Civil Rights/Costs/Interest: Attorneys, Not Clients, Are Entitled to Postjudgment Interest On Fee Award And Likely Entitled To Routine Costs Recovery

 

. . . Unless Retainer Agreement Requires Otherwise.

     Hernandez v. Siegel, Case No. A139653 (1^st Dist., Div. 5 Sept. 30, 2014) (published) decided, unless a client-attorney retainer agreement dictates otherwise, post-judgment interest on a fee award and routine costs generally are interests vested in the attorney, rather than the client. The appellate court placed great reliance on Flannery v. Prentice, 26 Cal.4^th 572 (2001) in reaching its result on the fee post-judgment interest issue.