[textbook]Traversing the Ethical Minefield Problems, Law, and Professional Responsibility by Susan R. Martyn (z-lib.org)(1) (1)

Actual authority includes both express authority and implied authority to act in a
manner that will further the client’s objectives, so long as the lawyer has reasonably
consulted with the client and believes the client desires such action. 10 A lawyer also has
actual authority if the client ratifies the lawyer’s action after the fact. 11
In the absence of actual or implied authority, a client can be bound by a lawyer’s
apparent authority; that is, authority “traceable to the principal’s manifestations” that
causes another to reasonably believe the lawyer-agent had the requisite authority to act on
behalf of the client. 12 Lawyers who purport to have actual or apparent authority but in fact
have neither do not bind their clients, 13 or, if they do, could be held liable to clients or
third parties harmed as result. 14 Machado makes clear that professional discipline also can
result when lawyers fail to clarify and heed their clients’ intent.
Machado v. Statewide Grievance Committee
890 A.2d 622 (Conn. App. 2006)
GRUENDEL, J.
The plaintiff, Arthur D. Machado, an attorney, appeals from the judgment of the trial
court dismissing his appeal from the reprimand issued to him by the defendant, the
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