Americans with a J.D.
Americans with an unapproved JD is more accurate. Again, going to those schools, you need to know the risks. They close a lot of doors, because frankly, there are a lot of scam schools out there that just want your money.
Look at the former SNESL (Southern New England School of Law), their bar passage percentage was in the high 20's, last year, non-ABA approved schools went 0/11 in Georgia. They are not good schools, and are not producing many quality lawyers, which is part of the reason that they are not accredited. Knowing that, and knowing that most states do not recognize those schools it is your own fault if you go there and are held back a bit. However, if you go to a foriegn school (especially if you are not from the USA) you are attending (likely) a quality school in the other regions, and it would be blatent exclusion based on not being a US educated person.
In the end it comes to, you need to know what you are getting into. The ABA approval, is a big deal. As much as those schools try to downplay it, its a HUGE deal. Not having that, closes so many doors its rediculous.