Tag Archives: Florida Bar Ethics Opinions

Florida Bar Board of Governors approves revised rule on qualifying provider fees and ethics opinion on “expert” and “specialist”

Hello everyone and welcome to this Ethics Alert which will discuss recent (October 12, 2018) vote of The Florida Bar’s Board of Governors to approve substantive revisions to Bar Rule 4-7.14 related to the use of “expert” and “specialist” and to approve proposed ethics advisory opinion 17-2, which addresses payment arrangements between lawyers and lawyer referral services (now called qualified providers).    The ethics opinion has been renumbered to 18-1 and the Bar’s notice of the approval of the opinion and requesting comments with a link to the opinion is here:  https://www.floridabar.org/ethics/etprop-advisory/

With regard to the proposed revised Bar Rule 4-7.14, the Board considered a new proposed amendment that is designed to remove the portions of the rule which were found unconstitutional by the federal court judge in 2015.  The proposed revised rule adds new subdivisions to comply to the federal court’s order and also to address the concerns of the Florida Supreme Court, which rejected the Bar’s previous proposed revised rule.

Revised Bar Rule 4-7.14 would allow non-certified attorneys to call themselves “expert” or “specialist” if they can objectively verify that claim based upon the lawyer’s education, training, experience, and “substantial involvement” in the area of practice. The amended rule would also allow law firms to call themselves “experts” or “specialists” if that claim can be objectively verified for at least one lawyer in the firm.  The law firm making the claim would be required to have a disclaimer stating that not all firm members meet the same standards, if there are lawyers who do not qualify.

With regard to Ethics Advisory Opinion 18-1,the Board considered an opinion drafted by the Board Review Committee on Professional Ethics provides that whether a particular payment method between lawyers and qualifying providers f/k/a lawyer referral services is permissible must be determined on a case-by-case basis.  The opinion sets out criteria for determining whether a payment plan is proper and ethical and the ethics opinion is discussed and summarized in the Bar News article here: https://www.floridabar.org/news/tfb-news/?durl=%2Fdivcom%2Fjn%2Fjnnews01.nsf%2F8c9f13012b96736985256aa900624829%2F06fb4fe9ad6425748525830f004fc60b

The Board considered and approved the ethics opinion at its meeting on October 12, 2018 and will consider any comments at its December 14, 2018 meeting in Naples, Florida.

Bottom line:  The Florida Bar’s Board of Governors has taken further steps to address the issues related to the use of “expert” and “specialist” (and the federal court’s ruling that its application was unconstitutional and issuing an injunction) and also the payment arrangements between lawyers and lawyer referral services/qualifying providers.

Be careful out there.

Disclaimer:  this Ethics Alert is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

29605 U.S. Highway 19, N., Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Potential Florida Bar ethics advisory opinion 17-2 will address lawyer referral fees and private client matching services

Hello everyone and welcome to this Ethics Alert which will discuss recent decision by the Florida Bar’s Board of Governors (BOG) to consider a potential ethics advisory opinion to address the ethics issues surrounding lawyer referral fees and private client matching services.  The advisory opinion has not been drafted; however, the draft opinion will be identified as Proposed Advisory Opinion 17-2.

The Bar review began after a lawyer sent an ethics inquiry to The Florida Bar asking whether lawyers could participate with a private lawyer referral service which planned to charge a different set fee depending upon the type of case referred.  The lawyer referred to the system “as a ‘pay-per-lead’ structure.”

The lawyer’s inquiry was referred to the BOG and, at its July 21, 2017 meeting in Miami, the BOG unanimously approved the recommendation of the Board Review Committee on Professional Ethics (BRCPE) that it be directed to prepare an advisory opinion on the inquiry, specifically whether lawyer referral services can charge a fee per referral and impose different fees for different types of cases.  The BRCPE has authority to decline drafting an opinion and the BOG could also decide not to issue the opinion if it is drafted.

If an ethics advisory opinion is drafted, it will address the ethics issues created when online entities (such as AVVO) rolled out programs which attempt to match potential clients with lawyers and which make different payments depending on the type of case.  The opinion would also address the Bar rules related to advertising and referral services.  Lawyers and others will be able to comment on the issues before any opinion is drafted and/or approved.

The Florida Bar Rules have long prohibited lawyers from sharing fees with private referral services.  The Bar’s Standing Committee on Advertising (SCA) also rejected “pay-per-lead” plans on previous appeals and the BOG rejected an appeal from a referral service that proposed a payment of $300.00 to participating lawyers for each referred and accepted case in 2012.

Other jurisdictions have published ethics opinions addressing these issues or are in the process of reviewing them.  As I reported in a recent Ethics Alert blog, New York Ethics Opinion 1132 (published August 8, 2017) found that New York lawyers are prohibited from participating in AVVO’s client referral services.  The opinion found that lawyers who participate in AVVO’s client referral services (and any similar services) would violate the New York Bar rules since they involve AVVO’s improper “vouching” for (recommendation of) the lawyer, improper lawyer referral fees, and improper fee sharing with a non-lawyer.

As background, The Florida Bar filed a petition with proposed Bar rule amendments with the Florida Supreme Court in 2015 addressing, inter alia, referral services that offer both legal and medical or other non-legal services. Those proposed rules would have allowed lawyers to participate in those services, as long as clients were informed about potential conflicts, there was no quid pro quo requiring the lawyer to send a referred client for medical or other services offered by the referral agency, and the lawyer’s independent judgment was not affected.

The Florida Supreme Court published an opinion on September 24, 2015 which declined to implement the rule revisions and instructed the Bar to draft rules that “preclude Florida lawyers from accepting referrals from any lawyer referral service that is not owned or operated by a member of the Bar.”    That opinion is here: 9/24/15 SC Opinion

The Florida Bar then filed revised rule amendments designating private entities which match lawyers with potential clients as “qualified providers” and requiring those entities to comply with the Bar rules, including a required review of the advertisements. Participating lawyers would not have been required to carry malpractice insurance.

The Florida Supreme Court heard oral argument in April 2017 and then published an order dismissing the petition on May 3, 2017. That order is here: 5/3/17 SC Order.  The order stated: “In this case, the Bar proposes amendments to rule 4-7.22 that do not comply with the Court’s direction concerning lawyer referral services that are not owned or operated by a member of the Bar and that seek to expand the scope of the rule to include “matching services” and other similar services not currently regulated by the Bar.

The May 3, 2017 Order also stated that the dismissal was without prejudice “to allow the members of this Court to engage in informed discussions with the Bar and those who are in favor or against the proposed regulation of matching and other similar services. The Court lacks sufficient background information on such services and their regulation at this time.”  A meeting was held at the June 2017 Bar Annual Convention in Boca Raton to discuss the issues and was attended by Justices, Bar officials, and representatives of private referral services.

The Bar’s Notice of the proposed ethics advisory opinion was published in the August 15, 2017 issue of the Florida Bar News.  The Bar’s Notice is here: 8/15/17 Notice of Proposed advisory opinion 17-2.

According to the Notice:  “The Board Review Committee on Professional Ethics will consider adopting a proposed advisory opinion at the direction of The Florida Bar Board of Governors based on an inquiry by a member of The Florida Bar, at a meeting to be held on Thursday, December 7, 2017, from 1-3 p.m. at the Ritz-Carlton on Amelia Island.” and “comments from Florida Bar members are solicited on the issues presented. Comments must contain Proposed Advisory Opinion number 17-2, must clearly state the issues for the committee to consider, may offer suggestions for additional fee arrangements to be addressed by the proposed advisory opinion, and may include a proposed conclusion. Comments should be submitted to Elizabeth Clark Tarbert, Ethics Counsel, The Florida Bar, 651 E. Jefferson Street, Tallahassee 32399-2300, and must be postmarked no later than 30 days from the date of this publication.”

Bottom line:  If the ethics opinion is drafted and approved, Florida will join the growing list of jurisdictions addressing “marketing fees” taken from fees paid by private online entities to lawyers participating in client generation services.  This ethics opinion (like all ethics opinions) would be advisory and for guidance only.

Stay tuned and be careful out there.

Disclaimer:  this e-mail is not an advertisement, does not contain any legal advice, and does not create an attorney/client relationship and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

29605 U.S. Highway 19, N., Suite 150

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

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Lawyer’s ethical obligations in surrendering client papers and property after termination of representation and asserting retaining liens

Hello everyone and welcome to this Ethics Alert will discuss the lawyer’s ethical obligations to surrender papers and property to which the former client is entitled after termination of the representation and asserting retaining liens.  American Bar Association Formal Ethics Opinion 471 provides a good overview of these ethical obligations.  The July 1, 2015 ABA formal ethics opinion is here: ABA Ethics Opinion 471.

ABA Model Rule 1.16, Declining or Terminating Representation is substantially similar to Florida Bar Rule 4-1.16 and requires lawyers to surrender “papers and property to which the client is entitled.”  Neither the Model Rule of the Florida Bar Rules provide a definition of these terms.

The ABA opinion discusses the approaches taken in various jurisdictions and notes that the majority (including Florida) use the “entire file” analysis, wherein clients are entitled to receive all items in the file unless the lawyer can show that the item would fall under one of the generally accepted exceptions, which include the following:

“ materials that would violate a duty of nondisclosure to another person; materials containing a lawyer’s assessment of the client; materials containing information which, if released, could endanger the health, safety or welfare of the client or others; and documents reflecting only internal firm communications and assignments.”

In Florida, the client file is the property of the lawyer and the lawyer may assert a retaining lien on the client file after the representation is terminated; however, Florida Bar Rule 4-1.16(d) states that, upon termination, the lawyer must surrender papers and property to which the client is entitled, take all steps to mitigate the consequences of the termination to the client, and “may retain papers and other property as security only to the extent permitted by law.”

Florida Ethics Opinion 88-11 (Reconsideration) states:

“Many attorneys are unaware that in Florida a case file is considered to be the property of the attorney rather than the client. Dowda and Fields, P.A. v. Cobb , 452 So.2d 1140, 1142 (Fla. 5th DCA 1984); Florida Ethics Opinion 71-37 [since withdrawn]. Under normal circumstances, an attorney should make available to the client, at the client’s expense, copies of information in the file where such information would serve a useful purpose to the client. Opinion 71-37 [since withdrawn].

In appropriate situations, however, an attorney is entitled to refuse to provide copies of material in the file and instead may assert an attorney’s lien. Such situations include a client’s refusal to reimburse a discharged attorney for the attorney’s incurred costs or to provide a reasonable guarantee to the attorney that the costs will be repaid at the conclusion of the case. See Florida Ethics Opinion 71-57. While in such a situation it may be ethically permissible for an attorney to assert a lien with respect to materials in a case file, the validity and extent of the lien is a question of law to be decided by the courts.

Florida common law recognizes two types of attorney’s liens: the charging lien and the retaining lien. The charging lien may be asserted when a client owes the attorney for fees or costs in connection with a specific matter in which a suit has been filed. To impose a charging lien, the attorney must show: (1) a contract between attorney and client; (2) an understanding for payment of attorney’s fees out of the recovery; (3) either an avoidance of payment or a dispute regarding the amount of fees; and (4) timely notice. Daniel Mones, P.A. v. Smith , 486 So.2d 559, 561 (Fla. 1986). The attorney should give timely notice of the asserted charging lien by either filing a notice of lien or otherwise pursuing the lien in the underlying suit. The latter approach is preferred.

Unlike a charging lien, a retaining lien may be asserted with respect to amounts owed by a client for all legal work done on the client’s behalf regardless of whether the materials upon which the retaining lien is asserted are related to the matter in which the outstanding charges were incurred. A retaining lien may be asserted on file materials as well as client funds or property in the attorney’s possession, and may be asserted whether or not a suit has been filed. Mones , 486 So.2d at 561.  Florida Bar Ethics Opinion 88-11 (Reconsideration is here: http://www.floridabar.org/TFB/TFBETOpin.nsf/SMTGT/ETHICS,%20OPINION%2088-11%20(Reconsideration).

An attorney’s right to assert a lien may be limited, however, by the ethical obligation to avoid foreseeable prejudice to the client’s interests. What papers or documents must be furnished to a client in a particular case in order to avoid prejudicing the client’s interest therein will necessarily depend on the specific facts and circumstances involved.

Some  jurisdictions follow the “end product” analysis. Under this analysis, clients are entitled only to those items that are the end product of the representation, and may not be entitled to receive the documents or other materials that led up to the end product.

“…Under these variations of the end product approach, the lawyer must surrender: correspondence by the lawyer for the benefit of the client; investigative reports and other discovery for which the client has paid; and pleadings and other papers filed with a tribunal. The client is also entitled to copies of contracts, wills, corporate records and other similar documents prepared by the lawyer for the client. These items are generally considered the lawyer’s “end product.”

Under this alternative analysis, administrative documents, internal memoranda and preliminary drafts of documents do not have to be returned; however, internal notes and memos may need to be turned over if the final product of the representation has not yet emerged and nondisclosure could harm the client.

Bottom line:  Lawyers must be aware of the requirements of their jurisdictions regarding the return of a client’s file after termination of the representation and before contemplating the assertion of a retaining lien on the client’s file.

Be careful out there!

Disclaimer:  this Ethics Alert is not an advertisement and does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Please note:  Effective June 27, 2016, my new office address is:

29605 U.S. Highway 19 N., Suite 150, Clearwater, Florida 33761

E-mail addresses and telephone numbers below will remain the same. 

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

29605 U.S. Highway 19 N., Suite 150,

Clearwater, Florida 33761

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

 

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Florida Bar’s Professional Ethics Committee concludes that a lawyer can forgive advanced costs after a negligence case is resolved

Hello everyone and welcome to this Ethics Alert blog which will discuss the Bar Professional Ethics Committee’s (PEC) Proposed Advisory Opinion 16-1, which concludes that a lawyer can forgive advanced costs at the conclusion of a negligence case when the lawyer also does not take a fee and inform lien holders and the lawyer advises third parties with an interest in the settlement.  The proposed advisory opinion is here:  Proposed Advisory Op. 16-1.

The PEC considered the issue at its June 17, 2016 meeting at the Bar’s Annual Convention in Orlando.  The underlying circumstances were as follows:  the lawyer had a contingency fee contract with the client and agreed to advance the costs of litigation.  After the case was filed, an appellate decision in another matter eliminated the cause of action.  The parties later reached a settlement, but the settlement amount only slightly exceeded the lawyer’s costs and was about 1/2 of the client’s total medical bills and the costs.

The lawyer waived the contingency fee and then asked the Bar ethics department if he could reduce the amount of the advanced costs so that the client could receive some of the settlement proceeds after the outstanding medical liens and other interests were resolved..  The Bar ethics department opined that this was prohibited under the Bar rules; however, a request was made for the PEC to review it.

The underlying circumstances potentially implicate Florida Bar Rule 4-1.8(e), which prohibits financial assistance to clients “in connection with pending or contemplated litigation” (except for an initial agreement to advance of litigation costs which is contingent upon the outcome (no recovery, no costs), or paying the costs and expenses of an indigent client).

The proposed advisory opinion states the lawyer’s forgiveness of the advanced costs is permitted under the Bar rules since the fee agreement did not make the lawyer unconditionally responsible for the costs “at the outset of the representation”, the cost forgiveness occurred after the settlement of the case, and the lawyer has waived the fees.  The advisory opinion concludes:

In summary, the committee is of the opinion that the inquirer’s proposal not to seek reimbursement for some of the costs the inquirer has advanced on behalf of the client is permissible under these specific circumstances: where there has been no agreement for the inquirer to be unconditionally responsible for the costs at the outset of representation, the cost “forgiveness” occurs after settlement, and the inquirer will receive no fees for the representation. The committee believes that the rule’s prohibition is inapplicable because there was no agreement at the outset of representation for the inquirer to be responsible for the costs, and the committee believes that application of the exception to Rule 4-1.8(e) leads to the same result, as the recovery is insufficient to cover all medical bills and litigation costs and the repayment of the costs is therefore “contingent on the outcome of the matter” under the rule.

The proposed opinion also states that “(i)n negotiating liens, the inquirer must disclose to lien holders that the inquirer will not be taking a fee, will not seek reimbursement for some of the inquirer’s costs, and is seeking to disburse some of the recovery to the client.”  The proposed advisory opinion was published on the Bar’s website and the PEC will consider any comments from Bar members when it meets in October 2016.

Bottom line:  This proposed advisory opinion is clearly a correct result based upon both the language and intent of Florida Bar Rule 4-1.8(e).  In my opinion, the forgiveness of advanced costs after a matter is settled should never be considered to be financial assistance “in connection with pending or contemplated litigation.”

Be careful out there.

Disclaimer:  this Ethics Alert is not an advertisement and does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Please note:  Effective June 27, 2016, my new office address is:

29605 U.S. Highway 19 N., Suite 150, Clearwater, Florida 33761

E-mail addresses and telephone numbers below will remain the same. 

My main office number, (727) 799-1688, is temporarily unavailable due to a telephone company issue.  Please call (727) 286-6625 (my rollover number) if you need to contact me immediately.   Thank you. 

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Filed under Attorney Ethics, Florida Bar, Florida Lawyer Ethics and Professionalism, joe corsmeier, Joseph Corsmeier, Lawyer ethics, Lawyer Ethics and Professionalism, Lawyer ethics opinions, Lawyer waiving costs and fees, Waiver of costs, waiver of costs financial assistance to client

The Florida Bar’s Statewide Committee on Advertising has reversed in part and affirmed in part the recent Bar Staff Opinion on LinkedIn

Hello everyone and welcome to this update of my October 14, 2013 Ethics Alert which will discuss the decision of The Florida Bar Standing Committee on Advertising (SCA) today (October 29, 2013) regarding the 9/11/13 Florida Bar Advertising Staff Opinion.  That Staff Opinion states, inter alia, that Florida lawyers cannot list areas of practice on the LinkedIn “Skills and Expertise” page unless they are Board Certified (or the equivalent).  The September 11, 2013 staff opinion is here:  http://it-lex.org/wp-content/uploads/2013/09/Florida-Bar-Opinion-re-LinkedIn-Redacted.pdf

I have received information today from Bar Ethics and Advertising Counsel Elizabeth Tarbert updating the SCA’s decisions at its meeting today, October 29, 2013 regarding the September 11, 2013 Staff Opinion on LinkedIn.

According to Ms. Tarbert, the SCA voted 3-1 to affirm the staff opinion that the firm may not list areas of practice under the header “specialties” even though the word “specialties” is chosen by LinkedIn and cannot be modified by the firm because the firm controls whether the firm adds areas under the listing, a law firm cannot be certified, and the areas listed are not areas of certification under Rule 4-7.14(a)(4) and 6-3.4(c).

The SCA voted 4-0 to reverse the staff opinion that a listing under “Top Skills and Expertise”  of wrongful death, personal injury litigation, medical malpractice, automobile accidents, product liability (together with a numeric indicator) violates Rule 4-7.14(a)(4), because the firm states that the information is posted solely by LinkedIn and the firm has no control over the posting.

The SCA voted 4-0 to reverse the staff opinion that a posting of a former firm employee requires the area of certification when indicating board certification under Rule 4-7.14(a)(4) because the firm states that LinkedIn is solely responsible for the appearance of the posting of part of a former firm employee’s profile on the firm’s LinkedIn page and the firm has no control over the posting and cannot modify it.

The SCA also voted to contact LinkedIn to inform LinkedIn of the problem created for Florida Bar members by LinkedIn choosing the terms “specialties” and “expertise” in parts of LinkedIn profiles without the entity having the ability to modify those terms, in light of Rule Regulating The Florida Bar 4-7.14(a)(4), and to request that LinkedIn change its method of operation to permit modification of those terms by individual entities when creating their profiles.

The SCA also voted 4-0 to request that the Board of Governors direct the committee to issue a formal advisory opinion on LinkedIn, including the “specialties” header, the endorsements feature that shows endorsements for “skills and expertise.”  If the Board of Governors approves the committee’s request to adopt a formal advisory opinion, a notice will be published in the bar News inviting comments by members of The Florida Bar in good standing in accordance with the Florida Bar Procedures for Issuing Advisory Opinions Relating to Lawyer Advertising or Solicitation.

Bottom line:  This decision by the SCA reverses the advertising staff’s opinion and finds that a listing under “Top Skills and Expertise” does not violate Rule 4-7.14(a)(4) and that a posting of a former firm employee requires that does not have the area of certification when indicating board certification does not violate Rule 4-7.14(a)(4); however, it affirms the staff’s opinion that a law firm may not list areas of practice under the header “specialties” even though the word “specialties” is chosen by LinkedIn and cannot be modified by the firm.  In addition, the SCA voted to contact LinkedIn and inform that entity of the problems created for lawyers and also to ask the BOG to request the SCA to issue a formal opinion on the subject.  This appears to be a step in the right direction and I will keep everyone posted when I receive additional information.

Let’s be careful out there!

Disclaimer:  this e-mail does not contain any legal advice and the comments herein should not be relied upon by anyone who reads it.

Joseph A. Corsmeier, Esquire

Law Office of Joseph A. Corsmeier, P.A.

2454 McMullen Booth Road, Suite 431

Clearwater, Florida 33759

Office (727) 799-1688

Fax     (727) 799-1670

jcorsmeier@jac-law.com

www.jac-law.com

 

 

 

 

 

 

 

 

 

 

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