GA Code § 15-19-14 (2021)
2021 Georgia Code|Title 15 - Courts|Chapter 19 - Attorneys|Article 1 - General Provisions|§ 15-19-14. Liens for Services Rendered; Priority; Modes of Enforcement; Other Rights

  Attorneys at law shall have a lien on all papers and money of their clients in their possession for services rendered to them. They may retain the papers until the claims are satisfied and may apply the money to the satisfaction of the claims.   Upon actions, judgments, and decrees for money, attorneys at law shall have a lien superior to all liens except tax liens; and no person shall be at liberty to satisfy such an action, judgment, or decree until the lien or claim of the attorney for his fees is fully satisfied. Attorneys at law shall have the same right and power over the actions, judgments, and decrees to enforce their liens as their clients had or may have for the amount due thereon to them.   Upon all actions for the recovery of real or personal property and upon all judgments or decrees for the recovery of the same, attorneys at law shall have a lien for their fees on the property recovered superior to all liens except liens for taxes, which may be enforced by mortgage and foreclosure by the attorneys at law or their lawful representatives as liens on personal property and real estate are enforced. The property recovered shall remain subject to the liens unless transferred to bona fide purchasers without notice.   If an attorney at law files his assertion claiming a lien on property recovered in an action instituted by him, within 30 days after a recovery of the same, his lien shall bind all persons.   The same liens and modes of enforcement thereof which are allowed to attorneys at law who are employed to bring an action for any property, upon the property recovered, shall be equally allowed to attorneys at law employed and serving in defense against such actions in case the defense is successful.   This Code section shall not affect the rights of attorneys under Code Section 15-19-13 and decisions of the Supreme Court and Court of Appeals thereon.    (Ga. L. 1873, p. 42, § 16; Code 1873, § 1989; Ga. L. 1880-81, p. 63, § 3; Code 1882, § 1989; Civil Code 1895, § 2814; Civil Code 1910, § 3364; Code 1933, § 9-613.)   Cross references.   - Validity and enforcement of obligations to pay attorney's fees upon notes or other evidences of indebtedness, § 13-1-11.    Liens generally, § 44-14-320 et seq.   Law reviews.   - For article, "The Rights of Attorneys and Their Clients in Fee Disputes," see 16 Ga. St. B.J. 150 (1980). For article, "Trust Account Rules for Georgia Lawyers," see 24 Ga. St. B.J. 22 (1987). For annual survey of commercial law, see 43 Mercer L. Rev. 119 (1991). For article, "Setting the Fee When the Client Discharges a Contingent Fee Attorney," see 41 Emory L.J. 367 (1992). For annual survey article discussing legal ethics, see 51 Mercer L. Rev. 353 (1999). For annual survey article discussing trial practice and procedure, see 51 Mercer L. Rev. 487 (1999). For annual survey of legal ethics decisions, see 57 Mercer L. Rev. 273 (2005); 58 Mercer L. Rev. 239 (2006). For annual survey on legal ethics, see 64 Mercer L. Rev. 189 (2012). For annual survey on trial practice and procedure, see 67 Mercer L. Rev. 257 (2015).   JUDICIAL DECISIONS   ANALYSIS    General Consideration   Time When Lien Attaches   Extinguishment of Lien   Recovery by Attorney   Practice and Procedure    RESEARCH REFERENCES   Am. Jur. 2d.   - 7 Am. Jur. 2d, Attorneys at Law, § 310 et seq.   Reasonableness of Contingent Fee in Personal Injury Actions, 30 POF2d 197.   C.J.S.   - 7A C.J.S., Attorney and Client, §§ 207, 221, 230 et seq., 357 et seq.   ALR.    - Lien of attorney on public fund or property, 2 A.L.R. 274; 24 A.L.R. 933.    Agreement for contingent fee as assignment of interest in judgment, 2 A.L.R. 454; 19 A.L.R. 399.    Attorney's lien on property purchased by client on sale under a judgment procured by attorney, 2 A.L.R. 483.    Attorney's lien on papers or securities that come into his possession otherwise than in his professional capacity, 2 A.L.R. 1488.    Substitution by court of security for attorneys' lien, 33 A.L.R. 1296.    Attorneys' lien as subject to set-off against judgment, 34 A.L.R. 323; 51 A.L.R. 1268.    Attorney's lien on decedent's estate, 50 A.L.R. 657.    Right of attorney to have case continued to protect his compensation, 67 A.L.R. 442.    Validity of statutory provision for attorneys' fees, 90 A.L.R. 530.    Attorney's lien on property recovered for his client, 93 A.L.R. 667.    Affirmative duty of defendant to protect lien of plaintiff's attorney, 94 A.L.R. 695.    Right of attorney rendering service to personal representative or testamentary trustee to equitable substitution or subrogation to the latter's right against the estate in respect of such services, 100 A.L.R. 72.    Allowance of attorney's fee against property or fund increased or protected by attorney's services, 107 A.L.R. 749.    Means of enforcing or making effective attorney's retaining lien, 111 A.L.R. 487.    Payment into court or to clerk of court as affecting rights, liability, and procedure in respect of lien of judgment creditor's attorney, 117 A.L.R. 983.    Statute relating to attorney's lien as affecting common-law or equitable lien, 120 A.L.R. 1243.    Attorneys' fees or other expenses incident to proceeding for judicial determination of restoration of sanity or capacity of one previously adjudged to be insane or incompetent as a charge against his estate, 121 A.L.R. 1501.    Constitutionality of statute which by express terms or construction declares that attorneys' liens shall not be affected by settlement or compromise between the parties, 122 A.L.R. 974.    Attorney's contract for contingent fee as amounting to an equitable assignment of interest in cause of action, or proceeds of settlement thereof, 124 A.L.R. 1508.    Priority of lien of sales or consumers' tax, 136 A.L.R. 1015.    Terms of attorney's contingent-fee contract as creating an equitable lien in his favor, 143 A.L.R. 204.    Merits of client's cause of action or counterclaim as affecting attorney's lien or claim for his compensation against adverse party, in case of compromise without attorney's consent, 146 A.L.R. 67.    Right of attorney to set off claim for unrelated services against client's claim for money collected, 173 A.L.R. 429.    Attorney's right to lien or equitable assignment in respect of client's share or interest in decedent's estate, or in trust, 175 A.L.R. 1132.   Rights and remedies of client as regards papers and documents on which attorney has retaining lien, 3 A.L.R.2d 148.   Conflict of laws as to attorneys' liens, 59 A.L.R.2d 564.   What constitutes acceptance or ratification of, or acquiescence in, services rendered by attorney so as to raise implied promise to pay reasonable value thereof, 78 A.L.R.2d 318.   Sufficiency of notice to opposing party (or of serving or filing thereof) required to establish attorney's lien upon client's claim or cause of action, 85 A.L.R.2d 859.   Attorney's charging lien upon continuing payments to which client becomes entitled as result of litigation, 99 A.L.R.2d 451.   Right of attorney for holder of property insurance to fee out of insurer's share of recovery from tortfeasor, 2 A.L.R.3d 1441.   Funds in hands of his attorney as subject of attachment or garnishment by client's creditor, 35 A.L.R.3d 1094.   Amount of attorneys' compensation in absence of contract or statute fixing amount, 57 A.L.R.3d 475.   Amount of attorneys' compensation in matters involving guardianship and trusts, 57 A.L.R.3d 550.   Amount of attorneys' fees in tort actions, 57 A.L.R.3d 584; 86 A.L.R. Fed. 866.   Attorneys at law: fee collection practices as ground for disciplinary action, 91 A.L.R.3d 583.   Attorney's failure to report promptly receipt of money or property belonging to client as ground for disciplinary action, 91 A.L.R.3d 975.   Limitation to quantum meruit recovery, where attorney employed under contingent fee contract is discharged without cause, 92 A.L.R.3d 690.   Attorney's charging lien as including services rendered or disbursements made in other than instant action or proceeding, 23 A.L.R.4th 336.   Attorney's retaining lien as affected by action to collect legal fees, 45 A.L.R.4th 198.   Attorney's assertion of retaining lien as violation of ethical code or rules governing professional conduct, 69 A.L.R.4th 974.   What items of client's property or funds are not subject to lien, 70 A.L.R.4th 827.   Priority between attorney's charging lien against judgment and opposing party's right of setoff against same judgment, 27 A.L.R.5th 764.   Alimony or child-support awards as subject to attorneys' liens, 49 A.L.R.5th 595.   Circumstances under which attorney retains right to compensation notwithstanding voluntary withdrawal from case, 53 A.L.R.5th 287.