In Memoriam: Diane F. Bosse

This article originally appeared in The Bar Examiner print edition, Spring 2024 (Vol. 93, No. 1), pp. 75–80.

Diane Bosse, former chair of the New York Board of Law Examiners and of the NCBE Board of Trustees, passed away on March 17, 2024.

This special section honoring Bosse includes remembrances from other past NCBE chairs as well as former NCBE president Erica Moeser. See additional reflections from NCBE Board of Trustees chair John J. McAlary and NCBE president and CEO Judith A. Gundersen.

For Diane Bosse’s obituary, please visit www.legacy.com/us/obituaries/buffalonews/name/diane-bosse-obituary?id=54754084, and visit https://www.hurwitzfine.com/lawyers/profile/diane-bosse for a tribute by the law firm for which Bosse was Special Counsel.

Visit the Bar Examiner website at thebarexaminer.ncbex.org/ for articles Bosse wrote over the years. See the tribute on the occasion of Bosse’s retirement from the New York Board in 2020 after 41 years of service.

Remembrance by Hon. Cynthia L. Martin

Some events are so shocking and unexpected that they become immediate and unwelcome benchmarks—“life before and after” points against which the continued movement of time is measured. Diane Bosse’s abrupt passing on March 17, 2024, is such an event for me, and for many others who have been immeasurably affected by Diane’s unique and inimitable style, soul, and spirit.

I came to know Diane through my service on the Board of Trustees of the National Conference of Bar Examiners. I distinctly recall sharing a cab with Diane from the airport when attending my very first board meeting in 2011. I was drawn to Diane instantly; something about her exuded competence, integrity, and professionalism before a word beyond mere pleasantries had been spoken. Anxious for an introduction to the work of the Conference, and to the issues I would soon be asked to monitor and address as a board member, I sought her advice. What should I know? I was promptly schooled on the important work Diane was spearheading to undertake a job analysis to confirm the content validity of the bar examination. Wait—a what? I had assumed that eleven years of service on my state’s board of law examiners were adequate preparation for service on NCBE’s board. Five minutes into my first conversation with Diane, I realized I had a lot to learn.

Little could I have known that I had just forged an instant bond with a masterful, capable, gracious, loyal, and dedicated friend and professional mentor. And little could I have known the full circle that would be formed through my service with Diane on the NCBE board. From that first conversation with Diane (the Conference completed the analysis in 2012); to being appointed to serve with Diane in January 2018 on the Testing Task Force (TTF) charged with undertaking a three-year study to ensure that the bar examination continues to test the knowledge, skills, and abilities required for competent entry-level practice; to our joint multiyear appointment in January 2021 to the Implementation Steering Committee (ISC) charged with identifying and integrating the technical and policy considerations required to implement the TTF’s recommendations for the next generation of the bar examination; my friendship and professional relationship with Diane began and ended immersed in ensuring the bar examination is and remains a valid and reliable measure of minimum competence to practice law, and a high-stakes licensure examination that exceeds professional standards.

We all leave a mark on the world during our lives. For many, that mark is fleeting, like a footprint in the sand—distinct and personal when made, but soon erased by future generations. But for a rare few, that mark is impenetrable and permanent, like the lava fields created after a volcanic eruption—a beautiful, complex, and brilliant reminder of the forces of nature.

Diane was just that: a beautiful, complex, and brilliant force of nature. Through our work on the TTF and ISC, I was blessed with a front-row seat that enabled me to bear witness to the exceptional characteristics that made Diane a difference maker unlike anyone I have or will ever know.

Diane simply could not help but make better all that she touched and committed her time to, with no thought of or desire for recognition or credit. She had uncanny vision and a proactive awareness of the big picture, no matter how complex a project’s dynamics, while at the same time having an extraordinary command of every fine detail required to ensure its success. She never attended a meeting without having meaningfully reviewed and digested all the materials distributed in advance—preparation that was time and again revealed by her insightful questions and comments. She would often preface input apologetically, not because she was being coy or self-effacing, but because she knew what she was about to say was thorny and complicated, and the topic absolutely needed to be discussed. Invariably, the deliverables the TTF and the ISC produced were better as a direct result of Diane’s thoughtful and learned input.

Diane was diminutive in size but larger than life in stature. As a result, she invariably carried her weight and more on every collaborative project. But she never spoke of the indispensable contributions she made to a project’s success. Instead, she was ever generous in her praise of others’ input. Her soft-spoken voice belied the far-reaching command of her message. Her warm and frequent smile was welcoming, but always accompanied by her laser sharp focus.

Diane was faithful. Family focused. Fearless. Fair minded. And a devoted and loyal friend.  

And now she is gone. Our collective hearts are broken. 

No one controls our entry into this world. Few control the timing or means of their departure. Yet we all control how the story between those first and last chapters is written. The story that Diane wrote is a classic—one for the ages. It’s one we did not want to close or put down, a book that leaves us hungry for more, unsatisfied with the knowledge that she cannot author a sequel.

But perhaps we can draw solace from knowing that Diane’s legacy is the life story that she has written. There can be no debate: because of years of tireless, unselfish, and selfless service, Diane Bosse has positively and permanently refashioned the landscape of bar admissions and legal education.

As a result, though our Diane is gone, she is not and will never be forgotten.

Remembrance by David R. Boyd

I met Diane Bosse in the late 1990s, when both of us were NCBE volunteers. We, a New Yorker and an Alabamian, shared high school and law school graduation years, but that’s about all I knew beyond our mutual involvement with bar admissions. Along with everyone else at NCBE, I quickly realized that this lawyer from Buffalo was something special. She  rapidly became a fixture at the organization and took on the most challenging jobs, both before and after her year as Board of Trustees chair.

Diane and I ended up working together on many NCBE matters, which included serving on the Board of Trustees, co-chairing the Long Range Planning Committee for several years, helping lead a content validity study and, most recently, participating on the Testing Task Force. Along the way, my appreciation for Diane as a gifted and dedicated professional—but even more so as a remarkable human being—never stopped growing. As it turned out, we had a lot more in common than I imagined, and she became one of my most cherished friends. Although I’m pretty sure she wouldn’t claim me, over those two-plus decades I also came to see her as the sister I never had.

On the Tuesday evening before Diane’s sudden passing, she and I visited by text message, just a spur-of-the-moment exchange to catch up. “It would be great to see y’all,” I wrote, prompting her pithy retort: “Anytime, anywhere.” Even if only casual banter, Diane’s response said a lot more to me as I reread it after receiving the tragic news. I realized that it was so perfectly in character; in many ways it summed up how she lived.

Professionally, Diane was unfailingly generous with her time and talents, ready “anytime” to commit to activities or organizations she found important. And, as demonstrated by the breadth of those activities, she was willing to go virtually “anywhere” to contribute to a worthwhile cause, and often in a leadership role. Her experience is staggering, including  service with organizations such as the New York Board of Law Examiners, the ABA Section of Legal Education and Admissions to the Bar and its Accreditation Committee, and, of course, NCBE. She did all this and much more while excelling in a challenging law practice.

Still, Diane prioritized more important things, beginning with her family, and particularly her beloved husband Coleman, who over the years became a lasting part of NCBE’s fabric as well. Diane’s generosity—her willingness to serve others “anytime, anywhere”—was also manifested in her constant and abiding concern for her NCBE friends and their families. It might have been as simple as her sending a recipe for “bourbon bacon chocolate chip cookies,” or as impactful as reaching out to members of the NCBE family in times of health challenges or grief, or doing so on happier occasions involving children or grandchildren, birthdays, baptisms, and graduations. Whatever the circumstance, Diane was never too busy to be a friend, and being her friend had the added benefit of friendship with ­Coleman, to whom she was intensely devoted. For my wife, Toni, and me, our friendship included searching for the best grits, keeping Tabasco on Coleman’s shelf, monitoring his quest to visit every state, and sharing his memorable visit to the World War II Museum. He and Diane were a remarkable couple with a beautiful love story.

Wherever she happened to be contributing her unmatched talents, Diane seemed to be one step ahead. She read everything thoroughly and was invariably the most prepared person in a meeting. Sitting there with her, especially as her co-chair, could be a humbling, if not intimidating, experience. A listener first, Diane was remarkably proficient in directing or redirecting any discussion in a productive way. Diane’s standard was to be exacting in everything; her personal work ethic and discipline were unparalleled. She did nothing by halves, and nothing fell through the cracks. She was low key but persuasive. Determined but patient. Efficient but unhurried. Frank but tactful. Confident but self-effacing. Diane was elegant in thought, manner, and appearance—and always filled with grace and humility.

She had a natural wit about her, delivering playful quips that never failed to amuse. Seldom did I get an email that didn’t include some humorous aside, frequently in the form of a good-natured barb directed at me or one of our other NCBE buddies, or even at Coleman. She once observed that, as her committee co-chair, I was pretty good at looking for comma errors in her draft reports, but otherwise useless and always “requiring patience and care … and significant prodding.” She wrote all the reports, not only because she had to if we were to meet the deadline, but also because of her “experience that [I didn’t] take very good notes.” While congratulating our NCBE colleague Greg Murphy, with whom we both served on the Board of Trustees together for a few years, on the upcoming birth of the latest of his many grandchildren, she wondered to an email group whether “anyone else thinks the Murphys are going for world domination.” Exempting no one, she reminded a colleague that Coleman wanted to “get a few pointers on additional power tools he can buy and not use.” And she once wrote that she and Coleman were flying to Florida, thus “saving [her] 22 hours of a monologue on his excellent driving skills and the poor driving skills of fellow travelers.” Diane was just as quick and witty in person; always understated and with perfect timing. She also had no problem laughing at herself and never, ever took herself too seriously. She chuckled at Coleman’s description of her as “a three ball juggler with six balls in the air.”

No NCBE volunteer contributed more to the organization, over a longer period, than Diane. She will be remembered for her many vital contributions to the Conference’s work, to be sure, but perhaps even more so for the warmth and kindness she displayed in everything she undertook and with everyone with whom she came into contact. Generosity of spirit combined with an intense seriousness of purpose—that was the lovely and remarkable Diane, an unforgettable part of my life.

Remembrance by Erica Moeser

(edited excerpts from Erica Moeser’s eulogy at the funeral service for Diane Bosse)

Good morning, and thank you for coming together to grieve and to lend support to the people Diane loved above all others. Perhaps you share my disbelief that someone so talented and spirited left our lives so abruptly under circumstances that none of us would have predicted. The loss is immeasurable, and it is difficult to come to terms with it. How, on a sunny Florida morning, could Diane’s life end in such a tragic way? But it did, and now we are grappling with the aftermath of the moment when the news reached each of us. That moment is seared in our consciousness. It is unforgettable. Just as Diane is unforgettable.

And what is it we know about her, what we will never forget?  Professionally Diane was an achiever. She believed in service. When she tackled an assignment, it was completed to perfection. She was a person of considerable intellect, and that intellect was matched by a prodigious work ethic. Diane was disciplined. She kept commitments. Diane was imaginative in crafting solutions. She was determined and unshakeable when the situation required it.

Diane had numerous professional dimensions. Her law practice was one, and her volunteer activities with the New York Board of Law Examiners, with the National Conference of Bar Examiners, and the American Bar Association were performed with the same rigor and the same drive and heart that she brought to her law practice.

Somehow, in the volunteer context, Diane always managed to get into the position of doing the heavy lifting. She was the ultimate shepherd who saw to it that the work of the Board was done—and done well.

Similarly, her willingness to put a shoulder to the wheel meant that Diane was tasked with leadership roles in the national organizations she gave her time to. Her work was recognized for its excellence and her dedication, as exemplified by the fact that the ABA Section of Legal Education and Admissions to the Bar bestowed its most prestigious honor, the annual Kutak Award, on Diane for her contributions to legal education, the bench, and the bar.

I am sure that many of you here today knew Diane in one or more of these contexts, and you can attest to the quality that she contributed to everything she did professionally.

But today is about other, arguably more important aspects of Diane, and here I hope to join you in focusing on Diane, the extraordinary wife, family member, and friend, for that is at the heart of what brings us together to remember her.

One of the pillars of Diane’s life, in addition to her faith and family, was her army of friends, many of whom are here today, some having traveled great distances to get here. Diane earned each friendship by being the person that she was, frank and funny, smart and principled. Distance made no difference. Diane was a friend, not in the sense that one tosses the word friend around indiscriminately, but in the sense that her friendships were real and true and everlasting.

What will we remember about Diane? Each of us has our unique recollections. I will remember Diane’s distinctive laugh. No one else had a full-throated laugh quite like hers. I can still hear that signature laugh. There were many occasions to laugh with Diane because she had such a quick wit. Her humor sprang from a joyful place, whether during a conversation or in an email. She could be wonderfully funny. How we will miss that.

We all bring memories of the Diane we knew to this moment, and we will have an opportunity to share those later. Her loss is almost beyond comprehension. She was a dazzling figure, loyal and loving, with an array of accomplishments in a life cut far too short. At bedrock, for each of us, she will always be our spectacular, sparkling, unforgettable Diane. She carved a place in our hearts.

Remembrance by Hon. Rebecca White Berch

Perhaps unlike others, I don’t exactly remember when I first met Diane. She was just always there, at the heart of discussions about standards for becoming a lawyer or accrediting law schools, bar admissions, the Uniform Bar Examination (UBE) and portable scores, and professionalism in law practice—which speaks to her steady presence in such important conversations. We might have met at a host of events: at the ABA, where she served on the Accreditation Committee and the Council of the Section of Legal Education and Admissions to the Bar (as chair, of course); or at NCBE, where she served on the Board of Trustees (as chair, of course) and on many other NCBE committees; or at other education events surrounding professionalism and professional standards for the practice of law and admission to practice. As the then-former chair of the New York Bar Examination Committee, she helped New York adopt the UBE—a major coup for both the jurisdiction and NCBE.

Her hallmark? Thoroughly prepared, well-organized and thoughtful presentations. Her participation, no matter the topic, was thorough, deliberate, meticulous, persuasive—and usually brilliant. When Diane spoke, people listened.

Personally, Diane had charm, grace, and humor—terms not often ascribed to our country’s best lawyers. She was kindhearted, caring, considerate, and selfless.

It’s difficult to imagine a world without Diane Bosse in it. But she’s still with us in so many ways. She leaves her legacy in the professionalism she demonstrated and modeled for others, the excellence of her work, and her dedication to the causes she embraced. Will we miss her? Desperately. But we should wish to leave such a legacy.

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