Halks v. Kindley

CourtDistrict Court, S.D. California
DecidedJuly 10, 2025
Docket3:25-cv-00560
StatusUnknown

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

Bluebook
Halks v. Kindley, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 Case No.: 25-cv-560-DMS-AHG NICHOLAS HALKS,

12 Plaintiff, ORDER GRANTING IN PART AND 13 v. DENYING IN PART DEFENDANTS’ MOTION TO DISMISS 14 THE KINDLEY LAW FIRM, APC,

GEORGE KINDLEY, and 15 HAMPARYAN INJURY LAWYERS, 16 Defendants. 17 18 This matter arises out of a dispute between a Massachusetts lawyer and California 19 lawyers over a referral fee. Plaintiff, a Massachusetts lawyer who is not a member of the 20 California Bar and has not practiced in California, referred a significant wrongful death 21 case in San Diego to Defendants,1 who are California lawyers, in which the lawyers agreed 22 Plaintiff would receive “one-third of the total legal fees recovered” by Defendants for 23 referring the case. Plaintiff—in compliance with Massachusetts Rules of Professional 24 Conduct—obtained written client consent to refer the case to Defendants and receive a 25 referral fee. Nevertheless, after the case partially settled and Defendants recovered their 26 attorneys’ fees from the settlement, Defendants declined to share any of the attorneys’ fees 27 28 1 with Plaintiff because the lawyers failed to obtain written client consent to the “terms of 2 division” of the fees (i.e., the one-third share to Plaintiff), as required by California Rules 3 of Professional Conduct, Rule 1.5.1. Through this action, Plaintiff seeks one-third of the 4 total attorneys’ fees recovered by Defendants and brings claims against Defendants for 5 breach of contract, fraudulent misrepresentation, negligent misrepresentation, and 6 estoppel, among other claims. 7 Defendants contend Plaintiff’s attempt to recover the referral fee “undermine[s] the 8 consumer protection purpose of California Rule of Professional Conduct 1.5.1” and cannot 9 proceed as a matter of law. Plaintiff argues Defendants cannot use a non-compliant fee- 10 sharing agreement that Defendants themselves drafted as a “shield … to enjoy a windfall” 11 of attorneys’ fees that are supposed to be shared by counsel and that the clients—except 12 for the division of fees—approved. While California courts have yet to decide whether a 13 lawyer practicing in California can avoid a technically non-compliant fee-sharing 14 agreement under Rule 1.5.1 with an out-of-state lawyer not practicing in the state, other 15 courts have addressed the issue under analogous state rules2 and determined for public 16 policy reasons that such non-compliant agreements are enforceable: “To hold otherwise 17 would encourage non-compliance with the [in-state] Rule[s] [of Professional Conduct] and 18 create incentives for malfeasance among [in-state] lawyers at the expense of out-of-state 19 lawyers.” Potter v. Peirce, 688 A.2d 894, 897 (Del. 1997). This Court agrees. 20 Pending before the Court is Defendants’ motion to dismiss Plaintiff’s Complaint 21 pursuant to Federal Rule of Civil Procedure 12(b)(6). (Motion, ECF No. 7). Plaintiff filed 22 a response in opposition, (Opp’n, ECF No. 10), and Defendants filed a reply. (Reply, ECF 23 No. 11). For the reasons set forth below, the Court finds Plaintiff is not precluded from 24

25 26 2 “All states other than California have adopted rules of professional conduct based upon” the American Bar Association (“ABA”) Model Rules of Professional Conduct, Legal Ethics and Professional 27 Responsibility: Rules, DRAKE L., https://libguides.law.drake.edu/c.php?g=896184 (last visited July 10, 2025), although California’s rules are influenced by the Model Rules. Id. Many states use identical or 28 1 enforcing his alleged referral fee agreement with Defendants and has sufficiently alleged 2 breach of contract, fraudulent misrepresentation, negligent misrepresentation, and estoppel 3 claims. Defendants’ Motion is granted in part and denied in part. 4 I. BACKGROUND3 5 In November 2019, Dylan Hernandez, a Florida resident and freshman at San Diego 6 State University, tragically passed away after attending a fraternity pledge party. 7 (Complaint, ECF No. 1 ¶ 8). Dylan’s family, also Florida residents, contacted Plaintiff, an 8 attorney licensed in Massachusetts, for advice about potential claims against Dylan’s 9 fraternity and the California State University System. (Id. ¶¶ 9–10). Plaintiff agreed to 10 find legal counsel in the San Diego Area to represent the Hernandez family and Dylan’s 11 Estate (collectively the “Hernandez family”) in all their claims arising from Dylan’s death. 12 (Id. ¶ 12). 13 Plaintiff reached out to at least five law firms located in San Diego and all expressed 14 interest in representing the Hernandez family. (Id. ¶ 13). One of those law firms was 15 Defendant The Kindley Law Firm. (Id. ¶ 12). During a telephone call on November 11, 16 2019, Plaintiff spoke with George Kindley regarding the potential referral for 17 representation. (Id. ¶ 16). Kindley suggested to Plaintiff that his firm and Defendant 18 Hamparyan Injury Lawyers take on the case due to their combined experience in handling 19 personal injury and wrongful death cases on contingency in California. (Id. ¶ 17). 20 Kindley represented that if the Hernandez family retained the firms, the Kindley and 21 Hamparyan firms would pay Plaintiff a referral fee of one-third the total legal fees 22 recovered from any litigation related to Dylan’s death. (Id. ¶ 18). The referral agreement 23 was memorialized in subsequent emails between Defendants and Plaintiff. Kindley first 24 wrote on November 11, 2019, “[a]s discussed, when cases are referred to us by another 25 lawyer we do agree to pay referral fees.” (Ex. 1, ECF No. 1-2, at 5–6). Kindley followed 26

27 3 All facts stated in this Order are derived from Plaintiff’s Complaint, which are assumed to be true for 28 1 up with another email to Plaintiff and confirmed that the Hamparyan firm acknowledged 2 “the 1/3 fee.” (Ex. 2, ECF No. 1-3, at 3). Then, on November 22, 2019, Kindley sent 3 Plaintiff another email: “This confirms our agreement to pay you a referral fee of one third 4 of the attorney’s fees we are able to collect.” (Complaint ¶¶ 28, 30); (Ex. 3, ECF No. 1-4, 5 at 3). 6 Plaintiff ultimately recommended to the Hernandez family that they retain 7 Defendants. (Complaint ¶¶ 25–27). On November 25, 2019, Defendant Kindley Law Firm 8 emailed Plaintiff an unsigned copy of Defendants’ Contingency Fee Agreement with the 9 Hernandez family. The Contingency Fee Agreement provided that Defendants would 10 receive 40% of any recovery by the Hernandez family, (id. ¶ 44), that Defendants would 11 jointly represent the family in the San Diego litigation and split the fees, and that a referral 12 fee would be paid to Plaintiff out of Defendants’ attorneys’ fees award. The Contingency 13 Fee Agreement provided, in relevant part: 14 Clients acknowledge that attorneys’ fees will be split between the two law firms [Defendants Kindley Law Firm and Hamparyan Injury Lawyers]. This 15 fee splitting shall not increase the total amount of attorneys’ fees paid by 16 Clients. Clients have authorized [Defendants] to pay a referral fee to attorney Nicholas Halks as a courtesy and for his efforts assisting Clients. 17

18 (Ex. 4, ECF No. 1-5, at 2); (Complaint ¶ 33). Plaintiff discussed with the Hernandez family 19 the referral fee agreement he entered with Defendants, and informed Kindley of this fact 20 by email. (Ex. 5, ECF No. 1-6, at 2). Kindley then represented to Plaintiff that the 21 Hernandez family signed the Contingency Fee Agreement. (Complaint ¶ 35).

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Bluebook (online)
Halks v. Kindley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/halks-v-kindley-casd-2025.