Sutherland v. Sutherland, C.A. No 2399-VCN (February 26, 2016)

An “attorney charging lien” allows an attorney to recover compensation for his services from a fund recovered with his assistance.  This decision limits the application of such liens to recoveries where the attorney has not already been paid for the work that led to that recovery.  In other words, if you have already been paid for the work that generated a fund, you cannot lien that fund for other work that did not generate it, even if it occurred in the same litigation.