March 13, 2026
Court of Appeal of the State of California, Third Appellate District
The Rule of Jacobs v. Papez is that an attorney may bring a single declaratory relief action against both the clients and a competing attorney lien claimant to enforce an attorney lien claim on settlement or judgment proceeds, under circumstances where the attorney obtained a recovery for clients and seeks to resolve competing lien claims without having to wait for other attorneys to first establish their liens in separate actions.
January 28, 2026
Court of Appeal of the State of California, Second Appellate District, Division One
The Rule of Maynard Matthews et al. v. Patrick Ryan is that a section 998 settlement offer conditioned on consent by the defendant's insurance carrier is valid, under circumstances where the defendant is defended by an insurer whose consent is necessarily required for any settlement regardless of whether such consent is expressly stated in the offer.
2/17/26
Court of Appeal, Fourth Appellate District, Division One
The Rule of Hatlevig v. General Motors LLC is that a motion for attorney fees must be served within 180 days of when a case is voluntarily dismissed pursuant to court order, even when no formal dismissal order is filed until a later date, under circumstances where the case was deemed dismissed by operation of court rules after settlement.