A court can find it would be "inequitable and improper" to require a law firm to continue to represent a client. In October 2011, the plaintiff, Marcos Barraza, allegedly was injured in a multi motor-vehicle accident on Interstate 95. Edguardo Ramirez was one of the defendants, and Ramirez’s insurer, National Continental Insurance Co., hired the law firm of Halloran & Sage to represent him. National Continental filed a request for a declaratory judgment in Massachusetts District Court concerning its duty to defend and to indemnify. It obtained a court judgment in August 2013 that indicated it lacked the duty to defend or to indemnify. In November 2013, the law firm of Halloran & Sage moved to withdraw its appearance in the Connecticut Superior Court action and indicated that continued representation would result in a financial hardship for the law firm and that professional considerations other than compensation prevented continued representation. Ramirez objected to the law firm’s motion to withdraw and argued that he lacks sufficient funds to hire substitute counsel. The court found that Halloran & Sage conferred with Ramirez, to discuss continued representation, and was unable to reach agreement. Ramirez has sufficient time, prior to trial in June 2014, to find another attorney. Requiring Halloran & Sage to continue to provide representation would cause a hardship to the law firm. The court granted the motion to withdraw. "[I]t would be inequitable and improper," wrote the court, "to require the Firm to continue to represent Mr. Ramirez."

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