Doyle v. Hood

Plaintiff filed suit for legal malpractice in connection with attorney's preparation of living trust of Plaintiff's father, through which a special-needs trust was created, and his will. Court properly dismissed complaint as time-barred under special repose period in Section 13-214.3(d) of Code of Civil Procedure. Injury occurred upon death of Plaintiff's father, as Supplemental Trust was not funded until his death, at which time penalties were imposed, by DHS, against recipient of benefits of Supplemental Trust. Plaintiff, as trustee of Supplemental Trust, is the only person who can bring an action on the trust's behalf.  Disability of beneficiary of trust does not toll statute of limitations. (HUDSON and SCHOSTOK, concurring.)