What Are the Best Side Hustles for Paralegals? (w/Examples) + FAQs

Yes, paralegals can legally earn extra income through side hustles, but only if they avoid the unauthorized practice of law (UPL) under ABA Model Rule 5.5 and stay within the supervision boundaries of ABA Model Rule 5.3. The core problem is that every state bans non-lawyers from giving legal advice, setting fees, or representing clients, and violating those rules can trigger criminal charges, civil fines, and permanent career damage. In The Florida Bar v. Furman, 451 So.2d 808 (Fla. 1984), a legal secretary went to jail for helping customers fill out divorce forms, a case still cited today in Florida Bar UPL enforcement.

According to the U.S. Bureau of Labor Statistics, the median paralegal wage sits at $60,970, while freelance paralegals earn $25 to $75 per hour, and a 2025 NALA compensation report found that 38% of certified paralegals now earn supplemental income outside their main job.

Here is what you will learn in this guide:

• ⚖️ How to pick side hustles that respect UPL rules in all 50 states
• 💼 Which legal-adjacent gigs pay the most in 2026
• 📚 How to use NALA and NFPA ethics codes to protect your license
• 💰 How to handle self-employment taxes, 1099-NEC income, and Schedule C deductions
• 🚫 The most common mistakes that end paralegal careers fast

Why Paralegals Need Side Hustles in 2026

Paralegals face rising living costs, stagnant salaries in some regions, and growing demand for flexible legal support, which makes side hustles attractive. The BLS projects 1% job growth for paralegals through 2033, but freelance legal work is growing much faster because law firms want to cut overhead. A side hustle lets you build new skills, test a specialty, and create a financial cushion without leaving your main job.

The governing concern is always ABA Model Rule 5.5, which every state has adopted in some form. This rule says only licensed attorneys can practice law, and “practice” includes giving legal advice, drafting legal documents for the public, setting legal fees, and representing clients. The direct consequence of breaking this rule is a UPL charge, which is a misdemeanor in most states and a felony in Florida, Texas, and a handful of others.

A common misconception is that working “freelance” removes ethics duties. That is false because the NALA Code of Ethics and the NFPA Model Code both apply to certified paralegals no matter who pays them. A real-world example: Janet is a corporate paralegal in Austin who wants to earn $1,000 per month on the side. If she offers to “help people file LLCs” on Facebook without attorney supervision, she commits UPL under Texas Government Code § 81.101.

The Financial Case for a Second Income

The average U.S. household now spends roughly $6,440 per month, according to the Bureau of Labor Statistics Consumer Expenditure Survey, while paralegal take-home pay in many states barely covers that figure. A side hustle closes the gap without forcing a job change. Most paralegals who freelance report earning between $400 and $3,000 per month extra, depending on specialty and hours.

The IRS treats all side hustle income as self-employment income, which you must report on Schedule C. You also owe 15.3% self-employment tax on net earnings above $400. The consequence of skipping this filing is an IRS audit, back taxes, and penalties that can reach 25% of the unpaid amount.

A common misconception is that cash tips or Venmo payments do not count. They do, because the American Rescue Plan Act of 2021 lowered the 1099-K reporting threshold to $600 starting in 2024. Marcus, a litigation paralegal in Chicago, ignored $4,200 in PayPal tutoring income in 2024 and received a CP2000 notice the next year demanding $1,180 in back taxes and interest.

Market Demand for Paralegal Skills

Law firms outsourced roughly $3.5 billion in legal work to freelance paralegals in 2025, based on data from the Thomson Reuters Legal Department Operations Index. Small firms especially need contract help with document review, e-discovery, and client intake. Solo attorneys often pay $35 to $60 per hour for remote paralegal support.

The regulatory angle here is ABA Model Rule 5.3, which requires attorneys to supervise non-lawyer assistants. That means your freelance clients must be lawyers or law firms, not the general public, unless you work through an approved platform. Breaking this rule puts both you and the attorney at risk of discipline by the state bar.

A misconception is that “1099 contractor” status removes supervision duties. It does not, because the rule ties to the task, not the paycheck. Priya, an immigration paralegal in San Diego, contracts with three solo attorneys and bills each one separately, and every attorney signs a written supervision agreement to satisfy California Business and Professions Code § 6450.

The Best Legal-Adjacent Side Hustles for Paralegals

Legal-adjacent side hustles pay the most because they use the skills you already have, such as research, drafting, and case management. These gigs also carry the highest UPL risk, so every one of them must run through an attorney or an approved legal service provider. Below are the top paying and most sustainable options in 2026.

Freelance Contract Paralegal Work

Freelance contract paralegal work means billing attorneys directly for research, drafting, cite-checking, and discovery on a per-project basis. Platforms like Hire an Esquire, Paralegal Gateway, and Upwork connect paralegals to vetted attorneys. Rates usually run $30 to $75 per hour, with specialists in IP, healthcare, and securities law earning the top end.

The governing rule is ABA Formal Opinion 08-451, which says attorneys may outsource to non-lawyers if they supervise the work and protect client confidentiality. The consequence of freelancing without a supervision letter is that the hiring attorney can be sanctioned, and you can be named in a UPL complaint. A common misconception is that signing an NDA counts as supervision; it does not, because supervision means actual review of substantive work.

David, a real estate paralegal in Phoenix, contracts with two small firms through Hire an Esquire and earns about $1,800 per month drafting closing documents. He never communicates directly with the firm’s clients, and every document he drafts is reviewed and signed by the supervising attorney. This structure keeps him safely within Arizona Supreme Court Rule 31.

Legal Research and Writing Services

Legal research and writing is a high-demand niche because many attorneys hate spending hours on Westlaw or Lexis. You can charge $40 to $100 per hour to draft motions, briefs, memos, and research reports. The work is remote, asynchronous, and scales well with experience.

The rule you must follow is that the attorney is always the author of record. Under ABA Model Rule 1.1, the lawyer owns the competence duty to the client, so your work is a draft for their review. The consequence of signing your own name on a filed brief is a direct UPL violation and potential sanctions against the filing attorney.

A misconception is that “ghostwriting” for pro se litigants is allowed. It is not in most states, and the ABA Standing Committee on Ethics Formal Opinion 07-446 carved a narrow exception only when the lawyer is licensed. Sarah, a family law paralegal in Denver, charges $65 per hour through LAWCLERK and only accepts projects from bar-licensed attorneys who sign the final work product.

Virtual Paralegal Services

A virtual paralegal runs a remote practice that supports multiple law firms at once, usually on retainer. Monthly retainers range from $500 to $3,500 per firm, which makes this one of the most scalable side hustles. You can find clients through Upwork, LinkedIn, and the National Association of Freelance Legal Professionals.

The core rule is that every firm client must sign an engagement letter naming you as a non-lawyer assistant under attorney supervision, which satisfies ABA Model Rule 5.3(c). The consequence of skipping this letter is that the firm can be held liable for your mistakes, and some malpractice carriers will deny coverage. A common misconception is that a verbal agreement is enough; it is not, because state bars and insurance companies require written proof.

Elena, a corporate paralegal in Miami, runs a virtual practice with four small firms paying $900 each per month. She uses Clio to track matters and keeps separate conflict-check files for each firm. Her setup complies with Florida Bar Rule 4-5.3.

Legal Technology Consulting

Paralegals who know e-discovery platforms, practice management software, or AI review tools can charge $75 to $150 per hour to set up and train law firms. Tools like Relativity, Everlaw, Clio, and MyCase have active certification programs. Firms pay premium rates because improper setup can lead to sanctions under Federal Rule of Civil Procedure 37(e).

The rule here is that technology consulting is not the practice of law as long as you do not give legal advice about how to respond to discovery. The consequence of crossing that line is a UPL complaint, even if your intent was to help. A misconception is that certification in a tool gives you authority to advise on scope; it does not, because scope is a legal decision.

Aiden, an e-discovery paralegal in Seattle, is Relativity Certified Administrator and earns $110 per hour training legal ops teams. He never reviews the substantive content of documents for privilege calls; instead, he configures the platform and trains reviewers. This keeps him safely on the technology side of Washington RPC 5.5.

Non-Legal Side Hustles That Fit a Paralegal’s Skills

Non-legal side hustles carry zero UPL risk, which makes them attractive for paralegals who want to avoid the supervision headache. They also let you use writing, organization, and research skills in new markets. The trade-off is usually a lower hourly rate than legal-adjacent work.

Notary Public and Remote Online Notarization

Becoming a notary public costs $50 to $200 depending on your state, and Remote Online Notarization (RON) is now legal in 45 states as of 2026. Platforms like NotaryCam and Notarize pay $5 to $25 per notarization, and a busy notary can earn $500 to $2,000 per month. Loan signing agents earn $75 to $200 per closing.

The governing law is your state’s notary statute, such as Texas Government Code Chapter 406 or California Government Code § 8200, and the consequence of improper notarization can include loss of commission, civil liability, and criminal charges. A misconception is that notaries can explain what a document means; they cannot, because that is legal advice.

Jamal, a paralegal in Atlanta, became a loan signing agent through the National Notary Association and earns $1,400 per month working evenings and weekends. He picks up signings through Snapdocs and never offers opinions on mortgage terms.

Legal Content Writing and Blogging

Law firms need constant content for SEO, and few lawyers like writing it. Legal content writers earn $0.15 to $1.00 per word, with experienced paralegal writers averaging $75 to $200 per blog post. Platforms like Contently, Scripted, and direct pitches to marketing agencies all work.

The rule here is that marketing content is governed by ABA Model Rule 7.1, which bans false or misleading statements about legal services. The consequence of writing misleading copy is that the attorney faces discipline, and you may be fired by the agency. A misconception is that generic “informational” blogs are safe; they are not, because any content that invites reliance can be construed as advice.

Maria, a litigation paralegal in Boston, writes three blog posts per week for a personal injury firm at $150 each, earning $1,800 per month. She always adds a disclaimer drafted by the firm’s compliance team and lets the attorney approve every post before it goes live.

Tutoring and Online Teaching

Paralegals with strong writing or research skills can tutor LSAT, college writing, or paralegal certification students. Wyzant, Varsity Tutors, and Outschool pay $25 to $100 per hour. Teaching on Udemy or Skillshare can generate passive income from recorded courses.

The rule to watch is that tutoring for bar-adjacent exams is fine, but coaching actual clients through a real legal matter is UPL. The consequence of crossing the line is the same criminal risk as any UPL charge. A misconception is that “it is just tutoring” protects you; it does not, because substance, not label, determines UPL under Florida Bar v. Moses, 380 So.2d 412 (Fla. 1980).

Freelance Proofreading and Editing

Paralegals read for accuracy all day, which makes proofreading a natural fit. Legal proofreaders earn $25 to $60 per hour through Scribendi, Reedsy, and direct outreach to law firms. Specialized transcript proofreaders who serve court reporters earn $30 to $50 per hour.

The Proofread Anywhere transcript proofreading program is the most recognized entry point. You do not practice law because you are only correcting spelling, punctuation, and format. The consequence of accidentally changing substance is that the court reporter loses credibility with the court, so proofreaders strictly follow the NCRA guidelines.

Three Common Scenarios Paralegals Face

Paralegals who start side hustles usually fall into one of three patterns. Each pattern has a specific risk profile and a clear legal consequence. Use the tables below to match your situation to the right structure.

Scenario 1: Freelancing for Attorneys Only

Scenario 2: Offering Services to the Public Online

Scenario 3: Teaching, Writing, and Consulting

Three Named Examples of Paralegals Doing It Right

Real examples help more than abstract rules. Below are three paralegals from different specialties who have built sustainable side hustles while staying on the right side of UPL. Names are representative; the structures are drawn from common industry practice.

Example 1: Carlos, Immigration Paralegal in Houston

Carlos has seven years of immigration experience and is a NALA Certified Paralegal. He contracts with two solo immigration attorneys through Hire an Esquire, billing $55 per hour for I-130, I-485, and I-589 drafting. His side income averages $2,200 per month.

Carlos never signs forms himself, because only the attorney or the client can sign under 8 C.F.R. § 292.1. He keeps a written supervision agreement on file with each attorney, which satisfies the EOIR rules on accredited representatives. He carries a $1 million professional liability policy through CNA.

Example 2: Taylor, Litigation Paralegal in New York City

Taylor works full-time at a Midtown firm and runs a legal writing side business through LAWCLERK. She charges $85 per hour to draft motions and discovery responses for solo practitioners across New York State. Last year she earned $14,000 in side income.

Taylor’s structure complies with New York Judiciary Law § 478, the state’s UPL statute. She never files documents in court under her own name, never contacts the attorney’s clients, and never sets the fee the client ultimately pays. Every engagement runs through the LAWCLERK platform, which enforces attorney-only hiring.

Example 3: Robin, Corporate Paralegal in San Francisco

Robin holds the NFPA PACE credential and consults part-time on Clio implementations for small law firms. She charges $125 per hour and earns roughly $3,000 per month. She is also a Clio Certified Consultant.

Robin stays out of UPL territory by focusing on software configuration, not legal advice. She never tells firms what to do in a specific matter; instead, she builds templates, workflows, and billing rules. Her scope complies with California Rule of Professional Conduct 5.3 because the firm’s lawyers own every legal decision.

Mistakes to Avoid When Starting a Side Hustle

Most paralegal side hustles fail or blow up because of avoidable mistakes. The list below covers the seven most dangerous errors and what each one costs you. Read it before your first client.

• Advertising to the public without an attorney. The consequence is a UPL charge under your state’s practice statute, which is a crime in most states.
• Skipping the written supervision agreement. The consequence is loss of malpractice coverage and exposure to personal liability for the attorney’s errors.
• Signing court documents in your own name. The consequence is immediate sanction by the court and a bar complaint against any supervising attorney.
• Ignoring conflict checks across multiple firm clients. The consequence is disqualification from matters and possible claims under Model Rule 1.10.
• Failing to report side income on Schedule C. The consequence is an IRS audit, 25% failure-to-pay penalties, and possible state tax fraud charges.
• Using your day-job email or software for side gigs. The consequence is termination for cause and possible theft-of-services claims by your employer.
• Making legal promises in marketing copy. The consequence is a Rule 7.1 violation chargeable to any attorney who reposts your content.
• Mixing client funds with personal funds. The consequence is a direct violation of Model Rule 1.15 by your supervising attorney, with discipline flowing back to you.
• Skipping professional liability insurance. The consequence is personal financial ruin if a firm sues you for a drafting error.

Do’s and Don’ts for Paralegal Side Hustles

Paralegals who follow the list below avoid almost every common problem. The “why” behind each rule matters as much as the rule itself. Read both columns carefully.

Do’s

• Do get written supervision from every attorney-client because Model Rule 5.3 requires it.
• Do carry professional liability insurance because a single drafting error can cost $50,000 to defend.
• Do track every hour and dollar because the IRS requires contemporaneous records for Schedule C.
• Do check your employer’s moonlighting policy because most law firms require disclosure and conflict checks.
• Do keep CLE and certification current because NALA and NFPA both require continuing education to keep your credential.
• Do set rates at market because underpricing signals inexperience and attracts difficult clients.

Don’ts

• Don’t advertise legal services to the public because it is UPL in every state.
• Don’t give friends free legal advice because informal advice still counts as practicing law.
• Don’t use firm resources for side work because that is theft of services and cause for termination.
• Don’t accept cash without reporting because the IRS matches 1099-K and 1099-NEC data automatically.
• Don’t sign a non-compete without reading it because many paralegal employment contracts ban side hustles outright.
• Don’t skip the engagement letter because without one, fee disputes become impossible to win.

Pros and Cons of Paralegal Side Hustles

Before you start, weigh the tradeoffs. Side hustles bring money and freedom, but also stress and risk. The list below is drawn from real paralegal experience in 2025 and 2026.

Pros

• Extra income of $500 to $3,000 per month lets you build savings or pay down debt faster.
• New skill development in niches like e-discovery or IP can lead to higher day-job pay.
• Network expansion with new attorneys opens doors to full-time offers later.
• Tax deductions for home office, software, and CLE lower your overall tax bill.
• Schedule flexibility means you choose which projects fit your life.
• Resume strength with diverse experience makes you stand out in a tight market.

Cons

• UPL risk is real in every state and can end your career permanently.
• Tax complexity grows once you owe quarterly estimated payments.
• Burnout is common when you add 10 to 20 hours per week to a full-time job.
• Employer conflict may arise if your firm sees you as a moonlighter.
• Inconsistent income makes budgeting harder, especially in the first year.
• Insurance costs of $400 to $1,200 per year cut into profit margins.

How to Set Up Your Side Hustle the Right Way

Setting up correctly takes about two weekends and saves years of trouble later. The steps below cover the legal, tax, and operational foundation you need. Miss any step, and you expose yourself to real risk.

Step 1: Pick a Structure

Most paralegals start as sole proprietors because it is free and simple. The IRS explains sole proprietorship as a business where you and the owner are the same legal entity. The downside is unlimited personal liability, which is why many paralegals upgrade to an LLC once income exceeds $20,000 per year.

An LLC costs $50 to $800 to form, depending on your state, and it creates a liability shield between your business and your personal assets. The consequence of skipping an LLC is that a lawsuit against your business becomes a lawsuit against your house and savings. A misconception is that an LLC protects you from UPL charges; it does not, because UPL is a personal crime.

Step 2: Get an EIN and Open a Business Bank Account

An Employer Identification Number is free from the IRS EIN application page and takes about ten minutes. Use it instead of your Social Security Number when you fill out W-9 forms for attorney-clients. A separate business bank account is non-negotiable because mixing funds makes tax time painful and can pierce your LLC’s liability shield.

The consequence of mixing funds is that courts can “pierce the corporate veil” and hold you personally liable for business debts. A misconception is that a small side hustle does not need this discipline; it does, because audits happen at every income level.

Step 3: Buy Professional Liability Insurance

Professional liability policies for freelance paralegals cost $400 to $1,200 per year through carriers like Hiscox, Next Insurance, and CNA. The policy pays defense costs and settlements when a client claims your work caused a loss. Without it, a single mistake on a statute of limitations or filing deadline can cost $100,000 or more.

A misconception is that your employer’s malpractice policy covers side work; it does not, because those policies only cover work done for the employer. The consequence of going uninsured is personal bankruptcy after a single lawsuit.

Step 4: Set Rates and Contracts

Write every engagement in a signed contract that names the attorney-client, the scope of work, the hourly or flat rate, payment terms, and confidentiality duties. The NFPA sample engagement letter is a good starting template. Charge what the market pays; the 2025 NALA National Paralegal Compensation Survey lists median freelance rates by region.

The consequence of skipping a contract is that you cannot enforce payment or limit liability. A misconception is that email “confirmations” are enough; they are not, because most states require signed writings for contracts over $500.

State-Specific Rules Paralegals Must Know

UPL rules vary by state, and the biggest markets have the strictest enforcement. Below is a quick tour of four high-demand states. Always check your own state bar website before starting.

California

California is the only state with a formal Legal Document Assistant (LDA) registration under Business and Professions Code § 6400. LDAs can prepare documents for the public without attorney supervision, but they cannot give legal advice. Paralegals who want to serve the public must register as an LDA, post a $25,000 bond, and renew every two years.

Unregistered document prep for the public is a misdemeanor under Bus. & Prof. Code § 6126. The consequence is up to one year in county jail and a $1,000 fine, with each document counted separately. A misconception is that being a certified paralegal under Bus. & Prof. Code § 6450 lets you serve the public; it does not, because § 6450 paralegals must work under attorney supervision.

New York

New York has one of the oldest UPL statutes in the country, Judiciary Law § 478, which makes practicing law without a license a misdemeanor. New York does not offer an LDA program, so paralegal side hustles must run through licensed attorneys. The New York State Bar Association actively prosecutes UPL complaints.

The consequence of a New York UPL conviction is up to one year in jail and a criminal record. A misconception is that form-filling is safe; the New York Court of Appeals held in People v. Alfani, 227 N.Y. 334 (1919) that any act requiring legal knowledge is practice, even without advice.

Texas

Texas treats UPL seriously under Government Code § 81.101 and § 83.001. The State Bar of Texas UPL Committee investigates complaints and can pursue civil injunctions plus criminal referrals. A knowing UPL violation is a Class A misdemeanor, and a second offense is a felony.

The consequence of a Texas felony UPL conviction is up to two years in state jail. A misconception is that disclaimers like “not a lawyer” protect you; they do not, because Texas courts look at the act, not the label.

Florida

Florida’s UPL regime is one of the strictest in the country, and Florida Bar v. Furman set the tone. The Florida Supreme Court UPL rules treat certain unlicensed legal help as indirect criminal contempt. Florida does allow Registered Paralegals to work under attorney supervision, but not to serve the public directly.

The consequence of Florida UPL is jail time, fines, and permanent injunction. A misconception is that helping a family member with a court form is safe; the Florida Bar has prosecuted cases involving paid help to non-family members, even with a clear disclaimer.

Tax Rules Every Paralegal Side Hustler Must Follow

Taxes are the hidden cost that kills paralegal side hustle profits. Plan for taxes from day one, or you will lose 30% to 40% of your earnings to the IRS and state. The rules below apply in 2026.

Self-Employment Tax and Schedule C

Side hustle net income over $400 triggers 15.3% self-employment tax, which covers Social Security and Medicare. Report income and expenses on Schedule C, and calculate SE tax on Schedule SE. The IRS treats 1099-NEC income and 1099-K payments from platforms as self-employment income.

The consequence of skipping SE tax is an IRS assessment plus 25% in failure-to-file penalties and daily interest. A misconception is that you only owe tax on “profit” after personal expenses; you only deduct ordinary and necessary business expenses under IRC § 162.

Quarterly Estimated Payments

Once you owe more than $1,000 in tax for the year, the IRS requires four quarterly estimated payments using Form 1040-ES. Payments are due April 15, June 15, September 15, and January 15. Missing a payment triggers an underpayment penalty, even if you pay the full balance in April.

The consequence of skipping quarterlies is a penalty of roughly 8% annualized on each underpayment. A misconception is that year-end payment fixes everything; it does not, because the penalty accrues from each missed quarter.

Deductions Paralegals Should Know

The top deductions for paralegal side hustles include home office (under IRC § 280A), CLE and certification fees, bar dues, software subscriptions, professional liability premiums, and a portion of your phone and internet. A properly tracked home office can save $800 to $2,400 per year in taxes. Use an app like QuickBooks Self-Employed or Wave to log expenses in real time.

The consequence of poor recordkeeping is disallowed deductions during audit. A misconception is that you can deduct commuting to your day job; you cannot, because the IRS classifies that as personal travel under Publication 463.

FAQs

Can paralegals legally run side hustles?

Yes. Paralegals can run side hustles as long as the work does not cross into the unauthorized practice of law and any legal work is supervised by a licensed attorney under ABA Model Rule 5.3.

Can a paralegal give legal advice as a freelancer?

No. Only licensed attorneys can give legal advice, and a freelance paralegal who advises the public commits UPL under every state’s practice statute, with penalties ranging from misdemeanor fines to felony jail time.

Can paralegals sell legal templates online?

No. Selling state-specific legal templates with customization or guidance is UPL in most states, although generic educational materials without client-specific instructions can be sold if clearly marked as informational only.

Is virtual paralegal work legal in every state?

Yes. Virtual paralegal work is legal in all 50 states when the paralegal works under written attorney supervision, runs conflict checks, and follows the supervising attorney’s state bar rules.

Do paralegal side hustlers need an LLC?

No. An LLC is optional, but most paralegals earning over $20,000 per year in side income form one to protect personal assets from business liability, at a state filing cost of $50 to $800.

Do paralegals owe self-employment tax on side income?

Yes. Net side earnings over $400 trigger 15.3% self-employment tax plus income tax, reported on Schedule C and Schedule SE, with quarterly estimated payments required once total tax owed exceeds $1,000.

Can paralegals notarize documents as a side hustle?

Yes. Paralegals can become notaries public and loan signing agents in all 50 states, earning $5 to $200 per notarization, with Remote Online Notarization legal in 45 states as of 2026.

Is writing legal blog content UPL?

No. Writing general legal information for a law firm’s blog is not UPL if the supervising attorney reviews and approves content, and the posts avoid client-specific advice or misleading claims under Rule 7.1.

Can I use my day-job experience in a side hustle?

Yes. You can market skills learned on the job, but you cannot use your employer’s client lists, templates, or software, and many firms require written permission under a moonlighting policy.

Do paralegals need malpractice insurance for side work?

Yes. Professional liability insurance costing $400 to $1,200 per year is essential because the employer’s policy does not cover outside work, and a single drafting error can cost $50,000 to defend.

Can paralegals represent clients in small claims court?

No. Most states ban non-lawyer representation even in small claims, though a few allow limited representation if specifically authorized, so always check your state’s court rules before helping anyone.

Can paralegals offer services to pro se litigants?

No. Helping pro se litigants usually crosses into UPL, although California Legal Document Assistants and Arizona Legal Paraprofessionals operate under specific state programs that authorize limited pro se support.