Reynolds v. Henderson & Lyman

Dist. Ct. did not err in granting defendant-law firm’s motion for summary judgment in plaintiff’s legal malpractice action, alleging that defendant gave negligent advice to several LLCs co-owned and managed by plaintiff, which, in turn resulted in plaintiff violating federal disclosure laws when drafting LLCs’ financial statements based on said advice. Plaintiff could not bring any legal malpractice lawsuit on his own behalf because he did not have any personal attorney-client relationship with defendant, where plaintiff never asked defendant to represent him. Moreover, plaintiff failed to establish that defendant was hired by LLCs for primary purpose of benefiting plaintiff, and primary purpose of retainer agreement between business entity and law firm is to benefit business entity and not owner of business entity. Fact that plaintiff’s and LLCs’ interests were closely aligned did not require different result.