Shaffer v. Superior Court

Firm not required to disclose hourly rate paid to contract attorney


Shaffer supports the proposition that firms/attorneys who employ contract attorneys may bill the client the fair market value of that work (regardless of the rate paid by the employing firm/attorney to the contract attorney). The rate the contract attorney charges impacts the employing firm/attorney's profit margin which is not relevant to whether the fee charged to the client is unconscionable in violation of Rules Prof. Conduct, rule 4-200.

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Reference Info:Decision | State, 9th Circuit, California | United States

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