Napoli Shkolnik PLLC v. Trice, No. 18-2172 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed the district court's order denying Napoli's quantum meruit request for attorney's fees. The court held that the district court did not fail to balance all factors and equities as required under Minnesota law when determining the reasonable value of Napoli's legal services. In this case, Napoli's services harmed, rather than helped, its clients. Therefore, the district court's consideration of additional factors would not have disturbed the district court's conclusion. The court also held that the district court applied the correct legal standard to consider the quantum meruit claims, and the district court did not abuse its discretion by considering allegations of misconduct, including Napoli's harm to its clients.
Court Description: [Kelly, Author, with Colloton and Beam, Circuit Judges] Civil case - Attorneys' fees. The district court did not err in determining that the plaintiff law firm was not owed any part of the contingency fees in the case under a quantum meruit theory; the firm's actions while lead counsel did not benefit the clients and it actually harmed them by failing to meet critical discovery and expert disclosure deadlines in the underlying litigation.
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