Law360, New York (March 25, 2016, 11:42 AM EDT) -- California has historically been one of the stricter jurisdictions when it comes to the forfeiture and disgorgement of attorneys' fees for conflicts of interest violations. If the latest decision to address the issue is any indication, that status is unlikely to change anytime soon. In Sheppard Mullin Richter & Hampton LLP v. J-M Manufacturing Co. Inc., 198 Cal.Rptr.3d 253 (Cal. App.4th 2016), a California court of appeals relied on long-standing precedent to overturn a trial court decision and find that the law firm of Sheppard Mullin must disgorge and forfeit millions of dollars in legal fees based on the firm's failure to disclose an actual conflict of interest....