March 13, 2026
Court of Appeal of the State of California, Third Appellate District
The Rule of Jacobs v. Papez is that an attorney may bring a single declaratory relief action against both the clients and a competing attorney lien claimant to enforce an attorney lien claim on settlement or judgment proceeds, under circumstances where the attorney obtained a recovery for clients and seeks to resolve competing lien claims without having to wait for other attorneys to first establish their liens in separate actions.