Court Lacked Jurisdiction Over Out-of-State Attorney for Fee Dispute

A New York appellate court ruled that the state lacked jurisdiction over a Massachusetts attorney to resolve a dispute over fees.  Case: Gottlieb v. Merrigan, No. 526945, 03/07/2019, published. Facts and procedural history: In 2007, Mark Swanson hired attorney Scott Gottlieb to represent him in a personal injury action from a car accident in Massachusetts. Swanson discharged Gottlieb and hired attorney James Merrigan. Merrigan settled Swanson’s personal injury action for $800,000. Gottlieb sued Merrigan in a New York court, demanding payment of $66,788.39 for the work he h...