Cooke v. Williams

Summary

The court adopted an exoneration rule for criminal-malpractice claims that require proving counsel's negligence caused or contributed to an underlying criminal conviction. It held that failure to obtain appellate or postconviction relief makes such a claim legally insufficient, not jurisdictionally unripe, so the proper procedural vehicle is a motion to strike rather than a motion to dismiss. Because the plaintiff's malpractice allegations necessarily challenged the validity of his conviction, the judgment was reversed in form and remanded for further proceedings.