Douglas Coe v. Proskauer Rose LLP

Summary

The court held that the fraud and negligent-misrepresentation claims were governed by their own accrual rules and could not be treated as legally malpractice claims merely because they arose from the same transactions. Those claims accrued when the plaintiffs paid fees and thereby sustained certain economic loss in 2002, but the limitation period could be tolled if fraudulent concealment prevented discovery and the plaintiffs exercised reasonable diligence. The court further held that genuine issues of material fact existed regarding the plaintiffs’ knowledge and diligence, requiring reversal of summary judgment. The opinion contains no separate writings.