Galanis v. Lyons & Truitt

STATON, Judge,

dissenting.

I dissent. Regarding the amount Lyons & Truitt is to recover, I agree with the majority that the Firm is entitled to the reasonable value of the services Truitt rendered under the theory of quantum meruit Kelly v. Smith, 611 N.E.2d 118, 122 (Ind.1993); Estate of Forrester v. Dawalt, 562 N.E.2d 1315, 1317-18 (Ind.Ct.App.1990), reh. denied. The trial court determined that reasonable attorney’s fees in this case equal “the hourly rate of a community attorney charging for similar services.” Recognizing that the trial court considers many factors in determining a rea-' sonable fee, I nevertheless concur in the majority’s affirmance of that determination.

I depart, however, from the majority’s statement that recovery on the basis of quantum meruit is appropriate because the contingent fee was not in writing. Op. at 371 and 372-73. The majority suggests that, if the contingent fee contract had been written rather than oral, the Firm would be entitled to a percentage of the recovery ultimately obtained by Galanis. I cannot agree. The proper recovery does not turn on whether the unfulfilled contingent fee contract is written or oral. In either ease, the attorney is entitled to receive the reasonable value of the services rendered.

I also dissent from the majority’s holding that Galanis is responsible for fees due the Firm. Liability for legal services is essentially a matter of contract. Estate of Anderson v. Smith, 161 Ind.App. 480, 316 N.E.2d 592, 594 (1974). I agree that the attorney and the client should reach a clear agreement regarding fees as soon as possible. If the contract involves a contingent fee, it “shall” be reduced to writing and

shall state the method by which the fee is to be determined, including the percentage or percentages that shall accrue to the lawyer in the event of settlement, trial or appeal, litigation and other expenses to be deducted from the recovery, and whether such expenses are to be deducted before or after the contingent fee is calculated.

Ind. Professional Conduct Rule 1.5(c). A prudent attorney would also contract with the client, in writing, concerning the client’s financial obligation upon the attorney’s discharge or withdrawal. Without specific terms addressing this obligation, the client who has entered into a contract which states the attorney is paid only when there is a recovery must resort to speculation, an unnecessary risk.

Here, Brown hired Galanis to bring her case to settlement or trial. Galanis agreed to do so for a contingent fee of 40%, and Brown voluntarily acquiesced. After trial and compromise, Galanis successfully reduced Brown’s claim to $200,000 for which he was to receive $80,000. The trial court did not *375specifically find the fee arrangement unreasonable.

Notably, the contract between Brown and Galanis did not provide Galanis would pay Brown’s obligation to Truitt, her former attorney. Likewise, there was no agreement, express or implied, between Galanis and either Truitt or the Firm regarding a division of fees. Nor is Galanis’ subsequent representation of Brown the type of arrangement contemplated by Indiana Professional Conduct Rule 1.5(e) where cooperating attorneys enter into a fee-sharing arrangement.4

Under the rule enunciated by the majority, when contracting for his or her own employment, successor counsel must now negotiate contingent fee agreements taking into account the contracts of the client and all former attorneys who have worked on the case, whether or not the services rendered by the former attorneys are valuable to present counsel. This is unworkable.

For the above reasons, I would adhere to the common law rule that makes a client liable for the reasonable value of services performed on her behalf by her attorney and, thus, hold that Brown is responsible for Truitt’s fee. Accordingly, I would affirm the amount of attorney’s fees awarded but would reverse the trial court’s decision to hold Ga-lanis responsible for those fees.

. Prof. Cond. R. 1.5(e) provides:

A division of fee between lawyers who are not in the same firm may be made only if:
(1) the division is in proportion to the services performed by each lawyer or, by written agreement with the client, each lawyer assumes joint responsibility for the representation;
(2) the client is advised of and does not object to the participation of all the lawyers involved; and
(3) the total fee is reasonable.
Comment following the rule explains:
A division of fee is a single billing to a client covering the fee of two or more lawyers who are not in the same firm. A division of fee facilitates association of more than one lawyer in a matter in which neither alone could serve the client as well, and most often is used when the fee is contingent and the division is between a referring lawyer and a trial specialist. Paragraph (e) permits the lawyers to divide a fee on either the basis of the proportion of services they render or by agreement between the participating lawyers if all assume responsibility for the representation as a whole and the client is advised and does not object. It does not require disclosure to the client of the share that each lawyer is to receive. Joint responsibility for the representation entails the obligations stated in Rule 5.1 ["Responsibilities of a Partner or Supervisory Lawyer”] for purposes of the matter involved. (Emphasis added).