legal malpractice claim (Kentucky) · Go Syfert
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legal malpractice claim in Kentucky

12 Kentucky opinions name it 2 courts 2007–2024 4 in the last five years

The cases below were cited by Kentucky 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 (14)

CaseFollowedCited
Marrs v. Kellygreen
ky · 2003 · cited in 2 Kentucky opinions naming this issue, 2012–2018
2 sentences

2018Marrs v. Kelly, 95 S.W.3d 856, 860 (Ky. 2003) (citing Stephens v. Denison, 64 S.W.3d 297, 298-99 (Ky. App. 2001)).

2012Marts v. Kelly, 95 S.W.3d 856, 860 (Ky.2003).

22
Klancke v. Smithgreen
coloctapp · 1991 · cited in 2 Kentucky opinions naming this issue, 2010–2010
2 sentences

2010Under our previous precedents, although a legal malpractice claim may accrue *107 only to the attorney's client, "an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney's acts are fraudulent or tortious and result in injury to that third person." Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) ("An attorney is charged with a duty t

2010Under our previous precedents, although a legal malpractice claim may ac crue only to the attorney’s client, “an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney’s acts are fraudulent or tortious and result in injury to that third person.” Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled, on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) (“An attorney is charged with a duty to a

22
Pedigo v. Breengreen
ky · 2005 · cited in 2 Kentucky opinions naming this issue, 2017–2023
2 sentences

2023We agree that the facts of Saalwaechter make it inapplicable here. 146 169 S.W.3d at 833 (emphasis added) (citing Faris v. Stone, 103 S.W.3d 1 (Ky. 2003) (holding that a CR 60.02 motion will not toll the statute of limitations in KRS 413.245)). 33 Court concludes that the problems with the Broadbent line of cases are too blatant to ignore.

2017Pedigo, 169 S.W.3d at 833 .

12
Rose v. Davisgreen
kyctapphigh · 1941 · cited in 2 Kentucky opinions naming this issue, 2010–2010
2 sentences

2010Under our previous precedents, although a legal malpractice claim may accrue *107 only to the attorney's client, "an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney's acts are fraudulent or tortious and result in injury to that third person." Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) ("An attorney is charged with a duty t

2010Under our previous precedents, although a legal malpractice claim may accrue *107 only to the attorney's client, "an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney's acts are fraudulent or tortious and result in injury to that third person." Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) ("An attorney is charged with a duty t

12
Lawrence v. Bingham, Greenebaum, Doll, L.L.P.green
moctapp · 2018 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024Id. at 141 (emphasis added).

11
Doe v. Golden & Walters, PLLCgreen
kyctapp · 2005 · cited in 1 Kentucky opinions naming this issue, 2024–2024
2 sentences

2024Ultimately, we reasoned that, “[b]ecause an unripe claim is not justiciable, the circuit court has no subject matter jurisdiction over it.” Id. at 270 (footnote omitted).

2024We held that the legal malpractice claim was unripe “because it was filed prematurely before any of the causes of action asserted ever accrued.” Id. at 263 .

11
Davis v. Scottgreen
ky · 2010 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024Davis v. Scott, 320 S.W.3d 87, 90 (Ky. 2010).

11
Michels v. Sklavosgreen
ky · 1994 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024“Where . . . the cause of action is for ‘litigation’ negligence, meaning the attorney’s negligence -28- in the preparation and presentation of a litigated claim resulting in the failure of an otherwise valid claim, whether the attorney’s negligence has caused injury necessarily must await the final outcome of the underlying case.” Michels v. Sklavos, 869 S.W.2d 728, 730 (Ky. 1994).

11
Stephens v. Denisongreen
kyctapp · 2001 · cited in 1 Kentucky opinions naming this issue, 2018–2018
1 sentence

2018Marrs v. Kelly, 95 S.W.3d 856, 860 (Ky. 2003) (citing Stephens v. Denison, 64 S.W.3d 297, 298-99 (Ky. App. 2001)).

11
Hill v. Willmottgreen
kyctapp · 1978 · cited in 1 Kentucky opinions naming this issue, 2010–2010
2 sentences

2010And certainly, "[s]uch liability may be found to exist where the attorney is responsible `for damage caused by his negligence to a person intended to be benefited by his performance irrespective of any lack of privity[.]'" Coombs, 219 S.W.3d at 209 ( quoting Hill v. Willmott, 561 S.W.2d 331, 334 (Ky.App.1978)).

2010And certainly, “[sjuch liability may be found to exist where the attorney is responsible ‘for damage caused by his negligence to a person intended to be benefited by his performance irrespective of any lack of privity[.]’ ” Coombs, 219 S.W.3d at 209 (quoting Hill v. Willmott, 561 S.W.2d 331, 334 (Ky.App.1978)).

11
Baker v. Coombsgreen
kyctapp · 2007 · cited in 1 Kentucky opinions naming this issue, 2010–2010
2 sentences

2010Under our previous precedents, although a legal malpractice claim may accrue *107 only to the attorney's client, "an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney's acts are fraudulent or tortious and result in injury to that third person." Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) ("An attorney is charged with a duty t

2010Under our previous precedents, although a legal malpractice claim may ac crue only to the attorney’s client, “an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney’s acts are fraudulent or tortious and result in injury to that third person.” Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled, on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) (“An attorney is charged with a duty to a

11
Weiss v. Leatherberrygreen
fladistctapp · 2003 · cited in 1 Kentucky opinions naming this issue, 2010–2010
1 sentence

2010See Weiss v. Leatherberry, 863 So.2d 368, 373 (Fla.Dist.Ct.App.2003) (remanding matter to trial court because “invalidity of the agreement [to assign] has no effect on the underlying cause of action for legal malpractice”).

11
American Employers' Insurance v. Medical Protective Co.green
michctapp · 1988 · cited in 1 Kentucky opinions naming this issue, 2007–2007
2 sentences

2007Co. v. Weber & Rose, P.S.C., 997 S.W.2d 12, 14 (Ky.App.1998), quoting American Employers’ Insurance Co. v. Medical Protective Co., 165 Mich.App. 657 , 419 N.W.2d 447, 448-49 (1987).

2007Co. v. Weber & Rose, P.S.C., 997 S.W.2d 12, 14 (Ky.App.1998), quoting American Employers’ Insurance Co. v. Medical Protective Co., 165 Mich.App. 657 , 419 N.W.2d 447, 448-49 (1987).

11
American Continental Insurance Co. v. Weber & Rose, P.S.C.green
kyctapp · 1998 · cited in 1 Kentucky opinions naming this issue, 2007–2007
1 sentence

2007Co. v. Weber & Rose, P.S.C., 997 S.W.2d 12, 14 (Ky.App.1998), quoting American Employers’ Insurance Co. v. Medical Protective Co., 165 Mich.App. 657 , 419 N.W.2d 447, 448-49 (1987).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
Faris v. Stone green
ky · 2003
2 sentences

2023We agree that the facts of Saalwaechter make it inapplicable here. 146 169 S.W.3d at 833 (emphasis added) (citing Faris v. Stone, 103 S.W.3d 1 (Ky. 2003) (holding that a CR 60.02 motion will not toll the statute of limitations in KRS 413.245)). 33 Court concludes that the problems with the Broadbent line of cases are too blatant to ignore.

2007In this way this case is more like Faris v. Stone, 103 S.W.3d 1 (Ky.2003), where the Court declined to allow a separate proceeding (a CR 60.02 collateral attack) to toll the statute of limitations for a legal malpractice claim related to litigation that had become final several years before.

22007–2023
Penrod v. Penrod green
kyctapphigh · 1972
2 sentences

2010Under our previous precedents, although a legal malpractice claim may accrue *107 only to the attorney's client, "an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney's acts are fraudulent or tortious and result in injury to that third person." Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) ("An attorney is charged with a duty t

2010Under our previous precedents, although a legal malpractice claim may ac crue only to the attorney’s client, “an attorney still may be liable for damages to a third party because of events arising out of his representation of a client if the attorney’s acts are fraudulent or tortious and result in injury to that third person.” Coombs, 219 S.W.3d at 208-09 ; Rose v. Davis, 288 Ky. 674 , 157 S.W.2d 284, 284-85 (1941), overruled, on other grounds by Penrod v. Penrod, 489 S.W.2d 524 (Ky.1972); see also Klancke v. Smith, 829 P.2d 464, 466-67 (Colo.App.1991) (“An attorney is charged with a duty to a

22010–2010
Hibbard v. Taylor green
ky · 1992
1 sentence

2024In Hibbard v. Taylor, 837 S.W.2d 500 (Ky. 1992), the Kentucky Supreme Court ruled that the date of occurrence for a client’s legal malpractice claim against his attorney for litigation negligence was the date the underlying case’s appellate decision became final, which put the client on notice that the adverse judgment was unalterable, and the damages were proximately caused by alleged malpractice of his attorney, rather than by error of trial court.

12024–2024
Coffey Ex Rel. Collins v. Jefferson County Board of Education green
kyctapp · 1988
1 sentence

2010Coffey v. Jefferson County Bd. of Educ., 756 S.W.2d 155 (Ky.App.1988).

12010–2010

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 413.245 (4)

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

TX 301 (1985–2026) NY 248 (1990–2026) IL 199 (1980–2026) OH 158 (1989–2026) NJ 88 (1980–2026) CA 76 (1969–2026) PA 68 (1987–2026) MI 65 (1987–2026) LA 53 (1985–2025) FL 53 (1983–2025) IN 44 (1981–2020) WA 43 (1992–2026) MN 40 (1984–2017) GA 39 (1990–2025) TN 38 (1996–2025) MA 37 (1988–2026) MO 28 (1981–2025) SC 28 (1996–2025) UT 27 (1996–2026) MS 27 (1982–2024) CT 25 (1996–2024) AZ 24 (1984–2026) IA 24 (1989–2026) CO 21 (1995–2025) ID 21 (1995–2026) KS 21 (1990–2026) AL 20 (1982–2025) NM 20 (1997–2025) NV 20 (1996–2025) OR 19 (1988–2025) MT 18 (1995–2026) VA 16 (1988–2026) ME 16 (1996–2020) WI 15 (1991–2025) DC 15 (1990–2024) NC 14 (2003–2022) VT 14 (1992–2025) SD 14 (1983–2023) RI 13 (1997–2017) WY 13 (2002–2026) KY 12 (2007–2024) MD 12 (1995–2024) NE 11 (1995–2026) AK 10 (1992–2025) ND 10 (1990–2024) WV 10 (2003–2021) DE 9 (1996–2025) HI 6 (2001–2026) NH 5 (2010–2019) OK 4 (2000–2025) AR 4 (2003–2025) VI 3 (1991–2014)

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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