George v. Bimbra (2025) & Good Cause in Awarding Attorney's Fees

Maryland and District of Columbia attorney’s fees are something which parties in family law cases often quarrel over. This isn’t difficult to understand: in some situations, such as very long and complex custody disputes, attorney’s fees can rapidly become quite high. As we’ve discussed in previous articles, custody disputes can often be dragged out over a long period of time, and parties are frequently not shy about fighting over even the smallest aspects of a case. When the bill comes, it’s not shocking that parties attempt to argue that “fee shifting” provisions should be applied. This is precisely what happened in the recent case of George v. Bimbra (2025).

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While this fact scenario is certainly not typical, this case is useful for numerous reasons. One reason is because the court was compelled to conduct a thorough analysis on “good cause” considerations when determining attorney fee shifting. Whether a court in Maryland decides to shift attorney’s fees to the other (losing) party can be an extraordinarily involved determination. In this case, the trial court made its decision using a good cause analysis, but this analysis was then questioned on appeal. Let’s look at the details of this recent case.

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Facts of the Case

The mother and father in this case engaged in a prolonged battle regarding physical and legal custody. The parents were never married, but the battle over custody issues began in 2021. Prior to December, 2021, the mother and father shared both physical and legal custody, but then in December of 2021 the mother filed a petition to modify the custody arrangement. Eventually, in 2024, the mother attained primary physical custody and sole legal custody of the child, even though these things weren’t sought in her original petition.  

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In between December, 2021, and June, 2024, numerous court actions were filed by both parties, as both parties frequently changed their goals and strategies. Ultimately, the mother sought primary physical custody and sole legal custody and was successful at trial. The father moved out of Maryland to Nevada prior to the end of the trial, and so ultimately he only had FaceTime visitation with the child, along with in person visitation at the mother’s discretion. The mother also sought attorney’s fees.

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Both parties spent an exorbitant amount on attorney’s fees during the custody dispute. When the trial court considered the mother’s attorney’s fees request, the court used a “good cause” analysis and took into account the financial condition of both parties. The father had a high net worth, although his yearly income fluctuated widely. The mother was a physician who worked for the government and had a high income, but her finances were substantially negatively impacted by the dispute. Although the father was in a better overall financial situation, the court only shifted half of the mother’s attorney’s fees to the father, and so the mother then appealed this determination.

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Ruling & Discussion

The appellate division reviewed Maryland’s legal concept of “good cause” and then discussed how that concept might be used in analyses of attorney fee shifting. One of the critical points noted by the appellate court was the fact that courts must always consider whether the parties had “substantial justification” when either bringing or defending their position.  

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If a party lacks substantial justification, the court cannot take that party’s financial condition into account when determining whether attorney’s fees should be shifted. The reason is because a party who lacks substantial justification loses the ability to invoke any sort of good cause consideration automatically. Any sort of good cause analysis which might weigh the relative financial conditions of the parties requires a showing a substantial justification from both parties. In other words, when the court determined that the father lacked substantial justification, the court abused its discretion when it took into account the financial situation of both parties. The mother ended up receiving nearly all of her attorney’s fees from the father, minus those expended directly on the trial.

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Contact the Murphy Law Firm for Additional Information

Readers who want to know about the concept of good cause in family law, the awarding of attorney’s fees under certain circumstances, the divorce process in general in Maryland, or another family law topic, contact one of the family law attorneys at the Murphy Law Firm today by calling 240-219-5243.

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