Clinical legal education models: recommended assessment regimes
Assessment methods applicable to the various CLE models
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6 Assessment methods applicable to the various CLE models The assessment methods applied are necessarily adapted to advance the range of objectives set for each individual CLE programme. Giddings is in support of this view, stating that "[t]he flexibility of clinical (assessment) methodologies means they can be adapted to support student learning of different kinds".70 Giddings refers to an interview with Hyams71 as part of his review of the Monash clinical programme, where Hyams "notes the problematic nature of assessment if it is "handed down like a decision without any constructive comment" … as assessment is "a vehicle of learning rather than just a handing down. The assessment assists students to do better".72 Regardless of the forms of assessment or combinations thereof chosen by clinics for their CLE courses, cognisance should be taken of the principles of assessment stated by Stuckey.73 These principles are:
Be clear about the goals of each assessment;74 Assess whether students learn what is taught (validity);75 Conduct criteria-referenced assessments, not norm-referenced (reliability);76 Use assessments to inform students of their level of professional development;77 Be sure assessment is feasible;78 Use multiple methods of assessing student learning;79 Distinguish between formative and summative assessments;80 Conduct formative assessments throughout the term;81 Conduct multiple summative assessments throughout the term, when possible;82 Ensure that summative assessments are also formative assessments;83 and Require students to complete educational portfolios.84 6.1 Forms of assessment The clinical assessment models already used by some South African university law clinics as well as those used in foreign jurisdictions were probed and compared in a recent study.85 These assessment methods will be discussed briefly in an effort to establish the assessment methods best suited for CLE courses in South Africa. 6.1.1 Written tests Written tests are capable of application to the specific South African context.86 It is submitted that assessment rubrics be designed and used to allow for an even-handed assessment of all the students, specifically where clinics operate across a number of different specialised units.87 6.1.2 Spot tests, minute papers and short essay quizzes Spot tests and minute papers can be applied successfully during student tutorials,88 but the use of short essay quizzes is discouraged due to the large student numbers clinics generally have to accommodate in South Africa.89 6.1.3 Multiple-choice quizzes Multiple-choice quizzes can be used to assess students’ understanding of foundational doctrine.90 These can be used either before or after plenary instruction when students’ knowledge and understanding of the substantive law learnt in previous years are re-enforced for application in the clinical context. 6.1.4 In-class short-answer tests In-class short-answer tests may be applied successfully as a revision exercise of the history on a case file during tutorials. Large student numbers and limited lecture time make this form of assessment less than convenient for application during classroom instruction or plenary sessions.91 6.1.5 Written assignments Written assignments are useful assessment tools when students’ understanding of legal practice and court processes is tested.92 The use of assessment rubrics is recommended.93 6.1.6 Essay examination The open-ended nature of essay examination often leads to a failure to test the skills taught in a clinical course, and grading is likely to be inconsistent.94 6.1.7 Oral examination Oral examination is an ideal form of assessment, as clinicians can test what students have learnt across a wider scope and in more detail.95 6.1.8 Reflective journals Reflective journals can be successfully required in the South African clinical context, but clinical directors should heed the challenges of having to deal with large student numbers and the time constraints clinicians often experience.96 6.1.9 Self-evaluation and peer evaluation Self-evaluations are useful formative assessment tools for both students and clinicians,97 specifically where students work with a partner. These evaluations can form part of a tutorial session where clinicians will be able to distinguishing between the approaches of the student partners.98 Peer evaluations are particularly useful when students do group work or operate in student firms.99 6.1.10 Client evaluation Chavkin states that "clients have enough to deal with in their lives"100 and they might view participation in reviews "as a condition of future service by the clinic". Clients may therefore complete questionnaires in a manner that is not intended to offend the student counselors to whom they entrust their legal problems.101 Client evaluations are not recommended. 6.1.11 Case file work assessment Case file work assessment is essential in CLE courses.102 It covers the complete range of skills students need to enable them to assist clients and proceed with their cases.103 It is suggested that assessment rubrics be used when assessing case file work. 7 Conclusion It has been shown that CLE forms part of the LLB curriculum at most South African Universities. There are many similarities in the approach to CLE, but often also many differences. The clinical models of four South African university law clinics have been reviewed in an effort to find suitable models. Formulating a mission for the law clinic will have a direct impact on the clinical model chosen. CLE courses are taught at university law clinics and it has been shown that the integration of CLE into the core curriculum of the law school will reveal its value as a teaching methodology. Pedagogic aims can be set and achieved, as CLE has intellectual worth in that it enables students to better understand the concepts and principles of law and the application thereof in practice. It is recommended that CLE courses be mandatory. The pedagogy of CLE comprise of three basic components, namely the clinical experience, tutorial sessions and the classroom instruction. The extent to which these three components find application in the four South African university law clinics under review has been indicated. The principles informing assessment have been described. Assessment methods appropriate for application in CLE courses, as indicated in a comprehensive study of the topic,104 have been discussed as to their applicability to CLE courses in the South African environment.
Barry et al 2012 Clin L Rev Barry MM et al "Teaching Social Justice Lawyering: Systematically Including Community Legal Education in Law School Clinics" 2012 Clin L Rev 401-458 Bloch and Noone "Legal Aid Origins" Bloch FS and Noone MA "Legal Aid Origins of Clinical Legal Education" in Bloch FS (ed) The Global Clinical Movement: Educating Lawyers for Social Justice (Oxford University Press Oxford 2011) 153-166 Chavkin 1994 Clin L Rev Chavkin DF "Matchmaker, Matchmaker: Student Collaboration in Clinical Programs" 1994 Clin L Rev 199-244 De Klerk Clinical Law De Klerk W et al Clinical Law in South Africa 2nd ed (LexisNexis Butterworths Durban 2006) Du Plessis Assessment Methods Du Plessis MA Assessment Methods in Clinical Legal Education (PhD thesis University of the Witwatersrand 2014) Du Plessis and Swanepoel 2014 De Jure Du Plessis MA and Swanepoel N "Reflective Journals as an Assessment Method in Clinical Legal Education" 2014 De Jure 283-297 Evans and Hyams 2008 GLR Evans A and Hyams R "Independent Valuations of Clinical Education Programs" 2008 GLR 52-86 Giddings Promoting Justice Giddings J Promoting Justice through Clinical Legal Education (Justice Press Melbourne 2013) Hall and Kerrigan 2011 IJCLE Hall J and Kerrigan K "Clinic and the Wider Law Curriculum" 2011 IJCLE 25-37 Haupt and Mahomed 2008 De Jure Haupt F and Mahomed SH "Some Thoughts on Assessment Methods Used in Clinical Legal Education Programmes at the University of Pretoria Law Clinic and the University of the Witwatersrand Law Clinic" 2008 De Jure 273-292 Hyams 2008 IJCLE Hyams R "On Teaching Students to 'Act Like a Lawyer': What Sort of a Lawyer?" 2008 IJCLE 21-32 Klein "Engaging and Assessing our Students" Klein DJ "Engaging and Assessing our Students: Student Grading of In-class Quizzes" in Institute for Law Teaching and Learning's Summer Conference (2011 New York) Conference Paper 1-10 Krause-Phelan "Connecting the Dots" Krause-Phelan T "Connecting the Dots: Stimulating Law Students to Love the Law from the Classroom to the Courtroom through Constructive Engagement, Content Integration, and Collaborative Assessment" in Institute for Law Teaching and Learning's Summer Conference (2011 New York) Conference Paper 1-8 Levy-Pounds and Tyner 2008 IJCLE Levy-Pounds N and Tyner A "The Principles of Ubuntu: Using the Legal Clinical Model to Train Agents of Social Change" 2008 IJCLE 7-20 McQuoid-Mason 1982 JJS McQuoid-Mason DJ "Methods of Teaching Civil Procedure" 1982 JJS 160-171 Munro 2002 JALWD Munro GS "How Do We Know if We are Achieving our Goals? Strategies for Assessing the Outcome of Curricular Innovation" 2002 JALWD 229-246 Parmanand 2003 Stell L Rev Parmanand SK "Raising the Bar: A Note on Pupilage and Access to the Profession" 2003 Stell L Rev 199-204 Sergienko 2001 San Diego L Rev Sergienko G "New Modes of Assessment" 2001 San Diego L Rev 463-505 Sparrow 2011 Elon L Rev Sparrow SM "Using Individual and Group Multiple-choice Quizzes to Deepen Students’ Learning" 2011 Elon L Rev 1-25 Stuckey Best Practices for Legal Education Stuckey RT Best Practices for Legal Education: A Vision and a Road Map (Clinical Legal Education Association New York 2007) Vawda 2004 JJS Vawda YA "Learning from Experience: The Art and Science of Clinical Law" 2004 JJS 116-134
UFSLC Mission and Vision UFSLC "RPK 412" 2013 Course Outline UJ "ALG (TPR 0000)" 2012 LG 2 UJ "ALS" 2013 LG UPLC "Practical Law 410" 2013 SG WLC 2015 PLS Course Outline WLC Vision and Mission Internet sources ACCLE 2015 http://accle.ca/ Association for Canadian Clinical Legal Education 2015 Home Page http://accle.ca/ accessed 1 September 2015 Anon 2007 Harv L Rev Anon "Adopting and Adapting: Clinical Legal Education and Access to Justice in China" 2007 Harv L Rev 2134-2155 BABSEA CLE 2015 https://www.babseacle.org/clinical-legal-education Bridges Across Borders Southeast Asia Community Legal Education Initiative 2015 About Clinical Legal Education (CLE) https://www.babseacle.org/clinical-legal-education accessed 1 September 2015 Bryxova, Tomoszek and Vlckova 2006 JCLE Bryxova V, Tomoszek M and Vlckova V "Introducing Legal Clinics in Olomouc, Czech Republic" 2006 JCLE 149-156 CLEA 2015 http://www.cleaweb.org/ Clinical Legal Education Association 2015 Home Page http://www.cleaweb.org/ accessed 1 September 2015 CLEO 2007 http://www.ukcle.ac.uk/resources/teaching-and-learning-practices/ clinical-legal-education/ Clinical Legal Education Organisation 2007 Model Standards for Live-client Clinics http://www.ukcle.ac.uk/resources/teaching-and-learning-practices/ clinical-legal-education/ accessed 14 June 2011 Columbia Law School 2015 http://web.law.columbia.edu/clinics Columbia Law School 2015 Clinics http://web.law.columbia.edu/clinics accessed 1 September 2015 Cornell University Law School and Jindal Global Law School 2015 http://www.gaje.org/wp-content/uploads/2012/09/Cor-JGLS-web_low.pdf Cornell University Law School and Jindal Global Law School 2015 Promoting Clinical Legal Education in India: A Case Study of the Citizen Participation Clinic http://www.gaje.org/wp-content/uploads/2012/09/Cor-JGLS-web_
ENCLE 2015 http://encle.org/ European Network for Clinical Legal Education 2015 Home Page http://encle.org/ accessed 1 September 2015 Evans et al 2012 http://www.cald.asn.au/assets/lists/Resources/ Best_Practices_Australian_Clinical_Legal_Education_Sept_2012.pdf Evans A et al 2012 Best Practices: Australian Clinical Legal Education http://www.cald.asn.au/assets/lists/Resources/Best_Practices_Australian_Clinical_Legal_Education_Sept_2012.pdf accessed 1 September 2015 Fordham University School of Law 2015 http://law.fordham.edu/clinical-legal-education/clinics.htm Fordham University School of Law 2015 Clinical Legal Education http://law.fordham.edu/clinical-legal-education/clinics.htm accessed 1 September 2015 Lennertz Date Unknown http://preview.ialsnet.org/wp-content/uploads/
Lennertz M Date Unknown Developing Legal Clinics in Brazil: Remarks on the FGV DIREOTO RIO's Experience http://preview.ialsnet.org/wp-content/uploads/2015/08/Lennertz.pdf accessed 1 September 2015 Lewis Date Unknown http://orca.cf.ac.uk/27655/1/CLINICED.pdf Lewis R Date Unknown Clinical Legal Education Revisited http://orca.cf.ac.uk/27655/1/CLINICED.pdf accessed 1 September 2015 Ling 2006 Fordham Int'l LJ Ling M "Clinical Legal Education and the Reform of the Higher Legal Education System in China" 2006 Fordham Int'l LJ 421-434 Martinez 2012 http://scholarlycommons.law.hofstra.edu/cgi/viewcontent.cgi?article
Martinez SA 2012 Law Clinics in Taiwan: Can Clinical Legal Education Succeed in this Civil Law Jurisdiction Education System? http://scholarlycommons.law.hofstra.edu/cgi/viewcontent.cgi?article=1311&context=faculty_scholarship accessed 1 September 2015 NUI Galway 2015 http://www.nuigalway.ie/business-public-policy-law/school-of-law/students/cle/ NUI Galway 2015 Clinical Legal Education http://www.nuigalway.ie/business-public-policy-law/school-of-law/students/cle/ accessed 1 September 2015 Ogilvy and Czapanskiy 2004 http://wp.cedha.net/wp-content/uploads/2011/05/doc
Ogilvy JP and Czapanskiy K 2004 Clinical Legal Education: An Annotated Bibliography (Revised 2004) http://wp.cedha.net/wp-content/ uploads/2011/05/doc246-eng.pdf accessed 1 September 2015 Phan 2005 http://digitalcommons.law.yale.edu/yhrdlj/vol8/iss1/ Phan PN 2005 Legal Education in China: In Pursuit of a Culture of Law and a Mission of Social Justice http://digitalcommons.law.yale.edu/yhrdlj/
Polish Legal Clinics Foundation 2005 http://www.fupp.org.pl/down/legal_clinic.pdf Polish Legal Clinics Foundation 2005 The Legal Clinic: The Idea, Organization, Methodoly http://www.fupp.org.pl/down/legal_clinic.pdf accessed 1 September 2015 Qafisheh 2012 http://www.austlii.edu.au/au/journals/LegEdRev/2012/8.html Qafisheh MM 2012 The Role of Legal Clinics in Leading Legal Education: The Model from the Middle East http://www.austlii.edu.au/au/journals/
South African University Law Clinics Association 2014 Home Page http://www.saulca.co.za/home accessed 11 May 2014 Thomas and Mahasneh 2012 http://repository.law.umich.edu/cgi/viewcontent.cgi
Thomas KA and Mahasneh N 2012 Learning for the Unique and Common Challenges: Clinical Legal Education in Jordan http://repository.law.umich.edu/cgi/viewcontent.cgi?article=1753&context=articles accessed 1 September 2015 Yanmin and Pottenger "Chinese Characteristics" Yanmin C and Pottenger JL "The 'Chinese Characteristics' of Clinical Legal Education" in Bloch FS (ed) The Global Clinical Movement: Educating Lawyers for Social Justice (Oxford University Press Oxford 2011) 87-104 LIST OF ABBREVIATIONS
* Riette (MA) du Plessis. BA LLB (Stell) LLM (Wits) PhD (Wits). Associate Professor, School of Law, University of the Witwatersrand, Johannesburg. Email: Riette.duplessis@wits.ac.za. 1 The following South African university law clinics, are listed members of SAULCA (South African University Law Clinics Association), which describes part of its mission as being to promote high-quality CLE programmes at universities in South Africa: Rhodes University Law Clinic, University of Stellenbosch Legal Aid Clinic, University of Cape Town Law Clinic, University of Fort Hare, University of Johannesburg Law Clinic, University of KwaZulu-Natal, University of Limpopo Law Clinic, University of Pretoria Law Clinic, University of South Africa Legal Aid Clinic, University of Venda, University of the Witwatersrand Law Clinic, Nelson Mandela Metropolitan University Law Clinic, University of the Free State Law Clinic, North West University Law Clinic, Walter Sisulu University Law Clinic, University of the Western Cape Legal Aid Clinic, and University of Zululand Law Clinic. SAULCA 2014 http://www.saulca.co.za/home. 2 For Southeast Asia, see BABSEA CLE 2015 https://www.babseacle.org/clinical-legal-education, where the Bridges Across Borders Southeast Asia Community Legal Education Initiative (BABSEA CLE) has worked collaboratively with universities, law students, law faculties, lawyers, members of the legal community, and justice related organisational partners since 2003 to develop CLE programmes throughout Southeast Asia. For the USA, see Fordham University School of Law 2015 http://law.fordham.edu/clinical-legal-education/clinics.htm; CLEA 2015 http://www. cleaweb.org/; and Columbia Law School 2015 http://web.law.columbia.edu/clinics. For Europe, see ENCLE 2015 http://encle.org/, stating that CLE is a rapidly growing form of legal education across much of Europe and that it is widely accepted as a powerful pedagogical model which engages students and universities in the life of the community. For India, see Cornell University Law School and Jindal Global Law School 2015 http://www.gaje.org/wp-content/uploads/2012/09/Cor-JGLS-web_low.pdf; For Canada see ACCLE 2015 http://accle.ca/ (Association for Canadian Clinical Legal Education). For the UK see Lewis Date Unknown http://orca.cf.ac.uk/27655/1/CLINICED.pdf. For Ireland see NUI Galway 2015 http://www.nuigalway.ie/business-public-policy-law/school-of-law/students/cle/. For the Middle East see Thomas and Mahasneh 2012 http://repository.law.umich.edu/cgi/view content.cgi?article=1753&context=articles; Qafisheh 2012 http://www.austlii.edu.au/au/ journals/LegEdRev/2012/8.html. For Australia see Evans et al 2012 http://www.cald.asn.au/assets/lists/Resources/Best_Practices_Australian_Clinical_Legal_Education_Sept_2012.pdf. For South America see http://wp.cedha.net/wp-content/uploads/2011/05/ International-Developments-in-Clinical-Legal-Education.pdf and Lennertz Date Unknown http://preview.ialsnet.org/wp-content/uploads/2015/08/Lennertz.pdf. For Eastern Europe see Bryxova, Tomoszek and Vlckova 2006 JCLE; Polish Legal Clinics Foundation 2005 http://www.fupp.org.pl/down/legal_clinic.pdf; Ogilvy and Czapanskiy 2004 http://wp.cedha.net/wp-content/uploads/2011/05/doc246-eng.pdf; http://www.germanlawjournal.net/current-issue. The Far East: for China, see Phan 2005 http://digitalcommons.law.yale.edu/yhrdlj/vol8/iss1/; Also see Ling 2006 Fordham Int'l LJ; Anon 2007 Harv L Rev; Yanmin and Pottenger "Chinese Characteristics". For Japan see Martinez 2012 http://scholarlycommons.law.hofstra.edu/cgi/viewcontent.cgi?article=1311&context=faculty_scholarship. 3 See the discussion in para 4 below. 4 Du Plessis Assessment Methods 15. 5 Hyams 2008 IJCLE 25. 6 Hyams 2008 IJCLE 25. 7 WLC Vision and Mission. Available from the Wits Law Clinic. 8 UPLC "Practical Law 410" 2013 SG 3. 9 UJ "ALG (TPR 0000)" 2012 LG 2. 10 UFSLC Mission and Vision. 11 Munro 2002 JALWD 231-232. 12 Hall & Kerrigan 2011 IJCLE 30. 13 CLEO 2007 http://www.ukcle.ac.uk/resources/teaching-and-learning-practices/clinical-legal-education/. 14 De Klerk Clinical Law 246-250. 15 For example: Vawda 2004 JJS 124; Parmanand 2003 Stell L Rev 202-204; McQuoid-Mason 1982 JJS 162. 16 McQuoid-Mason 1982 JJS 162. 17 Advised by the Director in an interview with the author in 2013. 18 Advised by the Director in an interview with the author in 2013. 19 For a discussion on the social justice component of CLE, see Barry et al 2012 Clin L Rev 401-458; Levy-Pounds and Tyner 2008 IJCLE 12. 20 Advised by the Director in an interview with the author in 2013. 21 Advised by the Director in an interview with the author in 2013. 22 Advised by the Director in an interview with the author in 2013. 23 Du Plessis Assessment Methods 37-43. 24 The method described here was followed until the end of 2014. Student firms were introduced during 2015. Their success will be measured over time. 25 Haupt and Mahomed 2008 De Jure 278. 26 Du Plessis Assessment Methods 62. 27 Haupt and Mahomed 2008 De Jure 278. 28 Du Plessis Assessment Methods 63. 29 Research done by the author, see Du Plessis Assessment Methods 62. 30 Research done by the author, see Du Plessis Assessment Methods 62. 31 The UFSLC is situated in Bloemfontein, which is also the seat of the South African Supreme Court of Appeals. 32 Du Plessis Assessment Methods 63. 33 Du Plessis Assessment Methods 63. 34 Du Plessis Assessment Methods 28-31. 35 A semester course allows for the division of the students into two groups, each group being allocated to a different semester, resulting in there being fewer students per semester. Student numbers may be limited in elective courses, as such courses will not be regarded as foundational courses for the LLB degree. 36 Du Plessis Assessment Methods 28-31, 63. 37 Du Plessis Assessment Methods 28-31, 63. 38 Du Plessis Assessment Methods 39-42. 39 "Experiential courses … rely on experiential education as a significant or primary method of instruction. … [T]his involves using students’ experiences in the roles of lawyers or their observations of practising lawyers … to guide their learning". Stuckey Best Practices for Legal Education 165. 40 These specialised units are: family law; refugee law; consumer law; labour law; land, housing and evictions; the law of delict; and a general unit to accommodate cases that cannot be allocated to any of the other units. 41 Du Plessis Assessment Methods 63-65. 42 Du Plessis Assessment Methods 63-65. 43 Du Plessis Assessment Methods 63-65. 44 Du Plessis Assessment Methods 63-65. 45 WLC Vision and Mission. 46 WLC Vision and Mission. 47 WLC Vision and Mission. 48 WLC 2015 PLS Course Outline. 49 WLC 2015 PLS Course Outline. 50 WLC 2015 PLS Course Outline. 51 These specialised units are: family law; refugee law; consumer law; labour law; land, housing and evictions; the law of delict ("tort"); and a general unit to accommodate cases that cannot be allocated to any of the other units. 52 UPLC "Practical Law 410" 2013 SG 7-16. 53 Du Plessis Assessment Methods 71. 54 UPLC "Practical Law 410" 2013 SG 7-16. 55 Students have prescribed reading materials for every Study Theme. Du Plessis Assessment Methods 71-74. 56 Du Plessis Assessment Methods 71-74. 57 UJ "ALS" 2013 LG 2-30. 58 Du Plessis Assessment Methods 74-80. 59 UFSLC "RPK 412" 2013 Course Outline. 60 UFSLC "RPK 412" 2013 Course Outline. 61 UFSLC "RPK 412" 2013 Course Outline. 62 UFSLC "RPK 412" 2013 Course Outline. 63 UFSLC "RPK 412" 2013 Course Outline. 64 De Klerk Clinical Law. 65 UFSLC "RPK 412" 2013 Course Outline. 66 The topic of legal costs is discussed in a study guide handed to the students. 67 Bloch and Noone "Legal Aid Origins" 158-162. 68 Bloch and Noone "Legal Aid Origins" 158-162. 69 Bloch and Noone "Legal Aid Origins" 158-162. 70 Giddings Promoting Justice 39. 71 Giddings Promoting Justice 175. 72 Giddings Promoting Justice 175. 73 Stuckey Best Practices for Legal Education 240-263. 74 Stuckey Best Practices for Legal Education 240, 241. 75 Stuckey Best Practices for Legal Education 241-243. 76 Stuckey Best Practices for Legal Education 243-245. 77 Stuckey Best Practices for Legal Education 245-253. 78 Stuckey Best Practices for Legal Education 253. 79 Stuckey Best Practices for Legal Education 253-255. 80 Stuckey Best Practices for Legal Education 255. 81 Stuckey Best Practices for Legal Education 255-259. 82 Stuckey Best Practices for Legal Education 259, 260. 83 Stuckey Best Practices for Legal Education 260, 261. 84 Stuckey Best Practices for Legal Education 261-263. 85 Du Plessis Assessment Methods 111-192. 86 Du Plessis Assessment Methods 112, 113. 87 Du Plessis Assessment Methods 112, 113. 88 Du Plessis Assessment Methods 112, 113. 89 See Klein "Engaging and Assessing our Students"; Krause-Phelan "Connecting the Dots". 90 Sparrow 2011 Elon L Rev 4-9. 91 Du Plessis Assessment Methods 119. 92 Du Plessis Assessment Methods 111-124. 93 Du Plessis Assessment Methods 111-124. 94 Du Plessis Assessment Methods 111-124; Sergienko 2001 San Diego L Rev 469-474. 95 Du Plessis Assessment Methods 126-128. 96 Du Plessis Assessment Methods 130-140. See Du Plessis and Swanepoel 2014 De Jure 283-297 for a full discussion. 97 Du Plessis Assessment Methods 140-148. 98 Du Plessis Assessment Methods 140-148. 99 Du Plessis Assessment Methods 140-148. 100 Chavkin 1994 Clin L Rev 203. 101 Haupt and Mahomed 2008 De Jure 292. 102 Du Plessis Assessment Methods 154-167. 103 Du Plessis Assessment Methods 154-167. 104 Du Plessis Assessment Methods. 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