Models tested 12
Perfect 20/20 4
Scored 17+ 8
GunnerBench · Issue No. 1 · Page I About · The Ronin Advisory Group LLC

Issue No. 1 · Page I · June 2026

Everyone passed — now the real question.

Two years ago, a clean pass on a bar-exam essay would have been the headline. Now it is the floor. Hand the current frontier — the most advanced AI models available today — a battery of bar-exam-grade legal problems and the perfect scores pile up at the top of the table — so the question worth asking is no longer who passed. It is what the reasoning was doing on the way there, and where it gave out for the models that fell short.

What you are reading

GunnerBench is a lab that measures how AI models actually behave on hard, real tasks — a workbench for deciding which model to trust with work that carries an obligation. It runs many different kinds of experiments, and will publish many more: different models, different prompts, different tools, different tasks. This issue is one of them. It puts the June 2026 AI frontier on a single hard legal-reasoning task; a future issue will ask a different question entirely. So read this as one experiment in a varied series, not as “the GunnerBench method.”

Concretely, here is the experiment behind everything that follows. Twelve current frontier models — what the field calls the “frontier,” the leading edge of the technology — from five companies that build them (Anthropic, OpenAI, Google, xAI, DeepSeek), each received the same battery of three bar-exam-grade legal essays — Property (fee tail + Rule Against Perpetuities), Criminal Procedure + §1983, and Evidence. Every answer was graded against a detailed checklist of what a correct answer must contain — a rubric, in effect a grading key — and the grading was done not by a person but by a separate, strong AI model (claude-opus-4-6) reading each answer against that checklist. The fact patterns were authored privately and never published anywhere. Four models returned a perfect twenty out of twenty. The full method — rubric items, cost correction, honesty rails — is the deep reference on the methodology page; what follows here is the story those numbers tell.

What we are actually measuring

No practitioner spends their days on the Rule Against Perpetuities, fee tails, or fertile-octogenarian fact patterns. These tasks were not chosen to test legal knowledge. They were chosen because they are dense, interdependent, trap-laden classification problems — a good vehicle for the thing we care about: a model’s ability to hold many analytical and narrative chains in play at once and resolve them correctly without dropping a node. Read the property problem as a working-memory-and-dependency-tracking test wearing a law-school costume.

We do not claim any model here can stand in for a lawyer. Law school does not teach you to be a practicing lawyer — it does not teach the business, the day-to-day, the judgment of practice — and a high score on this battery says nothing about fitness to practice. What it says something about is the reasoning on display: whether a model holds a long, branching chain of analysis together under load and reaches the right destination, or whether it drops a node somewhere along the way. The interest is the reasoning. The task is the vehicle.

The battery

Three tasks. Each is a standalone legal essay question at bar-exam difficulty — the kind a second-year associate would lose sleep over. The models had no special instruction beyond the question itself. They produced memoranda, analyzed doctrine, drew diagrams in code, and reached conclusions. A strong model (claude-opus-4-6) judged the output against four independent 1–5 point-sheet rubrics — Property memo, Property diagram, Criminal Procedure, and Evidence — that sum to 20, applied identically across all twelve contestants, with sub-scores for each issue presented in the task. That judge is an Anthropic model evaluating a field that includes Anthropic models; self-preference is a fair concern. The lab has examined it — the point-sheet style of the rubric partially insulates it from judge-model bias — and we will treat the question more fully in a future issue. The full disclosure is on the methodology page.

Task 1 — Property

Fee tail and the Rule Against Perpetuities

A testamentary devise in a common-law jurisdiction that never abolished the fee tail: Helena Cartwright leaves an orchard, Blackacre, to her son Arthur and the heirs of his body, then to Arthur’s widow for life, then to those of Arthur’s grandchildren who reach twenty-five, and — if no grandchild does — to the Rensselaer Historical Society. The model must: (1) classify the fee tail and each following interest under common-law doctrine; (2) analyze each contingent future interest against the Rule Against Perpetuities in its classical form (no wait-and-see, no cy pres, conclusive fertility presumptions intact); and (3) produce, as code, a six-element estate-chain diagram — chain of title, measuring lives, the RAP timeline, vesting markers, a void/valid distinction, and a legend. Why the RAP and fee tail are the doctrines students never forget — and why this problem breaks reasoning chains, human and machine alike — is the subject of the next section.

Task 2 — Criminal Procedure + §1983

Warrantless search, suppression, and the civil rights overlay

A multi-issue stop-and-arrest memo: Officer Martinez pulls over Dana Collins, obtains ambiguous consent to search, and pries open a locked box with a screwdriver; an arrest follows with a prolonged knee-on-back takedown. The analysis threads Fourth Amendment doctrine (the Jimeno limit on consent to a locked container, the Graham excessive-force standard), Fifth and Sixth Amendment doctrine (an Edwards violation when Martinez reinitiates after Collins invokes counsel, and a Missouri v. Seibert question-first two-step on the Mirandized morning statement), the resulting suppression analysis, and a parallel §1983 civil-rights claim — qualified immunity plus a Monell theory against the City for a documented pattern of prior excessive-force complaints. Exclusionary-rule suppression and civil liability answer different questions; the memo must keep them apart.

Task 3 — Evidence

Hearsay, exceptions, and the Confrontation Clause

A wire-fraud prosecution (United States v. Reyes) with five items of evidence — Items A through E — each to be classified for hearsay and Confrontation. The traps are structural. A bystander’s dying statement looks like a dying declaration, but that Federal Rules exception reaches only homicide prosecutions and civil cases — in this wire-fraud case it disappears, and the fallback runs through excited utterance. A notarized affidavit from an unavailable witness is “testimonial” under Crawford v. Washington, so the Confrontation Clause bars it however tidy the hearsay exception looks. And a statement to a psychiatrist, offered to prove the truth of the underlying transfers, does not fit the 803(3) state-of-mind exception — the offering purpose is the trap. Each flips on a single rule a practitioner will know and a generalist will miss.

Why the property problem is the hard one

Of the three tasks, the property devise is the centerpiece of this issue, and it is worth saying plainly why — because the phrase the question uses, classify each interest, hides the entire difficulty.

A will like Helena’s does not hand the orchard to one person. It sets up a relay: Blackacre passes from Arthur, to a future widow, to grandchildren who reach a certain age, to a charity — each taking only if the one before falls away, some of them not yet born, some conditioned on events decades off. Before you can say who ends up owning the land, you have to name every runner in that relay and every leg of it: who holds a right now, who holds a future right, what kind of future right it is, and whether it is locked in or still hanging on a condition. That naming step is what lawyers mean by “identifying the interests,” and nothing downstream can be correct until it is done.

That is the first reason it is brutal: it is a chain, not a checklist. Each step assumes the one before it. Misname the very first interest and every conclusion that follows inherits the error — cleanly, confidently, and wrong. A single early slip does not cost one point; it quietly forfeits the rest of the answer.

The second reason is the Rule Against Perpetuities — the doctrine students remember as the hardest thing they ever saw, so notorious that the California Supreme Court once held a lawyer was not negligent for getting it wrong (Lucas v. Hamm). The Rule does not ask what will happen; it asks what could happen, under any turn of events the words permit — an interest is void if there is any scenario, however far-fetched, in which it might vest too far in the future. The classical version makes you reason from premises deliberately detached from reality: a woman of eighty is presumed still able to bear children (the “fertile octogenarian”), and a living man’s eventual “widow” might turn out to be someone not yet born (the “unborn widow”). You hold a dozen interacting conditions in mind at once and reason about pure logical possibility, not probability.

That is precisely the shape of problem that separates fluent language from actual reasoning — for a person and for a model. It is long, it is interdependent, and it rewards holding many interlocking conditions in working memory without dropping one. A model that has merely absorbed the vocabulary of estates and perpetuities can produce a memo that reads like the real thing and still snap a link halfway down the chain — and, because the doctrine is counterintuitive, do it with complete confidence. That failure — the polished, self-assured answer that is wrong from a single broken link — is the one this issue spends the most time on, and the property problem is where it surfaces.

These fact patterns were never published

Every leaderboard result carries a shadow question: did the model generalize, or did it recall? A bar exam published in 2018 has been on the internet ever since, and a model trained on legal text has likely seen it. A high score on a known exam is consistent with memorized recall. It is not evidence of live reasoning under load.

A perfect score on a private, first-run battery is generalization on sight, not memorized recall. That distinction is the whole argument.

These three essays were authored privately. They were first run in April 2026 and have never been published anywhere. There is no mechanism by which these exact fact patterns could be in any model’s training data. The ambiguous consent to search a locked box, the jurisdiction that never abolished the fee tail, the dying declaration in a non-homicide case: none of it exists anywhere else. When a model scores perfectly on this battery, it did so by applying doctrine to a situation it had never encountered, not by retrieving a cached answer to a familiar question. That is the distinction that separates this result from a leaderboard number, and it is load-bearing. Without it, the perfect scores would tell us less.

The scoreboard

Scores are channel-corrected — the “channel” being simply how and where each model was run, which service it was reached through. Costs are put on a common basis, and the judge applied the same rubric to every answer regardless of where it originated. Anthropic models ran on their own native service (claude-code); all other models ran through a shared service called OpenRouter.‡ Here is what the frontier looks like on this battery:

12 models · four 1–5 rubrics summing to 20 · channel-corrected · judged by claude-opus-4-6

# Model Score / 20 Channel
1 claude-fable-5 20 claude-code
1 claude-opus-4.7 20 claude-code
1 gpt-5.5 20 openrouter ‡
1 deepseek-v4-pro 20 openrouter ‡
5 claude-opus-4.6 19 claude-code
5 gemini-3.5-flash 19 openrouter ‡
7 gemini-3.1-pro 18 openrouter ‡
8 claude-opus-4.8 17 claude-code
9 gpt-5.4 16 openrouter ‡
10 grok-4.3 14 openrouter ‡
11 haiku-4.5 13 claude-code
11 deepseek-v3.2 13 openrouter ‡

A few things leap out immediately. An open-weight model — one anyone can download and run on their own computers, as opposed to one you can only reach through the company’s own service — deepseek-v4-pro — ties the closed frontier at a perfect 20. That is not a rounding result. Eight of twelve models scored 17 or higher. The range from 17 to 20 is the gap between “strong sustained reasoning” and “no node dropped.” Below 17, the models begin to miss structural issues or handle the traps incorrectly — the chain breaks somewhere.

One number in the table deserves a connecting line: claude-opus-4.8 sits at 17 — mid-pack, not at the bottom. That 17 breaks down as three perfect fives — Criminal Procedure, Evidence, and the property diagram — plus a 2/5 on the property memo. (So the “mid-pack 17” here and the “memo 2/5” you will see on Page II’s chart are the same fact, seen two ways.) It earned that score by acing Criminal Procedure and Evidence while making a single confident miss on the property memo. Models further down the table broke earlier and more often, but their breaks were structurally legible — a missed classification, a near-miss on a single issue. The opus-4.8 miss was different: it classified every interest correctly and even flagged the traps in its own analysis, then committed to one wrong legal premise that carried a wrong conclusion all the way through — crisply, with full confidence, in publication-quality prose. That is the kind of failure a high aggregate score hides, and it is the thread Page II picks up.

Criminal procedure is now trivial for the frontier

The three tasks did not all discriminate equally. The criminal procedure memo was the most thoroughly handled: on the channel-corrected set, every model in the battery scored a perfect five on it — and not against a soft rubric: a five demanded catching the Edwards reinitiation bar, the Seibert question-first two-step, qualified immunity’s clearly-established prong, and Monell municipal liability, and the field cleared them all. (The models that land at 13 or 14 overall lose those points on the property and evidence essays, not here.) Fourth Amendment doctrine, §1983 analysis, suppression arguments — these have been legal-technology bread and butter for years, and the frontier has absorbed them completely. A domain that once required extended reasoning chains to navigate is no longer a distinguishing variable at the top of the field. The chains hold without effort; saturation is complete.

The property task, by contrast, continued to discriminate. The fee tail analysis and the classical RAP application (with its fertile-octogenarian and unborn-widow presumptions) produced the most spread in scores below the top. This is not surprising: the RAP is genuinely difficult conceptually because it demands reasoning about logical possibility rather than empirical probability — you must ask whether a future interest could vest too remotely under any state of affairs the language permits, not whether it will. That style of analysis is harder to generalize from examples; the chains are longer and more brittle. The evidence task, with its layered traps, fell between the two.

The models now draw the diagrams

The property task demanded more than doctrine. It asked for a six-element estate-chain diagram: the chain of title across the conveyance, the measuring lives identified, a RAP timeline with vesting markers, a void/valid distinction for each interest, and a legend. This is not a textual analysis task. It requires the model to produce, as code, a structured visual artifact that a reader can follow in order to check the legal reasoning — a second analytical chain, parallel to the prose, that must agree with it.

Several models at the top of the scoreboard produced accurate, publication-grade diagrams alongside correct doctrine. The diagrams show the estate chain in the correct sequence, mark the measuring lives, carry the RAP clock, and label each future interest as valid or void with a reference back to the analytical conclusion in the memo. This is a capability that simply did not exist at the top of the field until recently. A year ago, a model might have described the diagram; now it produces one you can read — and that matches the prose analysis.

The exhibit gallery lets you see these diagrams directly, in context, alongside the memos they accompany. Read the lawyering yourself — the exhibit gallery is open.

An honest caveat

This battery saturated at the top. But “saturated” describes this battery — three essays, three domains, one rubric, one sitting — not a universal law. Legal practice is vast. The doctrines tested here — property conveyances, constitutional criminal procedure, federal evidence — are areas in which the frontier has had years of exposure. Highly specialized, jurisdiction-specific, or genuinely novel questions may fare differently.

The headline — everyone cleared the bar — is real, but it is the least interesting part. For a sophisticated reader, the more interesting question is where the chain broke for the models that did not score perfectly, and what the mechanism was. Was it a dropped classification? A cascade from a single misidentified rule? A correct diagnosis with a wrong conclusion? That is what the next page takes up.

Anthropic models (claude-fable-5, claude-opus-4.7, claude-opus-4.6, claude-opus-4.8, haiku-4.5) scored on the native claude-code service. All other models scored via OpenRouter, with costs corrected to a common basis for comparability — the unit being the token, the chunk of text a model reads and writes and the unit it is billed by. Judge: claude-opus-4-6.

Next — Page II

The scoreboard is the setup. The real story is the failure modes — where models fell short, how the failure moved up the stack as capability rose, and what the mechanism behind each break reveals about the limits of sustained reasoning under load. Page II examines where the chain broke.

Everyone passed. The interesting question is what happened to the models that fell short.