Halks v. Kindley

District Court, S.D. California·Decided July 10, 2025·No. 3:25-cv-00560·Unknown

Opinion

Case No.: 25-cv-560-DMS-AHG NICHOLAS HALKS,

Plaintiff, ORDER GRANTING IN PART AND v. DENYING IN PART DEFENDANTS’ MOTION TO DISMISS

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

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 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 enforcing his alleged referral fee agreement with Defendants and has sufficiently alleged breach of contract, fraudulent misrepresentation, negligent misrepresentation, and estoppel claims. Defendants’ Motion is granted in part and denied in part. I. BACKGROUND3 In November 2019, Dylan Hernandez, a Florida resident and freshman at San Diego State University, tragically passed away after attending a fraternity pledge party. (Complaint, ECF No. 1 ¶ 8). Dylan’s family, also Florida residents, contacted Plaintiff, an attorney licensed in Massachusetts, for advice about potential claims against Dylan’s fraternity and the California State University System. (Id. ¶¶ 9–10). Plaintiff agreed to find legal counsel in the San Diego Area to represent the Hernandez family and Dylan’s Estate (collectively the “Hernandez family”) in all their claims arising from Dylan’s death. (Id. ¶ 12). Plaintiff reached out to at least five law firms located in San Diego and all expressed interest in representing the Hernandez family. (Id. ¶ 13). One of those law firms was Defendant The Kindley Law Firm. (Id. ¶ 12). During a telephone call on November 11, 2019, Plaintiff spoke with George Kindley regarding the potential referral for representation. (Id. ¶ 16). Kindley suggested to Plaintiff that his firm and Defendant Hamparyan Injury Lawyers take on the case due to their combined experience in handling personal injury and wrongful death cases on contingency in California. (Id. ¶ 17). Kindley represented that if the Hernandez family retained the firms, the Kindley and Hamparyan firms would pay Plaintiff a referral fee of one-third the total legal fees recovered from any litigation related to Dylan’s death. (Id. ¶ 18). The referral agreement was memorialized in subsequent emails between Defendants and Plaintiff. Kindley first wrote on November 11, 2019, “[a]s discussed, when cases are referred to us by another lawyer we do agree to pay referral fees.” (Ex. 1, ECF No. 1-2, at 5–6). Kindley followed

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

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