8 Indiana opinions name it 1 courts 2003–2018 0 in the last five years
The cases below were cited by Indiana 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.
| Case | Followed | Cited |
|---|---|---|
Biomet, Inc. v. Barnes & Thornburggreen2 sentences2018The Biomet court adopted the continuous representation doctrine as an exception to the discovery rule, stating, “In a situation where the attorney continues to represent the client in the same matter in which the alleged malpractice occurred, the date of accrual begins at the termination of an attorney’s representation of a client in the same matter in which the alleged malpractice occurred.” Biomet, 791 N.E.2d at 767 . [21] The Biomet court also specifically recognized that a client may terminate the attorney-client relationship without giving the attorney an opportunity to mitigate the damag 2018However, “the continuous representation doctrine does not apply to a client who retains new counsel on appeal.” Id. at Court of Appeals of Indiana | Memorandum Decision 41A01-1711-CC-2647 | May 24, 2018 Page 11 of 15 766 n.2. | 6 | 7 |
Bambi's Roofing, Inc. v. Moriartygreen2 sentences2017In Bambi’s Roofing Inc. v. Moriarty, 859 N.E.2d 347, 357 (Ind. Ct. App. 2006), we applied the continuous representation rule to the accounting profession, limiting the rule to the accountant’s representation in the same, specific matter. 2017In Bambi’s Roofing Inc. v. Moriarty, 859 N.E.2d 347, 357 (Ind. Ct. App. 2006), we expanded the continuous representation rule to the accounting profession, limiting its application to the accountant’s representation in the same, specific matter. | 2 | 2 |
Landmark Legacy, LP and Dennis W. Fahlsing v. Dennis Runkle, D.R. Financial Inc., and D.R. Financial Group, Inc.green2 sentences2017This court received a similar expansion request in our very recent case of Landmark Legacy, L.P. et al. v. Runkle, et al., 81 N.E.3d 1107 , 2017 WL 3429076 (Ind. Ct. App. Aug. 10, 2017), in which we declined to extend the continuous representation doctrine to a negligence claim against financial advisors. 2017This court received a similar expansion request in our very recent case of Landmark Legacy, L.P. et al. v. Runkle, et al., 81 N.E.3d 1107 , 2017 WL 3429076 (Ind. Ct. App. Aug. 10, 2017), in which we declined to extend the continuous representation doctrine to a negligence claim against financial advisors. | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Endervelt v. Slade
neutral
1 sentence2017“Certainly,, once the client discovers the attorney’s fraud, it is not reasonable to expect the client to continue to 'maintain confidence in the professional’s good faith and the client should be, as are all other victims of fraud, required to investigate and access the facts.” Endervelt v. Slade, 162 Misc.2d 975 , 618 N.Y.S.2d 520 , 525 (1994). | 1 | 2017–2017 |
Borgia v. City of New York
green
2 sentences2017New York pioneered the continuous representation doctrine in Borgia v. New York, 12 N.Y.2d 151 , 237 N.Y.S.2d 319 , 187 N.E.2d 777 (1962). 4 . 2017New York pioneered the continuous representation doctrine in Borgia v. New York, 12 N.Y.2d 151 , 237 N.Y.S.2d 319 , 187 N.E.2d 777 (1962). 4 . | 1 | 2017–2017 |
Virginia Tramill, Miah Gant, Marquel Cheaney and Jeremiah Tramill, the Mother and Children of Sara Tramill v. Anonymous Healthcare Provider
green
1 sentence2017Najam, J., and Brown, J., concur. 3 Although under the continuous representation doctrine, the statute of limitations commences at the end of an attorney’s representation of a client in the same matter in which the alleged malpractice occurred, Biomet, Inc. v. Barnes & Thorn burg, 791 N.E.2d 760, 765 (Ind. Ct. App. 2003), which made the date the statute of limitations began to run as July 9, 2012, Warren argues for the first time in his reply brief that he did not discover Epstein’s alleged malpractice until June 2014. “‘The law is well settled that grounds for error may only be framed in an a | 1 | 2017–2017 |
Burger King Corp. v. Rudzewicz
green
2 sentences2011Also, we do not believe that this rule runs afoul of Burger King’s requirement that a defendant have a “fair warning that a particular activity may subject [him] to the jurisdiction of a foreign sovereign.... ” 471 U.S. at 472 , 105 S.Ct. at 2182 (quoting Shaffer, 433 U.S. at 218 , 97 S.Ct. at 2587 ). 2011Also, we do not believe that this rule runs afoul of Burger King’s requirement that a defendant have a “fair warning that a particular activity may subject [him] to the jurisdiction of a foreign sovereign.... ” 471 U.S. at 472 , 105 S.Ct. at 2182 (quoting Shaffer, 433 U.S. at 218 , 97 S.Ct. at 2587 ). | 1 | 2011–2011 |
Shaffer v. Heitner
green
2 sentences2011Also, we do not believe that this rule runs afoul of Burger King’s requirement that a defendant have a “fair warning that a particular activity may subject [him] to the jurisdiction of a foreign sovereign.... ” 471 U.S. at 472 , 105 S.Ct. at 2182 (quoting Shaffer, 433 U.S. at 218 , 97 S.Ct. at 2587 ). 2011Also, we do not believe that this rule runs afoul of Burger King’s requirement that a defendant have a “fair warning that a particular activity may subject [him] to the jurisdiction of a foreign sovereign.... ” 471 U.S. at 472 , 105 S.Ct. at 2182 (quoting Shaffer, 433 U.S. at 218 , 97 S.Ct. at 2587 ). | 1 | 2011–2011 |
Hall & Co. v. Steiner & Mondore
green
2 sentences2006Hall & Co., Inc. v. Steiner and Mondore, et al, 147 A.D.2d 225, 229 , 543 N.Y.S.2d 190 (1989). 2006Hall & Co., Inc. v. Steiner and Mondore, et al, 147 A.D.2d 225, 229 , 543 N.Y.S.2d 190 (1989). | 1 | 2006–2006 |
Burns v. McClinton
green
1 sentence2006By contrast in Burns, 143 P.3d at 636 , the Washington court of appeals found that there was no distinct accounting matter that justified the application of the continuous representation doctrine. | 1 | 2006–2006 |
Ackerman v. Price Waterhouse
green
2 sentences2006In Ackerman, 252 A.D.2d at 205 , 683 N.Y.S.2d 179 , the client alleged that an accounting firm had repeatedly used an improper accounting method and failed to disclose to the. client the risks associated with that method. 2006In Ackerman, 252 A.D.2d at 205 , 683 N.Y.S.2d 179 , the client alleged that an accounting firm had repeatedly used an improper accounting method and failed to disclose to the. client the risks associated with that method. | 1 | 2006–2006 |
R.D.H. Communications, Ltd. v. Winston
green
1 sentence2003Communications, Ltd. v. Winston, 700 A.2d 766 (adopting the continuous representation rule as an exception to the discovery rule). | 1 | 2003–2003 |
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.
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.