What is the standard of care for a plaintiff to receive attorney fees from an employer's attorney in a wrongful dismissal action?

The same standard is applied where settlement is achieved solely through the efforts of the employer's attorney. ( 3860, subd. (d).) "After fixing the amount of the attorney fee award, the trial court must apportion the fee award between the parties benefitted by the recovery; in doing so, the trial court must decide to what extent the passive beneficiary should contribute to the litigation expenses and fees which created the recovery fund. [Citation.]" (Walsh v. Woods, supra, 187 Cal.App.3d 1273, 1277, 232 Cal.Rptr. 629.)