Minott v. Google LLC

Background

The court had previously granted Minott’s former attorneys, the Washington Law Firm PLLC (WLF), a charging lien under New York Judiciary Law § 475. A charging lien gives an attorney an interest in a client’s cause of action or recovery for legal services. On July 29, 2025, the U.S. Court of Appeals for the Second Circuit affirmed that order. This court then ordered the case closed, finding that all issues had been resolved.

Minott’s counsel later asked the court to reopen the case so it could decide Minott’s motion to vacate the original charging-lien order. The motion asserted that the original order rested on jurisdictional grounds that had not been raised on appeal.

Arguments and Analysis

Minott argued that WLF’s lien was based on a pre-litigation retainer agreement. She contended that the agreement had been superseded by a later agreement, making the original agreement moot and leaving WLF without standing to assert claims based on it. She also argued that the original agreement covered only pre-litigation work and therefore did not give WLF an interest in a settlement arising from later litigation. Finally, she argued that the court should have calculated WLF’s fees under a subsequent co-counsel agreement involving Minott, WLF, and the Spiggle Law Firm.

The court rejected those arguments. It explained that it had not granted the lien under either retainer agreement. Instead, the lien arose because WLF had obtained an interest in Minott’s cause of action by commencing proceedings before the U.S. Equal Employment Opportunity Commission. The court also declined to treat the original agreement’s description of WLF’s work as a contractual bar to recovering fees because the agreement did not specifically impose that limitation.

The court further explained that it had calculated the lien under quantum meruit, meaning the reasonable value of the legal services, rather than under a retainer agreement. In determining a reasonable hourly rate, the court may consider a retainer agreement for guidance. The court said that was all it had done, including over WLF’s objection that the rate in the agreement was below its current rate.

Ruling

Judge Margaret M. Garnett held that Minott’s challenge was not jurisdictional. Instead, it challenged the court’s exercise of discretion, which the Second Circuit had already affirmed. The motion to vacate, Docket No. 46, was DENIED, and the case remains closed.