The New York Court of Appeals today upheld an agreement to pay a referring law firm "one-third of the entire fee recovered" in a medical malpractice case. The "entire fee" included the amount attributable to the efforts of a third law firm. That the referring lawyer may not have contributed one-third of the productive work didn't matter, the court held. Nor could the firm that agreed to pay one-third of the fee complain about non-compliance with ethical rules, which in any event the referring firm satisfied. Samuel v. Druckman & Sinel, LLP, No. 39 (N.Y. Mar. 31, 2009).