Golba

INTRODUCTION

A fundamental principle of California law, enshrined in the State Bar Act (Bus. & Prof. Code, § 6000 et seq.), is that no person may “practice law in California” unless that person is an active member of the State Bar. (Bus. & Prof. Code, § 6125 (section 6125).) As a corollary principle, no person may recover compensation for practicing law “in California” unless that person was a member of the State Bar or admitted pro hac vice at the time the services were performed, or the legal services fall within an exception. (Birbrower, Montalbano, Condon & Frank v. Superior Court (1998) 17 Cal.4th 119, 127, 136-137 [ 70 Cal.Rptr.2d 304 , 949 P.2d 1 ] (Birbrower).)

In this case, those principles lead us to conclude the trial court did not err by denying recovery of attorney fees for work performed by out-of-state counsel who represented the named plaintiff in a class action in California but who had not been admitted pro hac vice. We affirm the trial court’s order awarding $11,000 in attorney fees and costs out of the $210,000 sought as part of a class action settlement. We also affirm the trial court’s decision to reduce the amount of the plaintiff incentive…