Bobby Cockrell, Jr., and Cockrell & Cockrell v. Juakeishia Vonshai Pruitt

Summary

The court held that an attorney's fraudulent misrepresentations concealing the status of a client's underlying claims may constitute a separate legal-malpractice claim under the Alabama Legal Services Liability Act, apart from the attorney's failure to timely file the underlying actions. Because the alleged misrepresentations occurred within the applicable four-year repose period, the trial court properly denied summary judgment on the claims that the law firm defendants were vicariously liable for the associate's fraud. Justice Murdock, dissenting, would have treated the concealment as preventing repose from running on the underlying malpractice rather than as a separate tort.