirements around substantiation — you need to be able to verify the claim if challenged. The recent updates to California’s rules have tightened some areas while loosening others; check current state.
Arizona (ER 7.1). Arizona follows the ABA Model Rule 7.1 closely, with the standard prohibition on false or misleading communications. The 2021 updates loosened some of Arizona’s more restrictive prior rules. Case results still require disclaimers under the unjustified-expectations principle, and the state bar has discussed the inline-disclaimer expectation in advisory opinions.
Other states sit on a spectrum between these. New Jersey has historically been strict. Pennsylvania has been more relaxed. Some states (Illinois, Massachusetts) have more straightforward rules with less aggressive enforcement. Knowing your state’s specific rule and the recent enforcement pattern is part of due diligence — it’s not optional.
A footer disclaimer on a 3,000-pixel scroll where the case result sits halfway up the page is not a disclaimer — it’s a fig leaf. If a reader can see the result without seeing the disclaimer, the disclaimer isn’t doing its job.
The contextual disclaimer pattern — what actually works
The structural pattern that satisfies the most state bars and the most readers is the contextual disclaimer — a disclaimer placed immediately adjacent to each result, in addition to a page-level summary disclaimer. This is more work than a single footer disclaimer, but it’s the pattern that holds up under bar scrutiny and reads as credible to sophisticated visitors.
What contextual disclaimer means in practice. Each result is presented with: (1) the type of case, (2) the result obtained, (3) any relevant context that makes the result understandable (the nature of the injury, the specific issues, why this outcome was achieved), and (4) an inline disclaimer note specific to this result. Example structure:
“Motorcycle accident — head injury — $1.2 million settlement. A 42-year-old client suffered traumatic brain injury after being struck by a vehicle making an illegal left turn. The case settled at mediation 14 months after filing. Liability was contested. The settlement amount reflects medical specials, lost wages, and pain and suffering specific to this client’s case. Past results do not predict or guarantee future outcomes — each case turns on its own facts.”
That format does several things at once. It surfaces a real result (E-E-A-T signal, see E-E-A-T signals for law firm pages). It contextualizes the result so a reader doesn’t read the dollar amount as a typical outcome. It includes an inline disclaimer that satisfies the strictest state rules. And it reads as substantive rather than promotional.
The page-level disclaimer is still useful as a summary — a paragraph at the top or bottom of the case results section that establishes context for all the results shown. Something like: “The case results below represent specific outcomes obtained for individual clients in their particular legal matters. Past results do not predict or guarantee future outcomes. Each case turns on its specific facts, legal issues, and circumstances. The results shown should not be taken as typical or representative.”
Both layers — the page-level summary and the per-result inline note — together produce a structure that satisfies most bar rules and reads as honest. The footer-only disclaimer alone almost never does.
Specific language that’s been challenged
A few specific phrases that have been the subject of bar discipline or formal advisory opinions. Avoid these or use them with extreme care.
“Aggressive” representation. Some state bars have viewed “aggressive” claims as creating unjustified expectations about the lawyer’s litigation approach. Comparatives like “the most aggressive” almost always cross the line. The descriptive use (“we take an aggressive approach to discovery in personal injury cases”) is generally safer but still drawn attention in some states.
“Best,” “top,” “leading.” Comparative superlatives without verifiable basis are misleading under Rule 7.1. Many states explicitly prohibit them. The safer pattern is to cite specific recognitions (“recognized by Best Lawyers since 2018”) rather than self-describe as “the best.”
“We’ve recovered over $50 million for our clients.” Aggregate result claims are particularly risky. The “$50 million” number sounds impressive but tells a prospective client nothing about their case. State bars have viewed aggregate claims as creating unjustified expectations when they’re not contextualized — what kind of cases, what kind of outcomes, what was the firm’s actual contribution. Either don’t use them, or include heavy contextualization.
Implied guarantees. “We’ll fight for every dollar you deserve” sounds harmless but can be read as an implied guarantee under aggressive interpretations of Rule 7.1. “We’ll get you the compensation you’re entitled to” is closer to a direct guarantee. Both have drawn enforcement attention. The safer pattern: describe your approach, not the outcome you’ll produce.
“No fee if we don’t recover.” This one is generally allowed in personal injury contexts but the surrounding details matter. Some states require additional context about costs (clients may still be responsible for case costs even if no recovery). The phrase by itself is often fine; surrounding fee details may need disclosure depending on state.
What NOT to do when publishing case results
- Don’t omit attorney fees. A $1 million verdict where the client received $300,000 after fees and costs is a different story than a $1 million verdict where the client received $750,000. Some states explicitly require fee/cost disclosure on results. Even where not required, omitting fees creates an unjustified expectation about what a client takes home.
- Don’t omit the amount. “Substantial settlement obtained for our client” with no number is its own kind of misleading — the implication is the result was large when, in many cases, it wasn’t. State bars have generally preferred specific numbers (with context) over vague claims of “substantial” recovery.
- Don’t cherry-pick only big wins. A case results page that lists exclusively seven-figure outcomes from a firm that handles 200 cases a year — most of which settle for far less — is misleading by curation. Include a representative range. Or, more honestly, frame the results as “representative significant outcomes” rather than implying these are typical.
- Don’t combine multiple cases into one result. “Recovered $5 million in a multi-vehicle accident case” when “the case” was actually three separate plaintiffs each receiving smaller amounts is misleading. Each case stands on its own facts.
- Don’t include cases other firms handled. If a partner left another firm to join yours, results from cases handled at the prior firm need attribution context. “Sarah obtained a $2 million verdict in 2018 while at [Prior Firm]” — the attribution matters.
- Don’t include results that have been overturned, settled differently than reported, or are subject to confidentiality. Settlement confidentiality clauses bind the firm — publishing a confidential settlement amount can violate the settlement agreement and the bar rule on confidentiality. Verify what you can publish before publishing.
- Don’t use stock photos of the “client.” A stock photo of a smiling stranger labeled as the client in a case result is misleading at multiple levels. Use no photo, use an actual client photo with explicit consent, or use a clear representative-photo disclaimer.
The case result page checklist
Use this when reviewing your existing case results page or building one. Each result on the page should pass each item.
- Result type clearly labeled (verdict, settlement, dismissal, etc.) — readers should understand whether this was a litigated outcome or a settlement, since the implications for what the result demonstrates are different.
- Practice area specified — personal injury motor vehicle case, criminal defense DUI, family law custody, etc. The reader needs to be able to determine relevance to their situation.
- Key facts surfaced — what was the injury, the charge, the dispute. Enough context that the reader understands why the outcome matters, without identifying the client.
- Amount disclosed (if relevant) — the specific dollar amount or sentence outcome, not a vague “substantial recovery.”
- Fees and costs context (if relevant) — particularly for contingency cases where the gross verdict differs from the client net.
- Per-result inline disclaimer — “Past results do not predict or guarantee future outcomes. Each case turns on its own facts.”
- Page-level disclaimer — a paragraph at the top of the section establishing the broader frame.
- Client anonymization where appropriate — first name and last initial, age range, occupation type if relevant, but not full identifying information unless consent was specifically obtained.
- No identifying photos without consent.
- Verifiable underlying record. If the bar asks, you can produce the docket, the settlement letter, the verdict form. If you can’t verify it, don’t publish it.
- No comparative superlatives in result descriptions. “Largest verdict in Maricopa County in 2018” is a specific verifiable claim if true. “One of the best results ever achieved” is not.
- State-specific compliance verified. Check current rule. Check recent bar advisory opinions. Check whether your state requires advertising review.
Where placement matters
Disclaimer placement isn’t a technicality. The functional test most bars apply is whether a reasonable reader encountering the result will also encounter the disclaimer. That means same screen on a mobile device. Same scroll-segment on desktop. Not “the same page” technically but at the bottom of a 4,000-word document where the reader will never see it.
Practical implementation: the per-result disclaimer is a short italic line directly below each result block. The page-level summary disclaimer is at the top of the case results section, before any result is shown. The footer disclaimer (which most sites have anyway) provides a third layer but doesn’t substitute for the first two. On mobile especially, where readers are scrolling fast and viewing screen-by-screen, the inline disclaimer is often the only one that actually gets seen.
For the broader practice-page integration of case results see case result pages and SEO and the answer page should I list case results on my site.
Schema markup and case results
One quick technical note. Some firms have used Review schema or aggregateRating schema on case results pages to try to get rich results in Google. This is risky — Google’s schema guidelines specify what content qualifies for review markup, and case results obtained by the firm don’t fit the standard definition (which is about user-generated reviews of a product or service). Misuse of schema can trigger manual penalties from Google and is also problematic under bar rules because of the implied claims it creates. Don’t do it.
The right schema for a case results page is structured data describing the underlying content — Article schema, with a named author, dated publication, and clear authorship. For the practice page itself, LegalService schema. For real client reviews aggregated elsewhere (Google reviews), the AggregateRating that flows from the GBP. Don’t try to manufacture rich results out of case outcomes. For the full schema treatment see schema markup for law firms and review schema and rich results.
The honest summary
Case results are powerful precisely because they’re specific. The bar rules around them exist because, without constraints, the specificity becomes misleading — one $5 million verdict implies your case will settle for similar amounts when it almost certainly won’t. The disclaimer rules are the bar’s attempt to preserve the legitimate use (showing what your firm has done) while preventing the misleading use (implying every client gets the same).
The structural pattern that works: contextual per-result disclaimers, a page-level summary disclaimer, real attribution and verifiability behind every claim, no cherry-picking that hides the typical range, no superlatives, no implied guarantees, and state-specific compliance verified against current rules. Get those right and a case results page becomes one of the most credible elements on your site. Get them wrong and the same page becomes a bar grievance waiting to happen.
For the full guide see the reviews and reputation guide. For the ABA-rule context around solicitation see ABA rules on soliciting client reviews. For the testimonials-and-reviews distinction see reviews vs testimonials on your site. For the broader legal SEO context see the legal SEO authority page.
If you want a second set of eyes
The free audit I offer includes a review of your case results page against ABA Model Rule 7.1 and your state’s specific rules. I’ll flag where you’re at compliance risk, where the disclaimers aren’t doing their job, where the language has the potential to draw bar attention, and what structural changes would fix it. No deck. Yours to keep whether you hire us or not.
— The owner, PHX Search Co.