Applying Multiplier to Lodestar Was Improper In Lawyer’s Fee Action Against Divorce Client

The jury in a lawyer’s quantum meruit fee case against a former divorce client should not have been allowed to apply a multiplier to the lodestar amount that reflected the hours expended times the lawyer’s hourly rate, the California Court of Appeal, Second District, held June 18 (Chodos v. Borman, 2014 BL 169738, Cal. Ct. App. 2d Dist., No. B2524466/18/14).

Awarding any enhancement to the lodestar was inappropriate and inequitable where the lawyer did not assume any contingent risk of nonpayment for his services and did not even have a written fee agreement with the client, the court ...