Cruze v. Hudler
Oregon Court of Appeals
267 P. 3d 176 (2011)
Relevant factsFree
Attorney Markley (defendant), a business partner of developer Hudler (defendant) in interconnected real-estate companies, prepared documents containing material misrepresentations that Hudler used to induce Cruze (plaintiff) to invest over $3.5 million in what turned out to be a Ponzi-type scheme; Markley never personally made misrepresentations to Cruze, but Cruze alleged Markley knew of Hudler's fraud, and the trial court granted Markley summary judgment for lack of direct misrepresentation.
IssueFree
Whether a lawyer may be liable to a third party for aiding and abetting a client's tort if the lawyer provided substantial assistant to the client's commission of the tort.