continuing representation doctrine (Louisiana) · Go Syfert
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continuing representation doctrine in Louisiana

5 Louisiana opinions name it 2 courts 1990–2013 0 in the last five years

The cases below were cited by Louisiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (1)

CaseFollowedCited
Schoenrock v. Tappegreen
sd · 1988 · cited in 2 Louisiana opinions naming this issue, 1990–1998
2 sentences

1998For that reason, we, in Succession of Smith , borrowed language from a decision by the South Dakota Supreme Court, Schoenrock v. Tappe, 419 N.W.2d 197, 201 (S.D. 1988), and adopted the views expressed therein that the continuous representation rule should apply only "where the professional's involvement after the alleged malpractice is for the performance of the same or related services and is not merely continuity of a general professional relationship." Succession of Smith, 565 So.2d at 995 .

1990However, other states have ruled on the issue and we elect to borrow the statement made by the supreme court of South Dakota in Schoenrock v. Tappe, 419 N.W.2d 197 (S.D.1988). [T]he continuous representation doctrine applies only to malpractice actions when `there is a clear indicia of an ongoing, continuous, developing, and dependent relationship between the client and the attorney....' This relationship is one `which is not sporadic but developing and involves a continuity of the professional services from which the alleged malpractice stems.' Furthermore, the application of this doctrine sh

12

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Louisiana. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Wong v. Hoffman green
lactapp · 2007
1 sentence

2013Wong, 05-1483 at p. 8, 973 So.2d at 7 .

12013–2013
Reeder v. North green
la · 1997
1 sentence

2007In Reeder v. North, 97-0239, pp. 6-7 (La.10/21/97), 701 So.2d 1291, 1295-96 , the Louisiana Supreme Court held that the peremptive periods set forth in La.

12007–2007
Lima v. Schmidt green
la · 1992
1 sentence

2007Like the continuing representation doctrine in legal malpractice cases, the continuing treatment doctrine in medical malpractice cases applies "where the professional's involvement after the alleged malpractice is for the performance of the same or related services and is not merely continuity of a general professional relationship." Id. at 16, 892 So.2d at 1271 , quoting Lima, 595 So.2d at 630 .

12007–2007
Braud v. New England Ins. Co. green
la · 1991
1 sentence

2007Further, in Braud, 576 So.2d 466 , in which this court first adopted the continuing representation doctrine for legal malpractice cases, the court noted that a finding that prescription ran during the existence of an on-going attorney-client relationship "would create a situation where an attorney could effectively defeat a malpractice claim against himself by utilizing the appeals process to continue the attorney-client relationship until such time as prescription has run." Again, that reasoning applies to this case.

12007–2007
Carter v. Haygood green
la · 2005
1 sentence

2007Like the continuing representation doctrine in legal malpractice cases, the continuing treatment doctrine in medical malpractice cases applies "where the professional's involvement after the alleged malpractice is for the performance of the same or related services and is not merely continuity of a general professional relationship." Id. at 16, 892 So.2d at 1271 , quoting Lima, 595 So.2d at 630 .

12007–2007

Statutes the citing opinions construe

LA § La. Rev. Stat. § 9:5628 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MA 25 (1987–2026) LA 5 (1990–2013) CT 4 (2003–2019) WA 4 (2011–2014) ME 4 (1999–2019) FL 3 (2008–2017) RI 3 (2004–2016) VA 3 (2017–2025) AR 2 (1998–2006) WY 2 (1996–1997) CA 2 (2006–2010) SD 2 (1988–2020) NY 2 (1994–2004) TN 2 (2007–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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