BYNUM-WILLIAMS v. SCUDERI

District Court, M.D. Georgia·Decided September 9, 2025·No. 5:23-cv-00265·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION

SYBIL ANGELA BYNUM-WILLIAMS, ) ) Plaintiff, ) ) v. ) CIVIL ACTION NO. 5:23-cv-265 (MTT) ) CHRISTOPHER SCUDERI, ) ) Defendant. ) __________________ )

ORDER M. Devlin Cooper, Kenneth E. Barton III, and Cooper, Barton & Cooper, LLP (collectively, “Former Counsel”) request that the Court enter an order recognizing the existence of an attorney-client relationship between Plaintiff Sybil Angela Bynum- Williams and Former Counsel and to satisfy Former Counsel’s attorney’s lien. Doc. 46. For the reasons that follow, Former Counsel’s motion (Doc. 46) is GRANTED. I. BACKGROUND On or about March 23, 2023, the Plaintiff retained Former Counsel to represent her in the present action and in a criminal defense case pending in Houston County, Georgia. Docs. 46 ¶ 3; 51 at 1. The Plaintiff paid Former Counsel a $5,000 retainer for representation in the Houston County criminal case. Docs. 51 at 1; 42-4. Former Counsel maintains that around the same time, Plaintiff and Former Counsel signed and executed a written agreement providing for a thirty-five percent contingency fee in the present action. Doc. 41 at 1-2. However, Former Counsel cannot locate the purported written agreement. Id. The Plaintiff maintains that Former Counsel “never provide[d] a written contingency fee agreement and contract to sign.” Doc. 51 at 2. In June 2024, the parties participated in a successful mediation with former Superior Court Judge Lamar Sizemore and drafted a written settlement agreement. Doc. 19-1 at 3. The settlement agreement was signed by the Plaintiff, Former Counsel, Defendant’s counsel, and Judge Sizemore. Docs. 19-1 at 3; 19 at 4. In September 2024, the Defendant filed a Notice of Settlement. Doc. 15. Shortly thereafter, the

Plaintiff informed Former Counsel by email that she would not honor the settlement agreement and intended to proceed to trial. Docs. 46 ¶ 11; 46-1 at 2. Former Counsel responded to Plaintiff’s email stating that the settlement agreement was enforceable and explaining the net amount Plaintiff could expect to receive after paying Former Counsel and satisfying any outstanding Medicare lien. Id. Former Counsel advised the Plaintiff that any motion by the Defendant to enforce the settlement agreement would likely be granted, and in that event Former Counsel would “likely become witnesses” and “be unable to represent [Plaintiff] in that proceeding.” Doc. 46-1 at 2. Former Counsel further cautioned the Plaintiff that she would be required to pay the

Defendant’s attorney fees in bringing any motion to enforce. Id. at 5. The Plaintiff responded that she understood Former Counsel was intending to “stack [his] deck” and she would not “tolerate [Former Counsel’s] overbearing intimidation.” Id. at 13. The Plaintiff remained adamant that she would “not sign the Release and Closure Document under any circumstances.” Id. Former Counsel informed the Defendant that the Plaintiff was refusing to settle her claim and that Former Counsel would be moving to withdraw from representation. Doc. 19 at 2. The Defendant moved to enforce the settlement agreement and to award attorney fees as a sanction. Doc. 19. Former Counsel successfully moved to withdraw on November 12, 2024 (Docs. 16; 22), and the Court granted the Defendant’s motion to enforce the settlement and denied the motion for attorney fees. Doc. 29. The Plaintiff and Former Counsel agree that the attorney-client relationship ended when the Court granted Former Counsel’s motion to withdraw. Docs. 42 at 2; 46 ¶ 11; 51 at 2. II. DISCUSSION

“An attorney-client relationship may be created expressly by written contract or inferred from the parties' conduct.” Mays v. Askin, 262 Ga. App. 417, 419, 585 S.E.2d 735, 737 (2003) (citing Huddleston v. State, 259 Ga. 45, 46, 376 S.E.2d 683 (1989)). When assessing whether an attorney-client relationship exists, several factors are considered, but the fundamental question is whether the would-be client reasonably believed they were represented by the attorney. Id. Here, the Plaintiff does not dispute the existence of an attorney-client relationship, and it is clear that in the absence of a written agreement, the Plaintiff reasonably believed she was represented by Former Counsel until the Court granted the motion to withdraw. See Doc. 51 at 1 (“Claimant

hires representation at Cooper Barton & Cooper LLP”); 2 (“By November, 2024, ATTORNEYS TERMINATED.”). Former Counsel now moves to enforce a lien for attorney fees and costs. Doc. 46 at 1. O.C.G.A. § 15-19-14(b) governs attorney's liens and states: Upon actions, judgments, and decrees for money, attorneys at law shall have a lien superior to all liens except tax liens; and no person shall be at liberty to satisfy such an action, judgment, or decree until the lien or claim of the attorney for his fees is fully satisfied. Attorneys at law shall have the same right and power over the actions, judgments, and decrees to enforce their liens as their clients had or may have for the amount due thereon to them. “This special, or charging, lien is the equitable right of an attorney to recover his fees and costs due him for his services, and may be satisfied out of the judgment obtained by his professional services.” Howe & Assocs., P.C. v. Daniels, 274 Ga. App. 312, 314, 618 S.E.2d 42 (2005) (citation omitted). “While the statute safeguards an attorney's right to a fee which has been earned, it does not control how the amount of the fee is

determined.” Greer, Klosik & Daugherty v. Yetman, 269 Ga. 271, 274, 496 S.E.2d 693 (1998). “The validity and enforceability of an attorney's lien, and the amount of fees to award the attorney enforcing the lien, are matters for the trial court to decide.” McDonald & Cody v. State, 364 Ga. App. 457, 461, 875 S.E.2d 430 (2022) (citing Tolson v. Sistrunk, 332 Ga. App. 324, 325, 772 S.E.2d 416 (2015)). “An attorney's lien under O.C.G.A. § 15-19-14(b) is based on ‘the fruits of the labor and skill of the attorney’ exerted on behalf of the client[.]” Tolson, 332 Ga. App. at 332 (citation omitted). “Where there is a contingent fee arrangement between a client and his attorney and the client prevents the contingency from happening, the attorney is

entitled to reasonable attorney's fees for his services that have been rendered on behalf of the client.” Sosebee v. McCrimmon, 228 Ga. App. 705, 707, 492 S.E.2d 584 (1997) (internal quotations and citation omitted). “This principle also applies when the client, by his or her conduct, gives the attorney reasonable cause to withdraw.” Id. “Thus, although prevented from recovering under the contract, the attorney still has a remedy in quantum meruit.” See Sutherland v. Hammers, 375 Ga. App. 439, 443, 916 S.E.2d 493 (2025) (citing Ellerin & Assocs. v. Brawley, 263 Ga. App. 860, 861-62, 589 S.E.2d. 626 (2003)). Here, Former Counsel cannot recover under any written contract both because there is insufficient evidence to determine the existence of a written contingency fee agreement1 and because the Plaintiff gave Former Counsel reasonable cause to withdraw, as discussed below.

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