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Illinois Supreme Court Applies Adverse Judgment Rule, Rejects Statute of Limitations Defense in Legal Malpractice Claim

The Illinois Supreme Court held that hiring new counsel and incurring legal fees did not, by itself, trigger the two-year statute of limitations to file a legal malpractice action (735 ILCS 5/13-214.3(b)) because plaintiffs...more

Illinois Appellate Court Reverses Summary Judgment For Defendants On Plaintiffs' Malpractice Claims Stemming From $2.8 Million...

An Illinois appellate court held that the trial court improperly granted summary judgment in defendants' favor based on the six-year statute of repose governing legal malpractice actions and the five-year statute of repose...more

Eleventh Circuit Finds Attorneys Owed No Duty to be Clairvoyant on Unsettled Law

On October 7, 2021, the United States Court of Appeals for the Eleventh Circuit affirmed summary judgment in favor of defendant law firm. The court held the attorneys owed no duty to advise the client to cease an activity...more

Marijuana Company's Legal Malpractice Claim Goes Up in Smoke

An Arizona appellate court held that summary judgment was appropriate in a legal malpractice action brought by a medical marijuana company for failure to timely pursue a petition for judicial review where plaintiffs could not...more

Illinois Appellate Court Affirms Summary Judgment For Defendant in Legal Malpractice Action Based on No Duty and No Causation

An Illinois appellate court held that: (1) plaintiffs' motion to amend their complaint was properly denied where the six-year statute of repose (735 ILCS 5/13-214.3(c)) barred the proposed amended claims based (in part) on...more

Property Owners Allege Their Own Lawyers Helped Initiate Ruinous Downzoning, Case Dismissed Due to Statute of Limitations

An Illinois appellate court held that plaintiffs' legal malpractice claim, which accrued as soon as his business partners learned of their wrongfully caused injuries, was barred by the two-year statute of limitations. ...more

Illinois Appellate Court Holds Legal Malpractice Claim is Barred by Statute of Repose, Rejects Plaintiff's Tolling Argument

Brief Summary An Illinois appellate court held that the statute of repose barred a plaintiff's legal malpractice claim, and that the plaintiff's claim of fraudulent concealment to toll the statute failed. The court also...more

Georgia Malpractice Judgment Reversed Because Trial Court Improperly Allowed Jury to View Complaint With Dismissed Claims

A Georgia appellate court held that plaintiff's nearly $6 million damage award was improper because the trial court permitted the jury to view a copy of the complaint which included allegations and claims that had been...more

Florida Court Rules That Retainer Agreement Arbitration Provision is Enforceable and Severable From Agreement's Unenforceable Fee...

Lemos v. Sessa, No. 3D20-1362, 2021 Fla. App. LEXIS 4527 (Dist. Ct. App. Mar. 31, 2021) - Brief Summary A Florida appellate court held that plaintiff was required to arbitrate her claims against the attorney and her law...more

Seventh Circuit Affirms Dismissal of Legal Malpractice Action For Lack of Proximate Cause

UFT Commercial Finance, LLC v. Fisher, No. 20-2012 (7th Cir., March 23, 2021) - Brief Summary - The Seventh Circuit affirmed the dismissal of a legal malpractice action filed by UFT Commercial Finance, LLC against the...more

Federal District Court in Nevada Tosses China-Based Auto Dealer's Legal Malpractice Suit Against Law Firm Based on Lack of...

China Auto Logistics, Inc. v. DLA Piper, LLP, Case No. 2:20-cv-00646, USDC, Dist. Nevada, March 3, 2021 - A Nevada federal judge tossed a legal malpractice suit against a global firm, finding that the firm was not subject...more

Texas Federal District Court Kicks Steel Importer's $6M Malpractice Suit Due to Lack of Personal Jurisdiction

Allied Fitting LP v. Steptoe & Johnson LLP et al., No. 4:20-cv-03447 (S.D. Tex. Jan. 21, 2021) - Brief Summary - A Texas federal district court dismissed a legal malpractice action brought by an international steel...more

Plaintiff's Legal Malpractice Action—First Filed Too Early, Then Refiled Too Late—Results in Dismissal With Prejudice

Flintlock Constr. Servs, LLC v. Rubin, Fiorella & Friedman, LLP, 2020 NY Slip Op 06711 (App. Div.). Brief Summary - After plaintiff's initial legal malpractice action was dismissed as premature because the underlying...more

Wisconsin Appellate Court Refines Actual Innocence Rule in Claims Against Criminal Defense Counsel

A Wisconsin appellate court held that to pursue a legal malpractice claim against a criminal defense attorney, the former client only has to show actual innocence to some, not all, of the charges for which he or she was...more

Landscaping Co. Gets Clipped: Malpractice Action Time-Barred and Fraudulent Concealment Claim Rejected

An Illinois appellate court held that plaintiffs' malpractice action was time-barred because plaintiffs knew, or reasonably should have known, of their wrongfully caused damages more than two years before they filed. The...more

Florida Appellate Court Reduces Legal Malpractice Verdict From $5M to $250K Because Plaintiff Failed to Prove Underlying Judgment...

After a Florida law firm and one of its attorneys (defendants) were hit with a $5 million jury verdict in a case arising out of an underlying medical malpractice action, they—along with the firm's insurer—appealed. Because...more

Plaintiff Cannot Maintain Legal Malpractice Action Absent Proof of Fraudulent Inducement to Settle

Jibreel Townsend v. Spear, Greenfield and Richman, P.C., Mark Greenfield, Rand Spear, Esq. Superior Court of Pennsylvania, No. 2950 EDA 2019 (8/13/20) - Brief Summary - A Pennsylvania court affirmed summary judgment in a...more

Expert Testimony Sufficient to Defeat Summary Judgment Motion in Settle and Sue Case

Webb v. Ellis, 2020 Tex. App. LEXIS 3527 (2020) - Brief Summary - A Texas appellate court reversed the trial court's grant of summary judgment in defendants' favor on plaintiffs' legal malpractice claim—which was based on...more

Defendants Entitled to Summary Judgment on Lack of Proximate Causation Because Plaintiffs' Expert Opinions were Conclusory

Summary judgment entered in the attorney defendant's favor on grounds of lack of causation in a legal malpractice case was upheld by a Texas court of appeal where plaintiffs' expert's opinions regarding proximate cause were...more

Plaintiff's Successor Counsel Not Liable for Contribution Where Underlying Case Was "Irretrievably Lost" Before He Was Retained

McNellis-Wallace v. Hoffman, et. al., Superior Court of New Jersey, Appellate Division, Docket No. A-1488-19T1 - Brief Summary - A New Jersey appellate court held that a defendant in a malpractice case could not maintain a...more

Wisconsin Supreme Court Finds No Exceptions to Actual Innocence Rule

Skindzelewski v. Smith, 2020 WI 57 (June 18, 2020) - Brief Summary - A Wisconsin plaintiff's legal malpractice action against his former criminal defense attorney was shot down by the Wisconsin Supreme Court because he...more

Illinois Law Firm Recovers No Attorney's Fees After Trial Court Concluded The Firm Breached Its Fiduciary Duties

Scot Vandenberg v. RQM, LLC, 2020 IL App (1st) 190544 - Brief Summary - An Illinois appellate court affirmed the adjudication of a firm's attorney's liens down to zero, where the discharged firm failed to provide any...more

Continuous Representation Doctrine Does Not Toll Statute of Limitations Where Attorney Withdraws in Appellate Court

Huyen Nguyen v. Karen Ellen Ford, No. H046809, 2020 Cal. App. LEXIS 411, at *1 (Ct. App. Apr. 24, 2020). Brief Summary - The court held that plaintiff's claims for legal malpractice and breach of fiduciary duty against her...more

Ninth Circuit Affirms Summary Judgment for Defendants Based on Plaintiffs' Failure to Present Expert Testimony

Plaintiffs appealed the district court's order granting summary judgment in favor of defendants on plaintiffs' legal malpractice and breach of fiduciary duty claims. Plaintiffs alleged that defendants were negligent in...more

Alabama Civil Appeals Court Holds Error in Judgment Rule Requires Expert Testimony to Establish Standard of Care

Schaeffer v. Thompson, Ala. Cov. App. LEXIS 25 (2020) - Brief Summary - The Alabama Civil Court of Appeals reversed a trial court's grant of summary judgment in favor of defendant on plaintiffs' legal malpractice claims,...more

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