A recent decision from the Delaware Court of Chancery clarifies the scope of a charging lien that attorneys may impose on the money available as a result of a lawsuit in which the client incurred unpaid legal fees. AutoLotto, Inc. v. J. Streicher Financial, LLC, C.A. No. 2022-0661-MTZ (Del. Ch. March 2, 2023).

Previous blog posts on these pages have discussed a decision by the Delaware Supreme Court in the Katten case, and in the Chancery decision in the Zutrau case that have addressed other nuances of the same issue. 

Most lawyers expect payment for their services pursuant to a fee agreement. Therefore, this decision, which clarifies the scope of the charging lien that an attorney may enforce to collect unpaid fees, and the limitations on what fees incurred by the client can be be subject to a lien imposed on what particular funds, is important when a lawyer or a law firm tries to collect unpaid legal fees incurred in connection with multiple lawsuits or multiple transactions that were handled for the same client.