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Keywords

contractlawsuitbreach of contractdamageslitigationattorneytrialmotionsummary judgmentmalpracticediscriminationlegal malpracticegood faithbad faith
lawsuitplaintiffdefendantdamagesattorneymotionsummary judgmentmalpracticelegal malpracticebad faithmotion for summary judgment

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Alexandru v. Strong, 81 Conn.App. 68, 837 A.2d 875

Facts

Michaela I. Alexandru retained Patricia M. Strong to represent her in a federal lawsuit against Northeast Utilities for alleged sexual discrimination and retaliation. After a deterioration in their attorney-client relationship, Strong filed a motion to withdraw, which was initially denied but later granted by the District Court. Following her withdrawal, Alexandru represented herself and ultimately lost her case against Northeast Utilities. Subsequently, she filed a lawsuit against Strong alleging legal malpractice, breach of contract, and other claims related to Strong's representation.

This action arises out of the defendant's legal representation of the plaintiff in a federal lawsuit against the plaintiff's former employer, Northeast Utilities Service Company (Northeast Utilities), for the alleged sexually discriminatory and retaliatory treatment of the plaintiff by several of its employees.

Issue

The main legal issues were whether Alexandru's claims against Strong were barred by collateral estoppel, whether her breach of contract claim was merely a restatement of her legal malpractice claim, and whether Strong's withdrawal constituted a breach of the implied covenant of good faith and fair dealing.

The court determined that the plaintiff was collaterally estopped from establishing that she would have succeeded on the emotional distress claim because the factual allegations underlying that claim were identical to those underlying the plaintiff's Title VII claims, which were litigated and resolved by the jury in favor of Northeast Utilities.

Rule

The court applied the principles of collateral estoppel, which prevents relitigation of issues that have been fully and fairly litigated in a prior action, and determined that claims of legal malpractice must demonstrate causation and damages, which were not established in this case.

To recover on a legal malpractice claim, the plaintiff must establish: “(1) the existence of an attorney-client relationship; (2) the attorney's wrongful act or omission; (3) causation; and (4) damages….

Analysis

The court found that Alexandru was collaterally estopped from relitigating the factual issues surrounding her claims against Northeast Utilities because those issues had been fully litigated in her prior federal case. Additionally, the court determined that her breach of contract claim was essentially a legal malpractice claim, which was also time-barred. The court further concluded that there was no evidence of bad faith on Strong's part when she withdrew as counsel, and thus Alexandru could not prevail on her claims for breach of the implied covenant of good faith and fair dealing.

The court correctly concluded that the plaintiff was collaterally estopped from establishing that she would have been successful in pursuing her emotional distress claim.

Conclusion

The Appellate Court affirmed the trial court's summary judgment in favor of Strong, concluding that Alexandru's claims were barred by collateral estoppel and that Strong acted appropriately in her withdrawal.

We accordingly conclude that the court correctly determined that the defendant's representations were protected by an absolute privilege and, therefore, properly granted the defendant's motion for summary judgment as to the plaintiff's claims for intentional infliction of emotional distress and defamation.

Who won?

Patricia M. Strong prevailed in the case because the court found that Alexandru's claims were barred by collateral estoppel and that there was no evidence of bad faith in Strong's actions.

The court determined that the plaintiff failed to offer any evidence that the defendant had acted in bad faith when she withdrew from representing the plaintiff.

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