Recent Illinois Case: Auto-Owners Insurance Co. v. Konow

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The Second District held that an attorney does not owe a duty to a non-client in a negligent misrepresentation case unless the Pelham test applicable to legal malpractice claims is satisfied. The court held: “This can be accomplished by synthesizing Pelham’s third-party-beneficiary model with the Penrod /Restatement rule so that information disseminated by an attorney in connection with a client matter is not for the ‘guidance’ of a third party unless the primary purpose of the attorney-client relationship was to guide or influence the third party.”

Auto-Owners Insurance Company v. Konow, 2016 IL App (2d) 150823

(This is for informational purposes and is not legal advice.)

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