Douglas v. Perez
- Thomas Hixson
- 3:24-cv-03983
- U.S. District Court · Northern District of California
- 4
In Douglas v. Perez, Judge Hixson granted James Douglas’s motion to replace Stanley Goff with Nicolette Glazer as his counsel.
James Douglas’s legal representation was changed from Stanley Goff to Nicolette Glazer. Goff was removed as counsel of record and was ordered to release Douglas’s client materials and property; the court did not decide whether Goff is entitled to fees.
What happened
In Douglas v. Perez, James Douglas asked to replace his attorney, Stanley Goff, with Nicolette Glazer. Douglas said he was dissatisfied with Goff’s representation and no longer wanted Goff as his lawyer.
The court granted the motion. It directed the clerk to remove Goff as Douglas’s attorney of record, add Glazer, and required Goff to promptly release Douglas’s client materials and property.
Judge Hixson said California law gives a client the absolute right to discharge an attorney. The court made no ruling on whether Goff is entitled to fees, although it noted that he may seek payment for the reasonable value of his services.
The detailed version
- Douglas v. Perez · No. 3:24-cv-03983
- Thomas Hixson
- Mar. 31, 2025
Background
James Douglas, who is incarcerated, filed this 42 U.S.C. § 1983 case represented by Stanley Goff. Goff remained Douglas’s attorney of record. The parties previously informed the court that Goff would be unable to participate while undergoing rehabilitation for injuries. Nicolette Glazer later filed a motion to substitute as Douglas’s attorney, but the court denied that motion without prejudice because it did not comply with the court’s local procedural rule.
Douglas then filed the motion at issue. He stated that he was dissatisfied with Goff’s representation and signed a confirmation saying that he no longer wanted Goff to represent him because of alleged failures to communicate, respond to inquiries, and represent him with care. He also stated that he had retained Glazer. Goff said he had not received direct notice from Douglas that Glazer had been retained, although he had seen Douglas’s signed notice in an exhibit.
Legal Standard and Analysis
The court explained that replacing one attorney with another requires a court order under the Northern District of California’s local rules. It applied California professional-conduct standards, under which a client’s power to discharge an attorney, with or without cause, is absolute.
Because Douglas stated that he no longer wanted Goff as his attorney, the court concluded that his decision had to be given effect. The court did not rule on whether Goff is entitled to fees. It stated that, if Goff is entitled to fees, he may pursue recovery from Douglas for the reasonable value of services provided before the discharge.
Ruling
The court GRANTED Douglas’s motion to substitute counsel. It directed the clerk to remove Stanley Goff as Douglas’s counsel of record and substitute Nicolette Glazer. The court also ordered Goff to promptly release all client materials and property to Douglas.
The order vacated the scheduled April 24, 2025 hearing because the court found the matter suitable for decision without oral argument.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.