The applicant client moved under Rule 54.09(2) to oppose confirmation of a Solicitors Act assessment of criminal defence accounts rendered under an unwritten alleged block-fee retainer.
The court held that review of an assessment officer's decision is limited to questions of principle, palpable and overriding error, or an amount so grossly improper as to warrant intervention.
Applying the quantum meruit framework and the Cohen factors, the court found no reviewable error in the assessment officer's treatment of research time, travel time, complexity, responsibility, skill, result achieved, or client expectations.
The report and certificate of assessment were confirmed, leaving the client liable for the remaining assessed balance.
