Brinkman v. Doe CA1/2

CourtCalifornia Court of Appeal
DecidedMarch 24, 2026
DocketA173377
StatusUnpublished

This text of Brinkman v. Doe CA1/2 (Brinkman v. Doe CA1/2) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brinkman v. Doe CA1/2, (Cal. Ct. App. 2026).

Opinion

Filed 3/24/26 Brinkman v. Doe CA1/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION TWO

ERIN BRINKMAN, et al., Plaintiffs, Cross-Defendants, and Respondents, A173377

v. (City & County of San Francisco JANE DOE, Super. Ct. No. CGC-22-603026) Defendant, Cross- Complainant, and Appellant.

Appellant Jane Doe was the lead plaintiff in a class action alleging discrimination against two banks. She was represented by the attorneys who are the respondents here. The attorneys negotiated separate settlements with each of the banks, and in the course of the second settlement a dispute arose as to the attorney fees to which the attorneys were entitled. The attorneys filed an action for declaratory relief, and Doe filed a cross- complaint seeking similar relief and several other claims. The parties filed competing motions for summary adjudication on their claims for declaratory relief, and the trial court ruled for the attorneys. The attorneys then moved for summary judgment on Doe’s remaining claims, on the basis that the summary adjudication meant that those claims could not succeed. The trial court granted that motion too, and entered judgment for the attorneys. We

1 affirm. BACKGROUND The General Setting In March 2019, represented by Erin Brinkman, Doe filed in the United States District Court a class action lawsuit naming a bank as defendant (the federal action). The federal action alleged that the bank, which came to be identified as Bank One,1 unlawfully discriminated against Doe and the putative class by denying them the ability to open an account because of their United States citizenship status. The complaint stated causes of action under the Unruh Act (Civ. Code, § 51 et seq.) and the Civil Rights Act of 1866 (42 U.S.C. § 1981), and sought statutory damages under the Unruh Act of $4,000 for Doe and the members of the putative California class, an award of attorney fees, and punitive damages. In February 2020, Doe retained additional counsel to represent her along with Ms. Brinkman: the firm of Lieff Cabraser Heimann & Bernstein LLP (Lieff Cabraser). When referred to collectively, Ms. Brinkman and Lieff Cabraser will, for consistency with the briefing, will be called Attorneys. When Lieff Cabraser became involved, Anne Shaver, an attorney at that firm, prepared a fee agreement and sent it to Ms. Brinkman for execution by Doe. On February 14, Ms. Brinkman emailed the fee agreement to Doe requesting that she review the agreement and sign it. Doe signed it and returned the signature pages that same day. As pertinent here, the fee agreement included a detailed description of contingent fee provisions that varied depending upon developments in the litigation, providing as follows:

1 Because Doe elected to proceed below in a fictitious capacity though having sued the bank using her real name, to protect Doe’s anonymity the defendant bank was referred to in the record below as Bank One.

2 “3. Contingent Legal Fee. CLIENT recognizes that she may recover as a result of a successful completion of this litigation and that any recovery will be the result of either an award by the court or a settlement. Should CLIENT recover money on CLIENT’s claims, CLIENT will then be obligated to pay a contingent fee to ATTORNEYS. “If the action is certified as a class action, and if a monetary recovery is obtained therein for the plaintiff class, either by settlement or judgment, ATTORNEYS retain the right to apply to the court for the greater of ATTORNEYS’ ‘lodestar’ (defined as each Attorney’s or legal professional’s hourly rate times the number of hours each Attorney or legal professional worked on this matter) plus an enhancement of the lodestar that is available to be recovered under applicable law or a reasonable percentage of recovery basis out of such recovery, and/or from the defendants if allowed by statute and case law. “If ATTORNEYS represent CLIENT on an individual basis only and ATTORNEYS obtain a monetary recovery for CLIENT on an individual basis, either by settlement or judgment, ATTORNEYS will be entitled to their costs related solely to the CLIENT’s individual representation, plus compensation for their services related solely to CLIENT’s individual representation in the amount of thirty-five percent (35%) of the total amount of the Gross Value of the settlement or award if obtained before trial begins or the amount forty percent (40%) if the case is resolved after trial commences or goes to judgment. This limitation is not applicable if the attorneys’ fee is negotiated separately or paid separately so as not to reduce the gross value of CLIENT’s recovery. ‘Gross Value’ means the total of all monetary awards obtained whether by settlement, mediated result, arbitration award or court judgment including back and front pay, and damages, but excluding ‘expenses.’ ”

3 The fee agreement also included an acknowledgment that Doe had read and understood its terms.2 Given the nature of the dispute here—between Attorneys and their client over attorney fees—we pause briefly from the chronology to note that this is not the typical setting in which the dispute arises, with an unsophisticated, inexperienced client/plaintiff with his or her attorney. Doe, by contrast, might accurately be called an atypical client and an atypical plaintiff—but quite a class representative. Doe is a litigation paralegal with extensive experience at a litigation law firm, apparently with particular experience in the area of attorney-client fee agreements and disputes, to the point that she serves as a lay arbitrator for the San Francisco Bar Association’s Fee Dispute Arbitration Program. Moreover, Doe has been a plaintiff in at least 10 lawsuits in the past eight years, and entered into written attorney fee agreements in five of them, two of which were putative class actions that included claims for attorney fees under fee-shifting statutes. And as specifically applicable to the litigation here, Doe knew that the Unruh Act contained a fee-shifting provision, and that the complaint expressly sought attorney fees from defendant bank. As Doe would come to testify, fee-shifting statutes “are meant to encourage attorneys to take cases with otherwise low or nonexistent actual damages, and that would encourage

2 It provided as follows: “12. Acknowledgement. The undersigned hereby acknowledge that they have read and understand the foregoing, that they have had the opportunity to consult with independent counsel, and that they agree to the representation on the terms set forth in this AGREEMENT. The undersigned all hereby acknowledge and agree that they have had the opportunity to provide input into the language of this AGREEMENT and that the terms of the AGREEMENT shall not be interpreted strictly against any single party to this AGREEMENT but shall instead be construed in a manner that most completely fulfills the intent of the parties as evidenced overall under the AGREEMENT’s terms.”

4 them to take cases . . . [¶] . . . which might give them an award of attorneys’ fees and very little actual damages from which to take a bite of.” Before Lieff Cabraser entered the picture, Ms. Brinkman had defeated a motion to dismiss by Bank One. She then filed a motion for class certification, but when Lieff Cabraser joined in the representation, Attorneys withdrew the motion and sought to conduct discovery.

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Bluebook (online)
Brinkman v. Doe CA1/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brinkman-v-doe-ca12-calctapp-2026.