Chandra A. Bozelko v. Angelica N. Papastavros

Summary

The court affirmed summary judgment for the defendant in a legal-malpractice and fiduciary-duty action because the plaintiff lacked expert testimony establishing that counsel's alleged errors caused her criminal convictions and resulting damages. It held that expert testimony is generally required to establish causation in legal-malpractice cases when the causal connection is beyond ordinary juror understanding, even if expert testimony might not be required to establish the standard of care. The court also held that causation must be assessed objectively through a case-within-a-case analysis rather than through testimony from jurors in the underlying criminal trial.