AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

A former criminal defendant brought a legal malpractice, breach of contract, and deceit action against his defense attorneys, alleging inadequate representation during his criminal trial. The plaintiff claimed that his attorneys failed to investigate and present an alibi defense and concealed their failure to file a required notice of alibi. The plaintiff's conviction was overturned years later on grounds of ineffective assistance of counsel (paras 1-5).

Procedural History

• Trial Court, December 1985: Plaintiff was convicted of multiple counts of criminal sexual penetration and incest.
• Court of Appeals, December 1986: Conviction affirmed on appeal.
• District Court, June 1991: Habeas corpus relief granted based on ineffective assistance of counsel.
• Supreme Court, February 1993: Affirmed the district court's grant of habeas corpus relief (paras 3-5).

Parties' Submissions

• Plaintiff: Argued that his malpractice, breach of contract, and deceit claims did not accrue until his criminal conviction was overturned, as he could not have discovered the harm caused by his attorneys until then. He also contended that the deceit claim related to the concealment of the alibi defense was timely filed (paras 6, 9-11).
• Defendants: Asserted that the claims were barred by the statute of limitations, as the plaintiff knew or should have known of the alleged malpractice and breach of contract at the time of his criminal trial. They argued that the deceit claim was also untimely, except for the portion related to the concealment of the alibi defense (paras 6, 9-10).

Legal Issues

• Whether the statute of limitations for legal malpractice, breach of contract, and deceit claims begins to run when the plaintiff knows or should have known of the facts constituting the claims or when post-conviction relief is granted (paras 6, 11).
• Whether the deceit claim related to the concealment of the alibi defense was timely filed (para 9).

Disposition

• The dismissal of the malpractice, breach of contract, and part of the deceit claims was affirmed (para 26).
• The dismissal of the deceit claim related to the concealment of the alibi defense was reversed (para 26).

Reasons

Per Pickard J. (Flores and Bustamante JJ. concurring):

• The court held that the statute of limitations for legal malpractice and related claims begins to run when the plaintiff knows or should have known of the facts constituting the claims, not when post-conviction relief is granted. The plaintiff was aware of the alleged malpractice at the time of his criminal trial, making his claims untimely (paras 6, 11, 23-24).
• The court rejected the plaintiff's argument for a special rule in criminal malpractice cases, emphasizing that statutes of limitations serve important policy goals, including fairness to defendants and avoiding stale claims. A "two-track" approach, allowing the civil case to be stayed while post-conviction proceedings are resolved, was deemed more appropriate (paras 23-24).
• The deceit claim related to the concealment of the alibi defense was found to have accrued in 1991, when the plaintiff first became aware of the concealment during the habeas corpus hearing. As the claim was filed within four years of this discovery, it was timely (para 9).
• The court affirmed the dismissal of the other claims and reversed the dismissal of the deceit claim related to the alibi defense (para 26).