Douglas Coe v. Proskauer Rose LLP

Summary

The court held that the Coes’ fraud and negligent-misrepresentation claims were governed by their own accrual rules rather than automatically by the legal-malpractice limitations analysis. Those claims accrued when the Coes paid the fees and thereby sustained certain economic loss in 2002, but fraudulent-concealment tolling remained potentially available because genuine issues of material fact existed regarding their reasonable diligence in discovering the alleged fraud. The court reversed the Court of Appeals and remanded with instructions to reverse the trial court’s summary judgment and conduct further proceedings.