Leventhal v. Black & LoBello

Appellant hired Law Firm to represent him in a divorce action. After a post-decree dispute, Appellant paid Law Firm for the firm's work through entry of the final decree but did not pay Law Firm the fees it charged to litigate the post-decree dispute. The district court granted Law Firm's post-decree motion to adjudicate and enforce a charging lien for unpaid attorney fees pursuant to Nev. Rev. Stat. 18.015, entering personal judgment against Appellant. Under section 18.015(3), a charging lien only attaches to a decree and to money recovered on account of the action from the time of service of the notices. The Supreme Court reversed, holding that because Law Firm did not serve the statutory notices required to perfect its lien until the case was over and the decree had already become final, and because no prospect of post-perfection recovery appeared, the lien should not have been adjudicated under section 18.015. View " Leventhal v. Black & LoBello" on Justia Law