In Ortiz v. Barrett, 222 Va. 118, 278 S.E.2d 833 (1981), lead counsel Edward Barrett, who was not licensed to practice law in Virginia, filed a personal injury suit in Virginia on behalf of his clients, signing the name of Ronald Barrett, an unrelated Virginia lawyer. Ronald had not authorized Edward to sign the pleading, and when Ronald later became aware that suit had been filed under his signature, he agreed to serve as "co-counsel without active participation" for a fixed fee. 222 Va. at 124, 278 S.E.2d 833. In holding that Edward's subsequent mishandling of the case did not impose liability on Ronald, the Virginia court reasoned that Edward and Ronald were not joint venturers, based upon the fact that "Ronald was employed by Edward to perform limited services for a fixed fee regardless of results." Id. at 131, 278 S.E.2d at 840.