Although Retainer Agreement Had A Limited Scope of Engagement, The Record Showed Client Made Promises To Ratify The Expanded Engagement And Pay Justifying A Judgment Based On Contract Breach, Unjust Enrichment, and Quantum Meruit Theories.
If you are the client and make written promises to pay for expanded scope of services, you are likely to be held to them, as Baker & McKenzie LLP v. Yehuda, Case No. B341253 (2d Dist., Div. 1 July 24, 2026) (unpublished) shows. There, the upfront written retainer agreement was limited to a scope of service performed in a Florida action on behalf of the ex-client. However, in various emails, ex-client promised to pay for expanded services provided outside of the retention agreement’s original scope. Both the trial and appellate court considered this ratification, with the 2/1 DCA affirming a lower court judgment in law firm’s favor based on breach of contract, unjust enrichment, and quantum meruit theories.