## Facts

- Quinn, a New York construction company, was involved in an arbitration with Hownor arising from a construction contract dispute involving claims and counterclaims for damages.
- Quinn was initially represented in the arbitration by a New York law firm, and multiple hearings occurred before Hownor completed its direct case.
- Quinn and its New York counsel concluded Quinn’s position in the arbitration was weak and sought counsel with construction-litigation experience to assist.
- Quinn authorized its New York counsel to engage a New Jersey professional association law firm, Williamson P.A., to participate in the arbitration in association with Quinn’s New York counsel.
- The agreed staffing arrangement provided that Donald J. Williamson (admitted in New York) would supervise strategy and representation, while Michael F. Rehill (not admitted in New York) would perform substantial day-to-day work.
- Williamson P.A. performed extensive services in preparing and presenting Quinn’s case in the arbitration and billed Quinn for fees and disbursements.
- Quinn refused to pay, asserting that Williamson P.A. and Rehill were not authorized to practice in New York in connection with the arbitration and therefore could not recover fees.

## Issues

1. Whether a law firm retained through New York counsel may recover fees for New York arbitration services when day-to-day work was performed by an attorney not admitted in New York, but supervised by a New York-admitted attorney.
2. Whether, even if there were a technical irregularity relating to authorization to practice, the client remains liable for the reasonable value of services received.

## Decision

- The court entered judgment for Williamson P.A. for unpaid fees and disbursements.
- The court rejected Quinn’s defense that fee recovery was barred by alleged unauthorized practice of law.
- The court found the engagement was authorized by the client, conducted in association with Quinn’s New York counsel, and supervised by a New York-admitted attorney.
- The court found the services and charges proven at trial were reasonable under the circumstances and compensable.

## Legal Principles

- Fee forfeiture is not automatic merely because some work on a New York matter is performed by an attorney not admitted in New York when a New York-admitted attorney supervises and remains responsible for the representation.
- A client’s informed authorization and acceptance of services weighs against denying compensation as a matter of professional-regulation policy.
- Courts may award compensation for the reasonable value of legal services where the client received and retained substantial benefits and where denial of all fees would operate as an unwarranted windfall.

## Conclusion

The court held that Quinn was obligated to pay for legal services and disbursements rendered in the arbitration because the representation was authorized and supervised by a New York-admitted attorney, and the client knowingly accepted the benefits of the work.


Williamson v. John D. Quinn Constr. Corp., 537 F. Supp. 613 (S.D.N.Y. 1982)