Altman v. Lento

CourtDistrict Court, E.D. Michigan
DecidedAugust 27, 2025
Docket2:24-cv-13345
StatusUnknown

This text of Altman v. Lento (Altman v. Lento) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Altman v. Lento, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

KEITH ALTMAN, et al.,

Plaintiffs, Case No. 2:24-cv-13345

v. Honorable Susan K. DeClercq United States District Judge JOHN D. LENTO, et al.,

Defendants. ________________________________/

OPINION AND ORDER GRANTING DEFENDANTS’ MOTION TO DISMISS (ECF No. 11)

Keith Altman and John Lento are both lawyers who run their own firms. In May 2020, they verbally agreed to work together on certain client matters. But their relationship quickly deteriorated, leaving nothing but litigation in its wake. First, Lento sued Altman in New Jersey federal court for, among other things, breaching the verbal agreement. Then, when that case was dismissed, Altman brought this lawsuit. Here, Altman alleges that Lento breached the same verbal agreement that was the subject of the first case, and that Lento maliciously prosecuted him by bringing the first case. As explained below, however, Altman’s contract-related claims were compulsory counterclaims that should have been brought in the first case. And as to malicious prosecution, Altman has not stated a plausible claim for relief. Lento’s motion to dismiss will therefore be granted. I. BACKGROUND A. Factual History

Keith Altman is a Michigan-based lawyer who runs the Law Office of Keith Altman, PLLC. ECF No. 1 at PageID.2. Joseph Lento is a Pennsylvania-based lawyer who runs the Lento Law Firm, LLC. Id. at PageID.1. Around May 2020,

Altman and Lento supposedly entered into a verbal agreement, under which Altman would provide legal services to Lento’s clients in student-defense matters. Id. at PageID.2. That agreement detailed how the parties would share fees and divide responsibilities. Id. at PageID.3. As to responsibilities, Lento would solicit cases and

then refer them to Altman to handle. Id. As to fees, Lento would first deduct his marketing expenses from the total fee. Id. The parties would then split the rest of the fee 60/40, with 60% going to Lento and 40% to Altman. Id.

This arrangement continued for some time. See id. But somewhere along the way, the parties’ relationship soured. Id. Allegedly, Lento was failing to pay Altman his share of the fees, and Lento soon racked up a massive debt for services rendered. Id.

Thus, in February 2022, the parties verbally agreed to modify their agreement. Now, after Lento’s marketing expenses were deducted, Lento would receive 55% of the fee and Altman 45% of it. Id. at PageID.3–4. The parties then supposedly agreed to modify their agreement once more, this time permitting Altman to take $100,000 per month from the fees to pay his employees’ salaries. Id. at PageID.4.

Ultimately, these modifications proved fruitless, and so the parties began to end their working relationship. Id. Altman claims that at this time, Lento still owed him around $700,000 dollars in fees. Id. So when the parties started negotiating the

terms of their breakup, Altman started with a demand for $500,000 to settle the matter. Id. at PageID.5. Lento countered with $365,000 and some other conditions, including mutual non-disparagement agreements and mutual release of all claims. Id. Altman then sent back to Lento a “memorandum of understanding,” which

memorialized these terms in writing. Id. But the back and forth did not stop there. Rather than accepting Altman’s version of the memorandum, Lento revised it further and sent back an unsigned copy

to Altman. Id. Neither party appears to have signed this final copy. See id. at PageID.5–6. At that point, the parties apparently called it quits. Rather than negotiating further, in August 2022, Lento ran to court and kicked off the first of several lawsuits.

Id. at PageID.6. B. Procedural History 1. First District of New Jersey Case

In August 2022, Lento sued Altman in United States District Court for the District of New Jersey. See Lento v. Altman (Lento I), No. 22-cv-04840 (D.N.J. Aug. 1, 2022), ECF No. 1. Lento’s amended complaint asserted federal RICO claims and

several state-law claims against Altman, including claims for breach of contract, bad faith, tortious interference with contract, and unjust enrichment. Lento I, No. 22-cv- 04840 (D.N.J. Sept. 1, 2022), ECF No. 17. Lento’s breach-of-contract claim focused on the original verbal agreement between the parties. Id. at PageID.220–22.

Specifically, Lento alleged that Altman repeatedly breached the verbal agreement by failing to handle the cases assigned to him, failing to honor the terms of the split-fee arrangements, and soliciting clients without Lento’s involvement. Id. at PageID.222.

In response to the amended complaint, Altman moved to dismiss for failure to state a claim under Civil Rule 12(b)(6). Lento I, No. 22-cv-04840 (D.N.J. Nov. 14, 2022), ECF No. 27. Altman did not move to dismiss for lack of personal jurisdiction or for improper venue. See id.

The district court granted Altman’s motion in part and denied it in part. Lento I, No. 22-cv-04840 (D.N.J. June 27, 2023), ECF Nos. 39; 40; see also 2023 WL 4232158, at *19 (D.N.J. June 27, 2023). It dismissed Lento’s federal RICO claims but allowed some of his state-law claims to proceed. Lento I, 2023 WL 4232158, at *19.

After the motion was resolved, Altman filed an answer and filed one counterclaim for breach of contract. Lento I, 22-cv-04840 (D.N.J. Aug. 1, 2023), ECF No. 51. The counterclaim alleged that the “memorandum of understanding”

was a binding contract that Lento violated by suing him. Id. at PageID.663–65. But in March 2024, the district court dismissed Altman’s counterclaim on the merits for failure to state a claim. Lento I, 22-cv-04840 (Mar. 18, 2024), ECF Nos. 122; 123; see also 2024 WL 1154470 (D.N.J. Mar. 18, 2024), aff’d, No. 24-1899, 2025 WL

914306 (3d Cir. Mar. 26, 2025). Altman appealed the dismissal of his counterclaim to the Third Circuit Court of Appeals, but the court affirmed the District Court’s dismissal. See No. 24-1899, 2025 WL 914306, at *4 (3d Cir. Mar. 26, 2025).

A few weeks later, the district court then sua sponte dismissed the remaining claims in the case, all of which were based on state law. Lento I, 22-cv-04840 (D.N.J. Apr. 10, 2024), ECF No. 146. In explaining this decision, the district court first noted that there was no longer federal-question jurisdiction, given that all federal claims

had been dismissed. Id. at PageID.1676. The district court next noted that Lento’s amended complaint did not sufficiently allege diversity jurisdiction, given that it failed to address the citizenship of the LLC law firm parties. Id. at PageID.1676–77.

Although Lento had a motion to amend his complaint outstanding, the district court denied the motion because it found that the proposed second amended complaint suffered from these same jurisdictional defects. Id. at PageID1677–78. Finally, the

district court declined to exercise supplemental jurisdiction over Lento’s remaining state-law claims, choosing instead to dismiss them without prejudice so they could be refiled in state court. Id. at PageID.1677. With that, the district court closed the

case. Id. at PageID.1678. This dismissal effectively sparked another race to the courthouse, with Altman and Lento each rushing to their preferred jurisdictions to refile their claims first. Like a hydra, when one case fell, two more sprung up in its place.

2. Second District of New Jersey Case For his part, Lento chose to refile his state-law claims in New Jersey state court. See Lento v. Altman (Lento II), No. 24-cv-05150 (D.N.J. Apr. 17, 2024), ECF

No. 1. Altman then timely removed back to federal court, invoking the federal district court’s diversity jurisdiction. Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Moore v. New York Cotton Exchange
270 U.S. 593 (Supreme Court, 1926)
Freeman v. Bee MacHine Co., Inc
319 U.S. 448 (Supreme Court, 1943)
Southern Construction Co. v. Pickard
371 U.S. 57 (Supreme Court, 1962)
Baker v. Gold Seal Liquors, Inc.
417 U.S. 467 (Supreme Court, 1974)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Gerber v. Riordan
649 F.3d 514 (Sixth Circuit, 2011)
Barnard v. Hartman
344 N.W.2d 53 (Michigan Court of Appeals, 1983)
Winnett v. Caterpillar, Inc.
553 F.3d 1000 (Sixth Circuit, 2009)
Lambert v. Hartman
517 F.3d 433 (Sixth Circuit, 2008)
Friedman v. Dozorc
312 N.W.2d 585 (Michigan Supreme Court, 1981)
Provident Life & Accident Insurance v. United States
740 F. Supp. 492 (E.D. Tennessee, 1990)
Dionte Tyler v. DH Capital Management, Inc.
736 F.3d 455 (Sixth Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Altman v. Lento, Counsel Stack Legal Research, https://law.counselstack.com/opinion/altman-v-lento-mied-2025.