A certified paralegal or certified legal assistant is the title of paralegals in the United States who have met certain education and work experience requirements and have passed one of a number of available certification exams. The primary function of paralegals is to assist attorneys in the delivery of legal services. According to the American Bar Association: "A legal assistant or paralegal is a person, qualified by education, training and/or work experience who is employed or retained by a lawyer, law office, corporation, governmental agency or other entity and who performs specifically delegated substantive legal work for which a lawyer is responsible."[1] Because certification programs are voluntary in most states, a paralegal may find work in the field without obtaining certification. Additionally, requirements for certification may vary by state.