Joanna Davis, et al. v. Michael A. Petito

Attorneys’ fees: financial status and needs: pro bono representation

CA No. 30, September Term 2011. Reported. Opinion by Battaglia, J. Filed Feb. 27, 2012. RecordFax #12-0227-20, 19 pages. Appeal from Wicomico County. Reversed and remanded.

The trial court’s consideration that one party was represented on a pro bono basis, in order to award attorneys’ fees to the other party, who had retained counsel, was erroneous under FL Section 12-103.

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