ASSOULINE & BERLOWE, P.A.
v.
801 HIALEAH DRIVE, LLC

Fla. 3d DCA | 2025-02-12
No. 3D2024-0901
2025 FL 1158 Florida District Court of Appeal, Third District (2025)

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Holding

An attorney's charging lien may issue only when there is a client-attorney relationship and the attorney has actually recovered proceeds for the client; the lien cannot issue if no proceeds have been recovered.


Headnotes

[1] An attorney's charging lien attaches only to funds actually recovered by the client through a positive judgment or settlement; no lien may be imposed where the client has…

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Key Quotes

“An attorney's lien, or charging lien on funds recovered for a client through the attorney's services may issue only if there is a client-attorney relationship and the attorney has, in fact, recovered proceeds for his client. The lien may not issue if no proceeds have been recovered.”

From Pasin v. Kroo, cited as controlling authority on charging lien requirements.

Facts & Procedural History

Assouline & Berlowe, P.A. sought to impose a charging lien on funds in a case where the firm represented 801 Hialeah Drive, LLC. The appellant was the…

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Opinion of the Court

PER CURIAM.

Affirmed. See Pasin v. Kroo, 412 So. 2d 43, 44 (Fla. 3d DCA 1982) (“An attorney's lien, or charging lien on funds recovered for a client through the attorney’s services may issue only if there is a client-attorney relationship and the attorney has, in fact, recovered proceeds for his client. The lien may not issue if no proceeds have been recovered. [Appellant] was the losing party so there was no recovery of funds.” (internal citations omitted)); Litman v. Fine, Jacobson, Schwartz, Nash, Block & England, P.A., 517 So. 2d 88, 91-92 (Fla. 3d DCA 1987) (“It is not enough, however, to support the imposition of a charging lien that an attorney has provided his services; the services must, in addition, produce a positive judgment or settlement for the client, since the lien will attach only to the tangible fruits of the services.”).


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