Friday, October 24, 2025
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Quinn Emanuel Fails in Bid for $1.7 Million From County
Court of Appeal Says Nothing Is Owed Based on Firm’s Representation of Then-Sheriff Villanueva
By a MetNews Staff Writer
The 1,200-lawyer international law firm of Quinn Emanuel Urquhart & Sullivan, founded in Los Angeles in 1986, has lost its bid in the Court of Appeal for a reversal of judgments against it in its effort to collect $1,740,001.70 from the county for services in representing then-Sheriff Alex Villanueva and the department he headed in litigation.
Villanueva hired Quinn Emanuel when the county brought suit to establish that he lacked authority, shortly after assuming office in 2018, to rehire a fired deputy, Caren Mandoyan, with $200,000 in backpay tossed in. Yesterday’s opinion deals only with the attorney-fee issue; the Court of Appeal in 2022 affirmed the determination by then-Los Angeles Superior Court Judge Mitchell L. Beckloff (now an arbitrator/mediator) that “the Sheriff’s action to rehire Mandoyan was unlawful.”
Although Villanueva signed a retainer agreement with Quinn Emanuel, granting it attorney fees ranging from $695 to $1,400 an hour, the county was not a party to that contract. A contract provided by the county called for a blended rate of $495 per hour but Quinn Emanuel declined to sign it, insisting that the contract between it and the sheriff was binding on his employer.
Letter to Sheriff
The law firm relied heavily on a Feb. 28, 2019 letter sent to Villanueva by the Office of County Counsel saying that the Board of Supervisors “has agreed to offer you conflict counsel on the question of whether under the Los Angeles County Charter you had the authority to settle the civil actions involving Mr. Mandoyan absent the approval of County Counsel and the Board of Supervisors.”
It adds:
“Accordingly, pursuant to California Government Code section 31000.6(a), the Board of Supervisors will provide you with independent legal counsel for [that] sole issue.”
That section says, in part:
“Upon request of the [sheriff or other listed officials], the board of supervisors shall contract with and employ legal counsel to assist the...sheriff...in any case where the county counsel...would have a conflict of interest in representing the...sheriff.”
The letter specifies:
“You may select which independent counsel to represent you in this matter. However, please note that the Board of Supervisors has discretion to pay such compensation as it deems just and proper for these services.”
Rubin’s Opinion
Los Angeles Superior Court Judge Holly Fujie on April 28, 2023, granted a motion by the county for summary judgment in its suit for declaratory relief, establishing that it had no liability to Quinn Emanuel, and judgment was entered on May 8, 2023. Retired Court of Appeal Presiding Justice Laurence Rubin, sitting on assignment authored the opinion upholding that judgment.
“Quinn relies on the February 28 letter from county counsel to the sheriff, but fails to come to grips with its express language,” Rubin said, declaring:
“We see nothing in the February 28 letter that may be construed to authorize the sheriff to contract with counsel on the terms of his representation.”
The jurist said that Quinn Emanuel’s arguments “all boil down to the conclusory argument that under the extraordinary circumstances,” it is reasonable to infer that the February 28 letter authorized the sheriff to retain and set attorney fees for independent counsel, and the court “fail[ed] to grant that reasonable inference in favor of Quinn Emanuel.” Rubin wrote:
“Neither the law nor the evidence supports that claim.”
Agency Theory
Quinn Emanuel noted in its opening brief on appeal that the county was arguing “that the Board and County Counsel have exclusive authority to contract for legal services, and the former Sheriff lacks any such authority.” It commented:
“Respondents’ argument, however, is misplaced. The relevant authority here is the Board’s authority, which was exercised through the former Sheriff as the Board’s agent.”
The law form contended:
“Because the February 28 letter expressly or impliedly authorized the Sheriff to retain Quinn Emanuel, and because the Sheriff acted pursuant to that authorization and within the scope of that authorization, Quinn Emanuel has adequately alleged that the Sheriff was authorized to act as an agent of the Board in retaining Quinn Emanuel to provide legal services for the Sheriff and the Sheriff’s department in the Mandoyan Matter.”
Rubin responded:
“Certainly the board may delegate its authority to an agent, and it did so; the board expressly delegated its authority ‘solely’ to county counsel.”
He pointed to a board policy that reads:
“County Counsel is solely authorized to contract for legal services provided to the County, its elected officials, agents, and employees.”
Cross Complaint
After Fujie announced that she was granting the county’s motion for summary judgment and before the judgment was signed, Quinn Emanuel moved for leave to file a cross complaint, and permission was denied. Rubin said:
“Quinn Emanuel deliberately delayed filing its motion until after it lost the case. By that time, it was far too late for a motion to be heard before entry of judgment in normal course.”
The law firm then filed a lawsuit seeking fees. Los Angeles Superior Court Judge Jon R. Takasugi sustained a demurrer without leave to amend and a judgment of dismissal was entered.
“Quinn’s subsequent lawsuit against the county defendants was properly dismissed on demurrer on either of two grounds: because it was a compulsory cross-complaint in the earlier declaratory relief action or because Quinn failed to allege compliance with the presentation requirements of the Government Claims Act,” Rubin said.
The case is County of Los Angeles v. Quinn Emanuel Urquhart & Sullivan, B331562.
Steven G. Madison, John P. D’Amato and Robert E. Allen of Quinn Emanuel Urquhart & Sullivan acted for their firm. James A. Bowman, Dimitri D. Portnoi, Kelsey A. Chandrasoma and Kyle M. Grossman of O’Melveny & Myers represented the county.
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