A Manhattan appellate court has ruled that a law firm acted properly when it voted to defer payments due partners leaving the firm, including its former managing partner.

W. Edward Bailey, the managing partner of New York intellectual property boutique Fish & Neave from 1994 to 2000, and management committee member Kevin J. Culligan, both left the firm in spring 2004 to join King & Spalding. Shortly before the two partners left, a majority of remaining partners voted to amend the partnership agreement to institute a cash accounting rather than accrual accounting system.