Cooke v. Williams

Summary

The court adopted the exoneration rule for criminal malpractice claims when proving the claim would require undermining the validity of the plaintiff's criminal conviction. It held that prior appellate or postconviction relief is an element of such a claim, but that failure to plead or prove relief is a pleading-sufficiency defect rather than a subject matter jurisdiction defect. The court therefore directed denial of the motion to dismiss and further proceedings under the proper procedural framework, while leaving the fee-related fraud claim undisturbed.