Bennett v. Gentile

Summary

The Court affirmed summary judgment for the drafting attorney, holding that Maryland's strict privity rule remains applicable to legal-malpractice claims brought by beneficiaries of an inter vivos trust. It further held that beneficiary status alone does not establish third-party-beneficiary status; the claimant must show that benefiting the nonclient was the direct purpose of the attorney-client engagement. On the undisputed facts, the settlor's primary purposes were to fund her care and exclude another beneficiary, making any benefit to the claimant merely incidental.