Chavarria v. State Farm Mut. Auto. Ins. Co
In Chavarria v. State Farm Mut. Auto. Ins. Co., 165 Ariz. 334, 337, 798 P.2d 1343, 1346 (App. 1990), an insurance bad faith case, the court found "that Chavarria neither paid nor had any agreement to pay attorney's fees either to her first attorney or to her third attorney.
According to the record and the briefs, her only agreement was to pay her second attorney a contingent fee of fifty percent of any recovery she ultimately made." Id. at 339-40, 798 P.2d at 1348-49.
Ultimately, the court restricted Chavarria's fee award because the record did not show that her third lawyer "told Chavarria that there was no longer a ceiling on the fees she might be liable for." Id. at 340, 798 P.2d at 1349.