I have a similar question. I am currently in law school, but will be applying to PhD programs this fall. My first year of law school I got a lot of B's and B- grades, but my law school GPA will be around a 3.2 - 3.3 when applying. However, 3.4 is the mark for graduating with honors, and surely the adcoms will realize that law school grades are curved at a C or C+, right?