“Clients are not merchandise. Lawyers are not tradesmen.”1
The New York Court of Appeals finally had an opportunity to analyze and provide guidance to attorneys and law firms with regard to the application of the “unfinished business” doctrine to law firms that dissolve or file for bankruptcy. Upon the same two certified questions from the U.S. Court of Appeals for the Second Circuit, in a unanimous decision in Geron v. Seyfarth Shaw (In re Thelen) dated July 1, 2014, New York’s highest court firmly rejected the “unfinished business” doctrine holding that “pending hourly fee matters are not partnership ‘property’ or ‘unfinished business’ within the meaning of New York’s Partnership Law. A law firm does not own a client or an engagement, and is only entitled to be paid for services actually rendered.”2
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