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LegalReasonBench

The standard for evaluating realistic long-horizon legal reasoning

    Key findings

    1

    Gemini 4 Argon and Claude Fable 5.1 are the only models to cross 50% on LegalReasonBench, and no model cleared every criterion on any one matter.

    Argon scores 50.8% against 50.6% for Fable and 46.5% for Claude Opus 5.5, and Argon wins more matters outright than any other model. Argon reaches its score at $6.71 of solver cost per matter, about a third of Fable’s $19.74, though it takes longer to get there, 45 minutes per matter at the median against Fable’s 38. Under the all-pass standard that Harvey LAB uses, every model would score zero on LegalReasonBench.

    2

    Every model spots legal issues better than it identifies governing law or applies it to the facts.

    Measured on the IRAC framework, every model scores higher on Issue than on Rule and Application, by 2 to 20 percentage points and 7 to 25 points respectively, and those two components carry 80% of the benchmark’s positive weight. Models find the legal neighborhood and then miss the controlling authority or misapply it, even when the record supplies the law.

    3

    Legal research failures compound legal reasoning failures.

    LegalReasonBench splits its matters between a closed universe, where the record supplies the governing law, and an open universe, where the model must find it through its own research. Moving from closed to open, every model’s Rule score sees a fall of 26 to 38 percentage points and its Application score a fall of 11 to 24. The models that search the most score no better than the models that search the least, which points to the quality of the research rather than the amount.

    4

    The highest-scoring models write the most, but length alone does not predict the ranking.

    Doubling the length of a deliverable adds about 3 points on average once the assignment and model are held fixed, though Gemini 4 Argon gains 18 and Claude Fable 5.1 gains 9. LegalReasonBench caps court-facing filings at a court’s word limits and leaves memoranda uncapped. Most models respect the limits without enforcement, and Fable is the least compliant at 56%.

    5

    A strong start on a long-horizon matter does not predict a strong finish.

    A model’s performance on the first assignment barely predicts its performance on the later ones, and the pattern holds whether or not the later assignments depend on the first and whether or not the record changes between them.

    1. Introduction

    Why we built LegalReasonBench

    LegalReasonBench is the first benchmark to measure legal reasoning on realistic, expert-authored, long-horizon legal workflows. Legal reasoning is the shared judgment that defines elite lawyering. Lawyers may disagree about exactly what a strong work product should look like, but they agree much more on the reasoning required to produce one. They identify the issues, determine the governing rules, apply those rules to the record, and reach supported conclusions. U.S.-educated attorneys know that structure as IRAC, and that consensus gives LegalReasonBench a basis for decomposing legal reasoning into measurable parts.

    LegalReasonBench is designed to maximize realism. Existing benchmarks built on bar-exam style prompts, such as LegalBench, use a format that frontier models have since saturated, and benchmarks built on synthetic tasks and materials, such as Harvey LAB, leave out the messiness of real legal work. LegalReasonBench uses matters that practicing lawyers build end to end, from sourcing the matter and its underlying files to writing the prompts and the evaluation rubrics, and that run from early research through filing-ready advocacy and decision-ready analysis. The client facts and procedural details stay in the uploaded case files rather than being paraphrased into the prompt, so the model has to reason where the facts are messy.

    LegalReasonBench’s rubrics are designed for diagnostic resolution. An all-pass standard for task completion, which Harvey LAB uses, would score every model evaluated here at 0%. LegalReasonBench instead scores weighted criteria, each mapped to an IRAC component, which preserves the signal about the individual legal judgments a model gets right or wrong. That signal can guide future evaluation, research, and post-training.

    What this update adds

    We published preliminary LegalReasonBench results in May 2026. This update changes the agent’s environment, the benchmark’s task composition, and the IRAC classification.

    The agent’s environment is now a true multi-step workflow that mimics how a long-horizon legal matter unfolds. Each matter runs as a sequence of two to five assignments in one persistent sandbox, and each assignment sees only what a lawyer would know at that stage. Because each assignment is scored on its own, we can follow a model’s trajectory across the matter and see how its performance changes from one assignment to the next.

    The task composition is more realistic. In May, every task was open universe with web search on. The updated LegalReasonBench splits evenly between open and closed universe, and the closed matters confine the model to an uploaded record that supplies the governing law along with the facts, so we can separate legal reasoning from legal research. Court-facing work product is now subject to a filing word limit. The role prompt holds motions, pleadings, and briefs to the limits of the Southern District of New York, and memoranda, as internal work product, have none.

    The IRAC classification is more robust. A three-judge panel now assigns each rubric criterion to its IRAC component, in place of the single classifier used in May.

    2. Methodology

    Task construction

    The 50 matters were selected to represent realistic and demanding legal workflows, across practice area, deliverable type, research universe, and horizon structure. Each matter is a sequence of two to five assignments worked in one persistent sandbox, and a practicing lawyer authored the matter, its case file, and its rubrics end to end. The table below summarizes the task set along each of those dimensions.

    DimensionHeadlineDetail
    Matters5022 open-universe (web research allowed), 28 closed-universe (confined to the uploaded record)
    Assignments per matter122 in total74% with 2, 14% with 3, 6% with 4, 6% with 5 assignments
    Deliverable types74% legal memorandum24% motions, briefs and pleadings; 2% administrative-agency submissions; 0.8% correspondence
    Research universe44% open56% closed; the label is the matter's own instruction on web search
    State dependency68% dependentlater work materially builds on the first assignment; 32% low-dependency
    Record evolution86% evolvingthe record changes after the first assignment; 14% static-record
    Case files per mattermedian 6.5range 3 to 25; 395 files in total (309 PDF, 64 DOCX, 22 images); 9 matters ship image exhibits and 41 PDFs in 22 matters are scans or screenshots with no text layer
    Case-file volumemedian 46k tokensinterquartile range 11k to 126k, maximum 4,074k tokens per matter; 116 pages median
    Rubric criteria2,2361,883 positive (23,882 points) and 353 penalty criteria (6,237 points); 3 to 54 per assignment, median 16
    Rubric composition (IRAC)Application 57% of positive weightIssue 7% of criteria / 5% of weight; Rule 29% of criteria / 23% of weight; Application 51% of criteria / 57% of weight; Conclusion 12% of criteria / 14% of weight; Other 1% of criteria / 1% of weight

    The practice areas overlap with Harvey LAB v1.0, which is largely corporate in focus, and add four more: criminal law and procedure, civil rights, administrative law, and sports law. The additions broaden the benchmark beyond the work of large law firms.

    Matters by practice area
    Harvey LAB
    LegalReasonBench additions
    litigation & disputes
    24%
    intellectual property
    20%
    criminal law & procedure
    10%
    real estate
    10%
    civil rights
    8%
    employment & labor
    8%
    healthcare & life sciences
    6%
    capital markets
    4%
    immigration
    4%
    administrative law
    2%
    corporate governance
    2%
    sports law
    2%
    Share of the 50 matters.

    Every matter comes with at least three case files, the documents a lawyer would have on the desk, from pleadings and orders to deposition excerpts and exhibits. The client facts and procedural details stay in those files rather than being summarized into the prompt. Practicing lawyers authored and curated the files. Most matters carry a modest record, with a third holding five or six files and a further fifth seven to nine, but nearly a third carry ten or more, and a handful run past fifteen. Measured in extractable text, half the matters stay under 50,000 tokens, and the rest spread across a long tail, with one matter in six carrying 400,000 tokens or more

    Uploaded files per matter
    16%
    34%
    20%
    24%
    6%
    3 - 6 5 - 6 7 - 9 10 - 14 15 or more
    Share of matters by number of uploaded case files (pleadings, orders, opinions, contracts, deposition excerpts, exhibits).
    Case-file volume per matter
    52%
    16%
    14%
    2%
    16%
    under 50k 50k to 100k 100k to 200k 200k to 400k 400k or more
    Tokens (o200k) of extractable text across a matter's uploaded files: PDFs through pdftotext, DOCX through pandoc; image files carry no text. 50 of 50 matters.

    Agent’s environment

    Each matter drops the model into a sandboxed container with the client's case file under /app/attachments/ and, where the matter allows research, an internet connection. Assignments arrive one at a time. The model writes the deliverable for the current assignment to a fixed path, the verifier grades that file, and the next assignment is issued into the same sandbox, where the earlier documents and the earlier deliverable are still on disk.‍

    /app/ ├── attachments/ The matter's documents (PDF, DOCX, occasionally PNG/JPG) │ ├── order-granting-petition.docx │ ├── complaint.pdf │ └── exhibit-b-photo.jpg ├── response1.md Deliverable for assignment 1 (graded when the assignment ends) └── response2.md Deliverable for assignment 2, written with response1.md still on disk

    Later assignments introduce new facts, new filings, a new jurisdiction, or a new posture. In 68% of the matters, the later work materially requires understanding or building on the first assignment. In 86% of the matters, the factual, documentary, procedural, or legal record changes after the first assignment. These two dimensions, dependency and record evolution, let us test whether a model carries its earlier reasoning forward and whether it revises that reasoning when the record moves.

    Evaluation protocol

    Run settings

    The harness is OpenCode 1.18.31, with reasoning effort set to high for every model. The seven models of the controlled rerun ran on Modal sandboxes with the subagent (Task) tool removed. Gemini 4 Argon* ran on Harbor-hosted sandboxes, with three of its matters rerun on Daytona sandboxes; its Task tool was not removed, but it never called it, so every model works alone. We verified the effort setting on the wire on smoke runs, reading it back from the sandbox rather than taking it from the request. The toolkit is small. The model has a shell with pdftotext, pandoc, and Python for document extraction, file read, write, and edit tools (the GPT-6 models get a single patch tool in place of write and edit), grep and glob, a todo list, and websearch plus webfetch. Each assignment opens with the same legal role prompt, a senior legal analyst on a multi-step matter, with court-brief word limits stated, and has a three-hour time limit. Every model ran every matter three times.

    Scoring

    Grading is a signed rubric per assignment. The 122 assignments carry 2,236 criteria, 3 to 54 each, with positive weights for required points and negative weights for penalties such as misstating the record. The assignment reward is earned points over available positive points, clamped to [0, 1]. The matter reward is the points-weighted total across its assignments. The leaderboard is the mean over matters of the mean of three runs.

    IRAC classification

    ‍A separate three-judge panel assigns each rubric criterion to Issue, Rule, Application, Conclusion, or Other. Each judge sees the matter, the assignment prompt, and the rubric, never a model’s work product, and the majority label is used. The panel agreed unanimously on 78% of criteria and by a two-to-one split on 20%. The 39 criteria with a three-way split were resolved by legal research lead. The classification is fixed per criterion and applied identically to every model.

    Criteria classifiedUnanimousMajority (2 of 3)Three-way split (unresolved)Resolved by the legal leadFleiss' kappa
    2,2491,764 (78%)446 (20%)0390.773
    Judge reliability

    A strict majority of three LLM judges (GPT-5.6 Terra, Claude Sonnet 5, Gemini 3.8 Flash) decides every criterion. Each judge reads the full deliverable independently at medium reasoning effort and votes yes or no on that one criterion, blind to which model wrote the answer. Each deliverable is a single markdown file and every criterion is judged in its own call, which removes two known sources of judge drift, the pressure of grading many criteria at once and content a judge cannot see in some file formats.

    Model gradedPositive criteria gradedUnanimousSplit 2 to 1GPT-5.6 Terra yesClaude Sonnet 5 yesGemini 3.8 Flash yesSeat agrees with panel
    Gemini 4 Argon*5,62879%21%69%68%60%92% to 94%
    Claude Fable 5.15,64978%22%70%66%58%92% to 93%
    Claude Opus 5.55,55077%23%66%64%55%91% to 93%
    Muse Spark 1.35,63877%23%63%57%50%92% to 93%
    Grok 4.75,64977%23%59%56%48%91% to 93%
    Gemini 3.8 Flash5,64979%21%59%56%50%93% to 93%
    GPT-6 Astra5,56278%22%56%55%48%92% to 93%
    GPT-6 Sol5,64978%22%47%46%38%92% to 93%

    Positive criteria only. "Yes" is the seat's yes-share; "seat agrees with panel" is the range across seats of the share of criteria where the seat's vote equals the majority verdict.

    The judges vote unanimously on roughly four criteria in five, and each seat lands on the majority verdict more than nine times in ten. Gemini 3.8 Flash is the strictest seat for every model graded, including its own output, which is the pattern one would expect if no seat favored its own vendor.

    Panel verdict against each single seat
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Panel (majority) GPT-5.6 Terra alone Claude Sonnet 5 alone Gemini 3.8 Flash alone
    Mean of matter means recomputed from one seat's votes on every criterion, penalties included, next to the panel's majority result.

    Rescoring the benchmark from any single seat would move no model’s mean by more than about six points. Claude Sonnet 5 grades most leniently for six of the eight models (GPT-5.6 Terra for the other two) and Gemini 3.8 Flash most strictly for all eight. The same three models lead under every seat, though Claude Fable 5.1 and Gemini 4 Argon* swap first and second under GPT-5.6 Terra, and the closely bunched middle reorders.

    3. Overall performance: leaderboard, cost, time

    Leaderboard

    Gemini 4 Argon leads at 50.8%, with Claude Fable 5.1 at 50.6%. The two are the only models above 50%, and Argon wins more matters outright than any other model. Claude Opus 5.5 sits alone in third at 46.5%. Muse Spark 1.3, Grok 4.7, Gemini 3.8 Flash, and GPT-6 Astra form a middle band within a point of one another, around 40%, and GPT-6 Sol trails at 31.9%.

    Leaderboard
    Mean reward per model (mean of matter means, 95% CI)
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Each model ran every matter three times (1,200 accepted runs). The bar is the mean of the 50 per-matter means; whiskers are a paired matter bootstrap (10,000 resamples).

    The all-pass column shows how far every model is from being trusted with a matter end to end. No run satisfied every criterion of its matter, and only 9% of individual assignments were completed without a miss. Under an all-pass standard every model would score zero, so the LegalReasonBench leaderboard ranks on the weighted rubric score instead, which gives partial credit for the criteria a deliverable does meet and preserves the signal that separates one model from another.

    ModelMeanMedian95% CIbest@3All-passWinsRuns / matters
    Gemini 4 Argon*0.5080.517[0.469, 0.548]0.5820 / 15019150 / 50
    Claude Fable 5.10.5060.520[0.468, 0.544]0.5670 / 15012150 / 50
    Claude Opus 5.50.4650.425[0.420, 0.510]0.5320 / 1477150 / 50
    Muse Spark 1.30.4040.390[0.363, 0.448]0.4680 / 1502150 / 50
    Grok 4.70.4040.383[0.366, 0.444]0.4740 / 1502150 / 50
    Gemini 3.8 Flash0.3960.379[0.358, 0.436]0.4560 / 1501150 / 50
    GPT-6 Astra0.3950.415[0.350, 0.440]0.4410 / 1476150 / 50
    GPT-6 Sol0.3190.290[0.278, 0.363]0.3740 / 1501150 / 50

    best@3: mean over matters of the best of the three runs. All-pass: runs that satisfied every positive criterion and triggered no penalty on every assignment of the matter, the Harvey LAB completion standard. Wins: matters where the model has the highest mean.

    Reading Gemini 4 Argon’s result

    Gemini 4 Argon was released after all other model runs were complete and was added under a near-identical protocol. By then the authors had updated 17 of the 50 matters, so Argon answered a newer version of those tasks than the other seven models did. The head-to-head table is the check on what that means for its result. For each pair of models it takes the difference in score on each matter where both answered the same version of the task, averages those differences, and puts an interval on the average by resampling matters.

    Row model minus column modelArgon*FableOpusMuseGrokGeminiAstraSol
    Gemini 4 Argon*+0.009 33+0.045 33+0.102 48+0.110 33+0.121 33+0.125 33+0.177 33
    Claude Fable 5.1-0.009 33+0.041 50+0.103 46+0.102 50+0.110 50+0.111 50+0.186 50
    Claude Opus 5.5-0.045 33-0.041 50+0.066 46+0.061 50+0.069 50+0.070 50+0.145 50
    Muse Spark 1.3-0.102 48-0.103 46-0.066 46-0.003 46+0.001 46+0.004 46+0.077 46
    Grok 4.7-0.110 33-0.102 50-0.061 50+0.003 46+0.008 50+0.009 50+0.084 50
    Gemini 3.8 Flash-0.121 33-0.110 50-0.069 50-0.001 46-0.008 50+0.002 50+0.077 50
    GPT-6 Astra-0.125 33-0.111 50-0.070 50-0.004 46-0.009 50-0.002 50+0.075 50
    GPT-6 Sol-0.177 33-0.186 50-0.145 50-0.077 46-0.084 50-0.077 50-0.075 50

    Each cell: mean over shared matching-version matters of (row model's matter mean minus column model's), with the number of matters beside the value. Shaded and bold: the 95% matter-bootstrap interval excludes zero (green, row ahead; red, row behind). Policy zeros count as zero. Hover a cell for its interval.

    On the matching-version matters, Argon is ahead of every other model and Fable is ahead of every model except Argon, with each of those gaps standing clear of noise. Between the two of them the difference is under a point, small enough that it could be an accident of the matters selected. Even with this robustness check, Argon and Fable are inseparable, and the rest of the leaderboard order holds.

    Tokenomics

    Cost separates models that the score does not. Claude Fable 5.1 spends $19.74 of solver cost per matter, nearly three times Gemini 4 Argon’s $6.71, for a score 0.2 points lower. In the middle band, four models score within a point of one another while their solver spend runs from under a dollar to over $22 per matter. GPT-6 Astra is the most expensive model to run. It writes fewer tokens than the Claude models, but its list price bills cached context at several times the Claude cache rates and doubles every rate once a request passes 272k tokens, and its long web-research sessions carry large contexts. Muse Spark 1.3 is the cheapest at 87 cents per matter. Judging adds $2 to $7 per matter and scales with the length of the deliverables being read.

    Score against solver cost per matter
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Mean of matter means against mean solver spend per matter, log scale.
    ModelSolver cost per matterEvaluation (judge panel) per matterSandbox and executor per matterTotal per matterSolver per assignmentSolver, all accepted runsEvaluation and compute, all accepted runs
    Gemini 4 Argon*$6.71$6.59$0.02$13.32$2.75$1,007$991
    Claude Fable 5.1$19.74$5.16$0.28$25.17$8.09$2,960$815
    Claude Opus 5.5$8.08$4.76$0.22$13.06$3.31$1,212$747
    Muse Spark 1.3$0.87$4.11$0.11$5.09$0.36$130$633
    Grok 4.7$3.42$3.65$0.21$7.28$1.40$514$579
    Gemini 3.8 Flash$3.96$5.18$0.17$9.31$1.62$595$802
    GPT-6 Astra$22.06$3.16$0.12$25.35$9.04$3,309$492
    GPT-6 Sol$2.45$1.77$0.08$4.30$1.01$368$277

    Means over accepted runs (one run works one matter end to end). Solver: the model under test, every token of every assignment, including the subagent-free tool loop. Evaluation: the three-seat judge panel grading every criterion of every assignment. Across the lineup, accepted runs cost $15,432, of which $10,095 is solver spend.

    Time

    Gemini 4 Argon works longest, 45 minutes per matter at the median, and GPT-6 Sol shortest at 9. Argon’s end-to-end time is longer still, close to two hours per matter, because its runs spent most of their wall-clock time waiting for the provider rather than working. Wall-clock time depends on provider load on the run dates and is not a property of the model alone.

    Score against agent working time per matter
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Mean of matter means against the median agent working time per matter, in minutes.
    ModelAgent minutes per matter (median)Agent minutes per matter (mean)Agent minutes per assignmentEnd-to-end minutes per matter (mean)Overhead (mean end-to-end minus agent)
    Gemini 4 Argon*455823.911253
    Claude Fable 5.1383815.6435
    Claude Opus 5.5303012.4355
    Muse Spark 1.311125.0164
    Grok 4.7262811.6335
    Gemini 3.8 Flash18229.1275
    GPT-6 Astra16156.3205
    GPT-6 Sol993.8144

    Agent working time sums, over a matter's assignments, the span from the first to the last step of the agent's trajectory: the time the model is thinking, calling tools and writing. End-to-end time runs from run start to run completion and adds sandbox setup, the transfer of files between assignments, queueing for a worker and grading by the panel. Wall-clock time depends on provider load on the run dates and is not a property of the model alone.

    4. Decomposing model performance

    IRAC
    Every model spots legal issues better than it identifies governing law or applies it to the facts.

    All eight models score higher on Issue than on Rule or Application. The Issue-to-Rule gap runs from 2 to 20 percentage points and the Issue-to-Application gap from 7 to 25. The direction holds for every model, and the Application gap stands clear of noise for six of the eight. The Rule gap is narrower and, for four models, within noise, so the drop after issue spotting is clearest where the model has to apply the law rather than state it. Gemini 4 Argon identifies the legal question about three times in four and then scores in the high fifties on stating and applying the law. The weakest models show the same drop from a lower starting point.

    Weighted mean score per IRAC bucket (positive criteria)
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Issue Rule Application Conclusion Other
    Positive-weight criteria, pooled over criterion-runs and weighted by rubric points.
    ModelIssueRuleApplicationConclusionIssue minus Rule (95% CI)Issue minus Application (95% CI)
    Gemini 4 Argon*0.7420.5660.5790.592+0.176 [+0.04, +0.33]+0.163 [+0.03, +0.31]
    Claude Fable 5.10.6760.5590.5540.564+0.117 [-0.06, +0.30]+0.122 [-0.04, +0.29]
    Claude Opus 5.50.6700.5210.5140.545+0.149 [-0.02, +0.33]+0.156 [+0.01, +0.31]
    Muse Spark 1.30.6360.5110.4440.429+0.125 [-0.03, +0.29]+0.192 [+0.05, +0.34]
    Grok 4.70.4970.4720.4300.464+0.024 [-0.12, +0.20]+0.067 [-0.07, +0.23]
    Gemini 3.8 Flash0.6320.4400.4480.482+0.193 [+0.01, +0.39]+0.184 [+0.01, +0.37]
    GPT-6 Astra0.6490.4530.4030.419+0.196 [+0.01, +0.38]+0.246 [+0.06, +0.43]
    GPT-6 Sol0.5160.3540.3130.328+0.163 [+0.01, +0.34]+0.203 [+0.06, +0.36]
    Penalties: the higher-scoring models also fall into more traps

    Penalty criteria catch affirmative errors, such as stating an incorrect rule or applying the law in a way the record forbids, and the leading models trip them most. Gemini 4 Argon, Claude Fable 5.1, and Claude Opus 5.5 each trigger about one penalty in four, and GPT-6 Astra about one in eight. The gap is widest on Conclusion and Application, where the three leaders fire penalties at roughly double Astra’s rate.

    Penalty criteria triggered, by bucket (lower is better)
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Issue Rule Application Conclusion Other All penalties
    Share of penalty-criterion instances the grading panel marked as present.
    ModelIssueRuleApplicationConclusionOther
    Gemini 4 Argon*30% 6316% 27330% 48338% 1929% 45
    Claude Fable 5.127% 6313% 27623% 48339% 19224% 45
    Claude Opus 5.530% 6313% 27326% 46527% 19222% 45
    Muse Spark 1.335% 6313% 27327% 48336% 19220% 45
    Grok 4.732% 6316% 27621% 48328% 19211% 45
    Gemini 3.8 Flash41% 6318% 27627% 48336% 1927% 45
    GPT-6 Astra37% 608% 27315% 47416% 1804% 45
    GPT-6 Sol27% 637% 27612% 48314% 1922% 45

    Fire rate, with the number of penalty-criterion instances underneath.

    A closed-universe example shows what the penalties intend to catch.In OTB Gang VICAR Trial Jury Instructions, a closed-universe matter that supplied all the relevant case law and prohibited external research. Models nevertheless applied abuse-of-discretion review standards to the court’s refusal to give the requested justification instruction rather than the applicable de novo standard, triggering a −30 Rule penalty. They supplied a familiar standard associated with jury instructions without identifying the standard governing the particular ruling under review.

    This pattern points to superficial reasoning. The leading models include more of what is right without reliably excluding what is wrong. An expansive answer can cover every required argument and still assert a rule that does not apply or a deadline the record rules out, and legal judgment lies in the selection. Listing the possibilities is not the same as determining which one governs. The verbosity analysis later in this section examines how length relates to score and whether filing word limits change the gaps between models.

    Research Universe
    Legal research failures compound legal reasoning failures

    Comparing Rule and Application scores across the two research universes, every model scores higher on closed-universe matters, where the record supplies the governing law and no outside research is required or permitted, than on open-universe matters, where the model has to find the law itself. 

    Rule scores are 26 to 38 percentage points lower in open-universe matters than in closed ones, for every model, and Application scores 11 to 25 points lower. Claude Fable 5.1 states the governing rule correctly about four times in five when the law is in the record and about two times in five when it has to find the law. Gemini 4 Argon holds up best, with the smallest Rule gap and the highest open-universe Rule score of any model, though its intervals overlap the others.

    Rule score by research universe
    Open universe
    Closed universe
    Argon*
    Fable
    Opus
    Muse
    Grok
    Gemini
    Astra
    Sol
    Mean over matters of the matter's Rule score (earned over available Rule points, runs averaged). Whiskers: matter bootstrap 95% CI.
    Application score by research universe
    Open universe
    Closed universe
    Argon*
    Fable
    Opus
    Muse
    Grok
    Gemini
    Astra
    Sol
    Same construction, Application criteria.

    A trace audit of 64 sampled open-universe failures supports the research reading with a caveat. In most of them the governing authority never entered the trace, but in a fifth the model found the authority, stated it correctly, and misapplied it, and among the matched passes half had cited the authority from memory without retrieving it. Research failure accounts for much of the open-universe gap and not all of it.

    The Application gap is smaller than the Rule gap because Application can fail for either of two reasons, a research failure upstream or a synthesis failure downstream. An Application failure in the closed universe comes from synthesis, from reading the rule and the facts and not putting them together, and supplying the record does not fix that, so the open universe adds less to Application than it does to Rule.

    Research volume does not close the gap. Every open-universe run made at least one web call, from about 17 lookups per run for Muse Spark 1.3 to over 100 for GPT-6 Astra, and the relationship between lookups and score is weakly positive for four models and negative for the other four, including the two leaders. The models that search the most score no better than the models that search the least.

    Web lookups per matter, by research universe
    Open universe
    Closed universe
    Argon*
    Fable
    Opus
    Muse
    Grok
    Gemini
    Astra
    Sol
    Mean websearch plus webfetch calls per run, open-universe matters against closed-universe matters. Whiskers on the open bars: matter-cluster bootstrap 95% CI.
    Verbosity 

    The highest-scoring models write the most, but length alone does not predict the ranking

    Higher-ranked models write longer deliverables

    The deliverables here are long, and the longer writers sit at the top of the leaderboard. Gemini 4 Argon writes a median of about 10,600 words per assignment and Claude Fable 5.1 about 9,700, while GPT-6 Astra writes about 5,800 and GPT-6 Sol about 2,700. The ordering by word count and the ordering by score agree at the top and at the bottom. Without controls, longer deliverables score a little higher, and within an assignment the longest third of the answers beats the shortest third by about ten points. 

    ModelMedian wordsLongest in cellLongest rep bestReward per 2xCoverage per 2xPenalties per 2xMeanAdjusted
    Gemini 4 Argon*10,57457%38%+0.183+0.120+0.0590.5080.490
    Claude Fable 5.19,71020%36%+0.088+0.071+0.0250.5060.491
    Claude Opus 5.58,8564%35%-0.016+0.008-0.0340.4650.455
    Muse Spark 1.36,6701%38%+0.030+0.053-0.0130.4040.406
    Grok 4.77,1401%35%+0.029+0.030-0.0030.4040.404
    Gemini 3.8 Flash8,59216%36%+0.061+0.071-0.0170.3960.387
    GPT-6 Astra5,7520%36%-0.035+0.017-0.0550.3950.404
    GPT-6 Sol2,7160%32%+0.048+0.022+0.0330.3190.361

    Per assignment deliverable; interquartile ranges, token counts and per-matter totals are in data_analysis/verbosity_summary.md. "Longest in cell" is the share of the 122 task steps where this model wrote the longest deliverable of any model. "Longest rep best" compares the model's three repetitions of the same assignment (chance 33%). "Per 2x" columns are the change per doubling of length, with assignment fixed effects within the model. "Mean" is the leaderboard mean; "Adjusted" adds the shift from rescoring every graded deliverable at its assignment's typical length using the pooled slope.

    Within the same assignment and model, the length premium is uneven

    Comparing deliverables written for the same assignment by the same model removes task size and model identity from the length effect, and what remains is small on average and uneven across models. Pooled, a deliverable twice as long scores about three points higher, nearly all of it from covering more rubric items. For Gemini 4 Argon a doubling buys about 18 points and for Claude Fable 5.1 about 9, and both cover more of the rubric and trip fewer penalties as they write more. For Claude Opus 5.5 and GPT-6 Astra a longer answer scores slightly lower, because the added length brings more penalties than coverage.

    What a doubling of length buys, same model, same assignment
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Net reward Rubric coverage Penalties
    Slope of step reward, rubric coverage (positive points earned over the positive total) and penalties (negative points over the positive total) on ln(words), per model with assignment fixed effects, expressed per doubling of length.
    Court-facing filings carry a word limit, and models mostly respect it

    Twenty-eight of the 122 assignments are court-facing filings, and the role prompt holds them to the word limits of the Southern and Eastern Districts of New York: 8,750 words for a brief supporting or opposing a motion, 3,500 for a reply, and 3,500 and 1,750 on a motion for reconsideration. The 93 memoranda and letters carry no word limit. The harness does not enforce the limits and no rubric criterion scores them.

    ModelSubject to a word limit (court-facing)Not subject (memoranda, letters)Difference (95% CI)Median words, court-facingMedian words, memoranda
    Gemini 4 Argon*0.5030.567-0.064 [-0.15, +0.03]8,55211,895
    Claude Fable 5.10.5110.570-0.059 [-0.14, +0.03]8,76110,235
    Claude Opus 5.50.5000.543-0.044 [-0.14, +0.06]7,8249,154
    Muse Spark 1.30.4360.467-0.031 [-0.14, +0.09]6,0576,795
    Grok 4.70.4480.459-0.012 [-0.11, +0.09]7,5747,049
    Gemini 3.8 Flash0.4190.463-0.044 [-0.14, +0.05]8,1508,744
    GPT-6 Astra0.3620.496-0.134 [-0.25, -0.02]4,9975,892
    GPT-6 Sol0.3040.413-0.109 [-0.21, -0.00]2,5762,726

    Mean assignment score over every graded deliverable in each group; the interval resamples matters, keeping all of a matter's assignments together.

    Every model scores lower on the court-facing filings than on the memoranda. For the three leaders the gap is four to six points, and for the two GPT-6 models it is 11 to 13 points, the only two gaps that stand clear of noise. Every model except Grok 4.7 also writes shorter court-facing filings, with Gemini 4 Argon dropping from a median of about 11,900 words on memoranda to about 8,600 on filings. The two groups differ in task as well as in the limit, so the gap describes the assignments as written. A controlled rerun with the word-limit instruction removed, lengthened the filings by 19% and moved scores by under a point.

    Where the limit is stated as a number, on the 16 motion and reply assignments, Muse Spark 1.3, GPT-6 Astra, and GPT-6 Sol never exceed it, four more models comply at least 83% of the time, and Claude Fable 5.1 is the least compliant at 56%, with its median brief right at the limit.

    ModelBriefs with a stated limitWithin the limitMedian words
    Gemini 4 Argon*4883%8,280
    Claude Fable 5.14856%8,329
    Claude Opus 5.54890%7,342
    Muse Spark 1.348100%5,710
    Grok 4.74892%7,270
    Gemini 3.8 Flash4896%8,042
    GPT-6 Astra48100%4,826
    GPT-6 Sol48100%2,320

    The role prompt states numeric limits for briefs supporting or opposing a motion (8,750 words) and replies (3,500), so compliance can be counted on those 16 assignments, three runs each; the other court-facing assignments carry no number in the prompt to check against. Words over the whole deliverable.

    Long-horizon performance
    A strong start on a long-horizon matter does not predict a strong finish

    In legal practice, early performance on a matter is a reliable signal of later performance. An attorney who frames the issues well at the outset tends to handle the motion and the reply well too, because the same judgment carries through each stage. The multi-step environment and the multi-assignment design of each matter let us test whether models show the same consistency. We decompose each run into its first assignment (A1) and the mean of its later assignments (A2+), and ask whether A1 performance predicts A2+ performance within the same matter. We then ask whether that relationship changes when the record evolves between assignments and when the later assignments depend more heavily on the first.

    On average, performance neither collapses nor improves. Gemini 4 Argon and Claude Fable 5.1 tick up slightly after the first assignment, the other six tick down by up to six points, and none of the movements stands clear of noise. The correlation is the more telling number. Within a matter, a model’s score on the first assignment barely predicts its score on the rest, with r between -0.06 and +0.24 for every model and every estimate consistent with zero. The same model can open a matter strongly and finish it poorly, or the reverse, about as often as not.

    Change in mean assignment score, A1 to A2+
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Mean over runs of (A2+ minus A1), same run. Whiskers: matter-cluster bootstrap 95% CI (10,000 resamples, all runs of a resampled matter retained).
    Does early success persist? r(A1, A2+)
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Pearson correlation across same-run pairs of the first-assignment score and the mean of the later assignments, with matter-cluster 95% CI.
    Explicit dependency between assignments does not strengthen performance continuity

    Matters where later work materially requires understanding or building on A1 (34 matters) show no clearer A1-to-A2+ pattern than low-dependency matters (16). The dependency-specific difference in the A1-to-A2+ change ranges from -6.7 to +6.1 percentage points across models, and every interval on that contrast, resampled independently within each stratum, covers zero. The results suggest that models often approach dependent sub-assignments much like separate tasks rather than consistently carrying earlier reasoning forward.

    ModelChange, low-dependencyChange, dependentDependent minus lowr, low-dependencyr, dependentMatters low / dep.
    Gemini 4 Argon*+0.041+0.034-0.007 [-0.17, +0.16]+0.21-0.0616 / 34
    Claude Fable 5.1+0.032-0.005-0.036 [-0.21, +0.14]-0.16-0.0216 / 34
    Claude Opus 5.5-0.034-0.014+0.021 [-0.15, +0.19]-0.03+0.0016 / 33
    Muse Spark 1.3-0.059+0.002+0.061 [-0.11, +0.23]+0.06+0.2516 / 34
    Grok 4.7-0.042-0.010+0.032 [-0.12, +0.19]+0.21+0.1116 / 34
    Gemini 3.8 Flash+0.041-0.026-0.067 [-0.24, +0.11]+0.21+0.0516 / 34
    GPT-6 Astra-0.064-0.042+0.022 [-0.14, +0.17]+0.11+0.1415 / 34
    GPT-6 Sol-0.067-0.058+0.009 [-0.15, +0.16]+0.18+0.2516 / 34
    An evolving record does not produce stronger matter-level persistence either

    In matters where the factual, documentary, procedural, or legal record changes after A1 (43 matters), average A1-to-A2+ changes remain near zero (Argon* +4.3, Fable +1.3, Opus -1.8, Muse -1.0, Grok -1.2, Gemini -1.0, Astra -2.3, Sol -5.1 points) and the relationship between early and later performance remains weak (r -0.08 to +0.16). Static-record matters show somewhat stronger correlations for several models (r -0.03 to +0.73), but they are only 7 matters (14% of the benchmark) and every static-record estimate is underpowered. Taken together, the results suggest that current models do not yet reliably use the dependencies and accumulating record that define long-horizon legal work.

    ModelChange, static recordChange, evolving recordEvolving minus staticr, staticr, evolvingMatters static / evolv.
    Gemini 4 Argon*-0.004+0.043+0.047 [-0.19, +0.28]+0.30-0.037 / 43
    Claude Fable 5.1-0.033+0.013+0.046 [-0.16, +0.25]+0.07-0.087 / 43
    Claude Opus 5.5-0.034-0.018+0.015 [-0.20, +0.21]+0.19-0.017 / 42
    Muse Spark 1.3-0.066-0.010+0.056 [-0.16, +0.27]+0.40+0.167 / 43
    Grok 4.7-0.071-0.012+0.060 [-0.16, +0.27]+0.24+0.117 / 43
    Gemini 3.8 Flash+0.030-0.010-0.041 [-0.32, +0.24]-0.03+0.117 / 43
    GPT-6 Astra-0.203-0.023+0.180 [-0.05, +0.39]+0.29+0.157 / 42
    GPT-6 Sol-0.123-0.051+0.072 [-0.07, +0.21]+0.73+0.137 / 43

    Dependency and record-evolution labels are the research lead's manual coding of each matter. Static-record cells (n = 7) are exploratory.

    Later assignments fail on new analysis, not on lost context.

    The traces point to the new analysis each assignment demands rather than to lost context. Each assignment starts a fresh session with the earlier work on disk, and models open their earlier deliverable in all but 7 of 1,702 later assignments. In an audit of 48 sampled later-assignment failures, drawn evenly across models, one traced to lost context. Most came from the material the later assignment introduced, and a dozen inherited a gap already present in the first deliverable, so the error carried forward. Each assignment in a long-horizon matter tests a new piece of legal reasoning, and for current models, getting the previous piece right carries no advantage into it.

    ModelContext lossAvailable, not usedContradictedEarlier finding never madeCarried forward, failed on new analysisCarried forward unrevisedRevised, reason the rubric rejectsUndeterminedAudited failures
    Gemini 4 Argon*1416
    Claude Fable 5.111316
    Claude Opus 5.5246
    Muse Spark 1.313116
    Grok 4.722116
    Gemini 3.8 Flash11316
    GPT-6 Astra2316
    GPT-6 Sol1146
    All sampled failures161122232148

    Counts describe a seeded, stratified sample of failed criterion-runs read trace by trace, not the population of failures. Of the 16 matched successes, 15 used the earlier finding correctly; 1 lost the earlier finding but re-derived it from the case file. Every row, with its quoted evidence, is in data_analysis/v3_audits/horizon/audit.json.

    Tool use and file processing
    Models now open every visual exhibit, and still score lower on the criteria that need one

    In the preliminary release in May 2026, models often skipped image exhibits and then described their contents anyway, and the rubric penalized the inventions. That gap has closed. Nine of the 50 matters ship image exhibits, and a further 41 PDFs across 22 matters are scans with no text layer, so the model has to look at the page. Every model opened every exhibit on every run.

    Criteria that need a visual exhibit vs the rest
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Needs a visual exhibit Other criteria
    Weighted mean score on the flagged criteria against all other positive criteria, per model.

    The score gap remains. Six of eight models score lower on the criteria that depend on a visual exhibit than on the rest of the rubric. Grok 4.7 falls furthest, 27% against 46%, and Gemini 4 Argon scores highest on the visual criteria at 59%, level with its score on everything else. The judges’ reasoning on the failed visual criteria shows a consistent shape. The deliverable describes the photograph or screenshot and does not draw the inference the assignment wanted from it.

    ModelRuns on image mattersOpened an exhibitVisual criteriaOther criteriaVisual, per matter
    Gemini 4 Argon*27100%0.590.590.63 [0.49, 0.76]
    Claude Fable 5.127100%0.450.570.46 [0.32, 0.61]
    Claude Opus 5.527100%0.460.530.47 [0.34, 0.59]
    Muse Spark 1.327100%0.400.470.36 [0.23, 0.50]
    Grok 4.727100%0.270.460.33 [0.22, 0.45]
    Gemini 3.8 Flash27100%0.490.460.53 [0.39, 0.67]
    GPT-6 Astra27100%0.410.430.43 [0.28, 0.59]
    GPT-6 Sol27100%0.240.340.23 [0.13, 0.35]

    A run counts as opening an exhibit when a tool call reads or processes one of the matter's image files. The last column is the mean over the 16 matters with flagged criteria, with a matter-bootstrap 95% CI.

    The failure comes after access, in synthesizing what the file says

    A trace audit of 60 sampled failures on file-dependent criteria, image exhibits and scanned documents alike, drawn evenly across models, traced each failure through three steps: whether the model opened the file, whether the needed content reached it, and whether the deliverable drew the required conclusion. One file was never opened. Six were opened without the needed content reaching the model, for instance a page rendered but never viewed, or handwriting trusted to OCR. In the other 48 the content reached the model and the failure came afterward, most often in the legal inference, where the model saw the exhibit and did not draw the conclusion, and in a smaller number in perception, where it misread the detail. When text extraction came back empty, models rendered the page, ran OCR, or re-read the file. Access is rarely the bottleneck. Synthesis is.

    ModelNot openedOpened, content not obtainedContent obtained, inference failedUndeterminedAudited failures
    Gemini 4 Argon*1348
    Claude Fable 5.1358
    Claude Opus 5.577
    Muse Spark 1.3268
    Grok 4.7167
    Gemini 3.8 Flash77
    GPT-6 Astra718
    GPT-6 Sol77
    All sampled failures1648560

    Counts describe a seeded, stratified sample of failed criterion-runs read trace by trace, not the population of failures. Of the 25 matched successes, 25 traced to the file's content. Every row, with its quoted evidence, is in data_analysis/v3_audits/files/audit.json.

    More tool calls do not lead to a better score

    Working styles differ widely behind similar scores. Gemini 3.8 Flash fires nearly 150 tool calls per matter and Muse Spark 1.3 makes do with about 50. Half the models lean on pdftotext for document extraction and the other half on Python. The scripted extractors and the search-heavy readers land in the same score band, and within every model the relationship between total tool calls and score is flat or negative.

    Tool calls per matter
    Gemini 4 Argon*
    Claude Fable 5.1
    Claude Opus 5.5
    Muse Spark 1.3
    Grok 4.7
    Gemini 3.8 Flash
    GPT-6 Astra
    GPT-6 Sol
    Mean tool calls per run across all assignments of the matter, all matters.
    ModelTool callsTurnsWeb callsbashreadMinutesOutput tokensr(reward, calls)
    Gemini 4 Argon*120.77626.132.235.4112169k-0.39
    Claude Fable 5.1108.311112.557.719.74386k-0.23
    Claude Opus 5.5107.99312.661.523.33574k-0.41
    Muse Spark 1.352.4417.824.615.31636k-0.24
    Grok 4.789.94618.038.121.83338k-0.21
    Gemini 3.8 Flash148.31508.7111.213.227213k-0.02
    GPT-6 Astra139.85054.742.522.72033k-0.15
    GPT-6 Sol106.65337.535.714.81423k-0.21

    Per run means across all assignments and all matters. r is the Pearson correlation across the model's runs.

    The same holds for web research. Within open-universe matters the relationship between lookups and score is weakly positive for four models and negative for the other four, including the two leaders. Where an assignment confines the model to the uploaded files, seven of eight models made no web call at all, and Gemini 3.8 Flash did on 6% of those runs.

    ModelOpen: web calls per runOpen: runs using webOpen: r(reward, web)Closed: web calls per runClosed: runs using webClosed: r(reward, web)
    Gemini 4 Argon*55.8 [40, 73]100%-0.382.84%-0.10
    Claude Fable 5.127.2 [22, 33]100%-0.091.04%-0.05
    Claude Opus 5.528.0 [22, 35]100%-0.251.04%-0.08
    Muse Spark 1.317.0 [15, 20]100%0.240.54%-0.18
    Grok 4.739.2 [33, 45]100%0.181.34%-0.17
    Gemini 3.8 Flash18.0 [13, 24]100%0.051.519%-0.07
    GPT-6 Astra116.4 [103, 131]100%0.104.44%-0.03
    GPT-6 Sol81.3 [73, 90]100%-0.083.24%-0.14

    Per run means; r is the Pearson correlation across the model's runs in that universe (66 open, 84 closed for most models).

    ModelProhibited assignment runsWith any web accessMatter runs with at least one violationWeb calls on prohibited assignmentsLimited assignments with web use
    Gemini 4 Argon*2070 (0%)0 of 81 (0%)022 of 24
    Claude Fable 5.12070 (0%)0 of 81 (0%)024 of 24
    Claude Opus 5.52070 (0%)0 of 81 (0%)024 of 24
    Muse Spark 1.32070 (0%)0 of 81 (0%)023 of 24
    Grok 4.72070 (0%)0 of 81 (0%)024 of 24
    Gemini 3.8 Flash20713 (6%)13 of 81 (16%)5123 of 24
    GPT-6 Astra2010 (0%)0 of 78 (0%)024 of 24
    GPT-6 Sol2070 (0%)0 of 81 (0%)024 of 24

    Assignment runs: one model run of one assignment. Graded runs only (the content-filter zeros produced no trajectory to check). Limited assignments allow research only as needed to identify the governing rules, so web use there is permitted.

    Conclusion

    LegalReasonBench measures legal reasoning on realistic, expert-authored, long-horizon legal workflows. Practicing lawyers built each matter from the case file to the rubric, the facts stay in the files, the law has to be found or read from the record, and the work arrives in two to five assignments that unfold as a matter would. That setting mimics the one in which an attorney’s judgment is exercised, and it proved difficult for every model to complete end to end. The two leaders barely cross 50% of the weighted score, and under the prevailing all-pass standard adopted by other legal benchmarks such as Harvey LAB, every model evaluated here would score zero.

    The rubric decomposition and the trace analysis point to a gap between coverage and selection, and that gap is the legal judgment the models currently lack. Every model identifies the issue far more reliably than it states the rule or applies it. The leading models earn the most positive criteria without reliably excluding what is wrong. The models that search the web most score no better than the models that search least. The clearest case is court-facing work, where the stakes are highest and the format forbids the survey. That weakness is particularly consequential in court-facing work, where sound analysis must fit within filing constraints. Every model’s mean score is lower on court-facing filings than on memoranda and letters, yet removing the word-limit instruction produces longer answers without a detectable improvement in scores. The challenge is not simply to fit more analysis into a filing, but to determine which analysis belongs there. Taken together, these findings suggest that the legal judgment demonstrated by frontier models today remains superficial.

    These results reinforce our view that the unit for training and evaluating legal judgment should be a realistic, evolving matter. Models should work from expert-curated records and face consequences that increasingly reflect the stakes of legal practice, with each choice tested by the work that follows. LegalReasonBench’s task construction is a step in that direction, providing a foundation for reinforcement-learning environments that train models to exercise meaningful legal judgment.

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