Galanis v. Lyons & Truitt
Indiana Supreme Court
715 N.E.2d 858 (1999)
Lyons & Truitt (plaintiff) represented Suzanne Brown under a one-third contingency-fee agreement for two and a half years before Brown discharged the firm and hired Michael Galanis (defendant) under a new 40-percent contingency agreement; Brown eventually settled for $250,000. Lyons & Truitt sued for compensation, Brown cross-claimed seeking to have Galanis, not herself, bear that cost, and the trial court ordered Galanis to pay Lyons & Truitt a reasonable hourly rate matching a community attorney's rate for similar work; both sides appealed, the court of appeals affirmed, and the Indiana Supreme Court granted review.
Whether an attorney working under a contingency-fee agreement who is discharged before the contingency occurs is entitled to the reasonable value of services rendered before discharge, and how that value should be measured.