Proof of the Value of Lawyers Professional Services In Georgia
In Georgia, an attorney cannot recover for professional services without proof of the value of those services.
A court may consider a contingent fee agreement and the amount it would have generated as evidence of usual and customary fees in determining both the reasonableness and the amount of an award of attorney fees.
When a party seeks fees based on a contingent fee agreement, the party must show that the contingency fee percentage was a usual or customary fee for such case and that the contingency fee was a valid indicator of the value of the professional services rendered.
In addition, the party seeking fees must also introduce evidence of hours, rates, or some other indication of the value of the professional services actually rendered. Home Depot U.S.A. v. Tvrdeich, 268 Ga. App. 579, 584 (2) (602 SE2d 297) (2004) See also Patton v. Turnage, 260 Ga. App. 744, 748 (2) (580 SE2d 604) (2003).