In Hallock v. State of New York, 64 N.Y.2d 224 (1948), the Court of Appeals held that from the nature of the attorney-client relationship itself, an attorney derives authority to manage the conduct of litigation on behalf of a client, including authority to make certain procedural or tactical decisions. "But that authority is hardly unbounded....Without a grant of authority from the client, an attorney cannot compromise or settle a claim and settlements negotiated by attorneys without authority from their clients have not been binding." (Hallock, supra at 230.)