Massachusetts Court Upheld Attorney Fees for Pro Se Counsel
Self-represented attorneys may now recover legal fees in G.L. c. 93A consumer claims under a new appellate ruling.
Updated on Sept. 23, 2026 in Financial Planning
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An appellate court vacated a lower court judgment that had denied attorney fees to a self-represented lawyer in a negligence case against Amazon.com, Inc. The ruling establishes that pro se attorneys in Massachusetts are eligible to collect legal fees under G.L. c. 93A.
Why it matters
The decision clarifies the application of the 2008 Robbins v. Krock precedent for self-represented counsel, ensuring that legal fee structures are consistently applied in consumer protection litigation. This remand requires the trial court to assess whether a defendant's settlement offer was reasonable before denying requested fees.
The court's decision, documented in a 7-page opinion filed under docket number 2025-P-732 and reference 81-114-26, clarifies the scope of fee recovery for self-represented attorneys. The amount of potential fees remains subject to further proceedings upon remand.
The players
Amazon.com, Inc.
A major global retailer and provider of cloud services that pays significant legal fees to defend against consumer claims.
Massachusetts Appeals Court
The state judiciary body that provides binding guidance on the interpretation of Massachusetts law and consumer protection statutes.
The details
The appellate court reviewed whether a trial judge correctly denied attorney fees, ultimately concluding that the judge failed to provide necessary written findings to justify the denial. By applying the established Robbins v. Krock precedent, the court affirmed that acting as one's own counsel does not disqualify an attorney from recovering statutory fees under Chapter 93A. The case will now return to the lower court to determine if the specific settlement offer provided in the suit against Amazon.com, Inc. justifies those fees.
Timeline
2008: Robbins v. Krock precedent was established.
September 18, 2026: The appellate court issued the order and memorandum.
Money Landscape
This ruling fits into the broader landscape of Massachusetts consumer protection litigation by clarifying how legal costs are awarded. It aligns with historical efforts to ensure that G.L. c. 93A remains a functional tool for individuals seeking recovery for negligence and other harms.
If you are an attorney representing yourself in a G.L. c. 93A case, this decision provides a clear path to seek recovery of your legal fees. Consult with a qualified legal professional to understand how this ruling impacts your specific litigation strategy and potential recovery.
The takeaway
The court has affirmed that self-represented attorneys are entitled to seek legal fees under G.L. c. 93A, provided their claims have merit. If you are involved in litigation, monitor the outcome of the remand proceedings to see how courts evaluate the reasonableness of settlement offers.
Further reading
For more information on legal costs and consumer litigation, visit Financial Planning.
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