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3rd DCAApril 22, 2026Reversed and Remanded🔬 Novel Issue

Virgin v. Frexes

Case No. 3D2024-1402

A referring attorney (the client's aunt) signed a Rule 4-1.5(g) fee-division agreement giving her 25% of a contingency fee in an aviation wrongful death case. After the client fired her by email mid-case, the referring lawyer filed a charging lien and the trial court awarded her the full contractual 25% (and alternatively the same sum in quantum meruit). The Third DCA reversed, holding a client may discharge a referral attorney just like any other lawyer, that no express release of joint responsibility is required, and that a discharged referral attorney is limited to modified quantum meruit for pre-discharge, in-scope services.

Key facts

  • A referring attorney who signed a Rule 4-1.5(g) fee-division agreement for 25% of a contingency fee in an aviation wrongful death case filed a charging lien after the client discharged her by email mid-case.
  • The trial court awarded the referring attorney her full contractual 25% of the fee, and alternatively the same amount under quantum meruit.
  • +2 more key facts with a free trial

Why it matters

This is the clearest Florida appellate statement yet that a referral attorney holding a Rule 4-1.5(g) fee-split agreement can be fired like any other lawyer and is then limited to quantum meruit rather than the… — full analysis with a trial

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