Although the California Supreme Court backed away from complete fee forfeiture, compliance with State Bar regulations concerning fee-splitting arrangements should be scrupulously adhered to. As the Supreme Court observed, in the typical contingency fee case, a quantum meruit recovery for the reasonable value of services rendered will be substantially less than the contingency fee splitting arrangement. Moreover, a quantum meruit recovery will require a law suit and litigation further reducing the potential recovery.

A final caveat is also in order: there can be no guarantee that other jurisdictions will allow quantum meruit recovery in the absence of written client authorization.