The law of unfinished business, as applied to cases billed on an hourly basis, has been the subject of much commentary and case law.

In 2014, the New York Court of Appeals definitively ended the debate in New York when it held that dissolved firms did not have any right to the post-dissolution hourly billings for matters left unfinished when a firm dissolved. In re Thelen LLP, 995 N.Y.S.2d 534, 536-37 (2014). In so doing the court held in part: “We hold 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.” Id.

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