Court Grants Law Firms Summary Judgment on Account Claims
A Michigan court ruled for Bodman PLC and Lennon Law PLLC on unpaid-bill claims and dismissed the defendants' malpractice counterclaims as time-barred.
Updated on Nov. 3, 2026 in Professional Services
A Michigan court granted summary disposition to law firms Bodman PLC and Lennon Law PLLC on account-stated claims, awarding money judgments of $45,512.45 and $22,907.85 respectively. The court also dismissed the defendants' legal malpractice counterclaims against both firms under the two-year statute of limitations.
Why it matters
The ruling shows that a client who does not rebut an attorney's affidavit of account balances with counter-affidavits may lose on unpaid-fee claims at the summary stage. It also illustrates how the limitations period for malpractice counterclaims is measured from when the attorney stopped serving the client.
The court awarded money judgments sought of $45,512.45 to Bodman PLC and $22,907.85 to Lennon Law PLLC, based on affidavits showing account balances. The defendants' malpractice counterclaims were dismissed under a two-year limitations period, and the extraction does not indicate whether any appeal is pending.
The players
Bodman PLC
A Michigan law firm that was a plaintiff seeking a $45,512.45 money judgment for unpaid account balances.
Lennon Law PLLC
A Michigan law firm that was a plaintiff seeking a $22,907.85 money judgment and was also a target of the dismissed malpractice counterclaims.
The details
The plaintiffs moved for partial summary disposition under MCR 2.116(C)(8) and (C)(10), and the court found their prima facie showing of indebtedness unrebutted because defendants filed no counter-affidavits denying the accounts. The defendants' generalized complaint about 'serious concerns about the bills' did not identify a specific billing error or amount, and the underlying litigation remained on appeal until February 18, 2025, without either firm representing the defendants in that appeal.
Timeline
• February 18, 2025: The underlying litigation's appeal concluded, starting the limitations analysis.
• November 3, 2026: The Michigan court issued its ruling granting summary disposition.
Professional Services
The ruling applies Michigan's existing summary disposition framework under MCR 2.116 and the affidavit rule of MCL 600.2145 to unpaid legal-fee claims, following the procedure those rules set out for account-stated disputes. It shows how the same rules can dispose of a client's malpractice counterclaim on limitations grounds before the merits are reached.
Clients who receive attorney invoices they dispute should respond with specific counter-affidavits or documented objections within the litigation timeline, since unrebutted account balances can support a summary judgment. Clients considering a malpractice claim should note that the two-year limitations period can begin when the attorney stops serving them on the matter.
The takeaway
Written fee disputes are decided largely on the affidavit record, so a client who wants to contest an attorney's bill should put specific, documented objections on file early. Waiting too long can forfeit both the defense and any later malpractice claim.
Further reading
Explore more on Professional Services to see how legal and consulting firms handle billing and client-dispute matters in Michigan.
Source note: This article includes information reported by Michigan Lawyers Weekly.
