Nichols v. Keller
Court of Appeals of California
19 Cal. Rptr. 2d 601 (1993)
Nichols (plaintiff) retained attorneys Fulfer and Keller (defendants) solely to handle a workers' compensation claim, and the attorneys never advised him that he might also have viable civil tort claims arising from the same underlying injury; Nichols learned of the potential additional claims only after the statute of limitations on them had already run. Nichols sued the attorneys for legal malpractice based on their failure to inform him of these other options, and the trial court granted the attorneys summary judgment; Nichols appealed.
Whether an attorney retained for limited representation on a specific claim owes the client a duty to identify and advise about other reasonably apparent legal claims that fall outside the scope of the limited retention.