The Law Offices Of Jorge Luis Flores, Llcv.Cruz & Associates
After a workers’ compensation claimant discharged her first lawyers and hired new counsel, the original firm asserted a lien for the value of its services. The administrative law judge awarded the firm $15,650 in fees and $1,530 in expenses under quantum meruit, and the State Board affirmed. The superior court reversed, reasoning that the contingent-fee contract was unenforceable and that the evidence did not support the award. The Georgia Court of Appeals held that the contract’s unenforceability did not eliminate the discharged lawyers’ equitable remedy because counsel may recover the reasonable value of lawful services performed before termination. The court also held that the superior court used the wrong standard of review: Board findings supported by any evidence are conclusive, and a reviewing court may not reweigh the record. The Board’s findings were supported by testimony, time records, correspondence, and expense documentation. The court reversed the superior court and affirmed the Board’s fee award.
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