Supreme Court of Delaware
ISN Software Corporation v. Richards, Layton & Finger, P.A.
February 17, 2020
Summary
The Court held that ISN’s legal-malpractice claim accrued when the allegedly erroneous advice caused injury by giving an additional stockholder appraisal rights, not when the later appraisal established the amount of damages. Because the claim accrued in January 2013 and was filed in August 2018, it was barred by the three-year limitations period. The Court also held that ISN’s allegations did not support tolling based on fraudulent concealment or justify delaying dismissal until production of RLF’s complete file.