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Keywords

plaintiffdefendantattorneynegligenceappealtrialsummary judgmentfiduciarymalpracticelegal malpracticefiduciary dutybreach of fiduciary duty
contractbreach of contractplaintiffdefendantnegligencetrialmotionsummary judgmentfiduciarymalpracticelegal malpracticefiduciary dutyduty of loyaltybreach of fiduciary dutymotion for summary judgment

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Kilpatrick v. Wiley, Rein & Fielding, 909 P.2d 1283

Facts

In the early 1980s, the plaintiffs hired the defendant law firm to represent them in obtaining a television license. The law firm simultaneously represented other clients with conflicting interests without disclosing this to the plaintiffs. As a result of the law firm's actions, the plaintiffs alleged they suffered significant financial losses when the firm failed to act in their best interests, leading to a legal malpractice claim based on breach of fiduciary duty.

In the early 1980s, the Federal Communications Commission (FCC) approved a new VHF television station for the Salt Lake City market (Channel 13). Plaintiffs hired defendant, a law firm specializing in communications law, to represent them in their effort to obtain the newly offered license.

Issue

Did the trial court apply the correct standard of causation for legal malpractice actions based on breach of fiduciary duty, and were there genuine issues of material fact regarding causation?

The trial court applied the wrong standard of causation for legal malpractice claims based on breach of fiduciary duty.

Rule

The standard of causation for legal malpractice actions based on breach of fiduciary duty is the same as that for legal malpractice actions based on negligence, requiring clients to show that but for the attorney's wrong, they would have benefited.

The standard of causation for legal malpractice action based on breach of fiduciary duty is the same as that for legal malpractice action based on negligence.

Analysis

The court determined that the trial court improperly granted summary judgment by weighing evidence and concluding that no genuine issues of material fact existed regarding causation. The plaintiffs presented evidence suggesting that had the law firm not breached its fiduciary duty, they would have made different financial decisions that would have benefited them. This created a factual dispute that should be resolved by a jury.

The trial court found facts and weighed evidence presented by the parties, which was inappropriate in considering a motion for summary judgment.

Conclusion

The Court of Appeals reversed the trial court's grant of summary judgment and remanded the case for further proceedings, emphasizing that genuine issues of material fact existed regarding causation.

We hold the standard of causation for legal malpractice is the same regardless of whether the cause of action is based on breach of contract, breach of fiduciary duty, or negligence.

Who won?

The plaintiffs prevailed in the appeal because the court found that the trial court had erred in granting summary judgment by not recognizing the existence of genuine issues of material fact regarding causation.

The plaintiffs presented evidence suggesting that had defendant not breached its duty of loyalty, they would have accepted CPL's financing commitment rather than Northstar's financing commitment and would have benefited from that choice.

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