Knutson v. Foster

(California Court of Appeal) – Held that an attorney was not entitled to a new trial after a jury found him liable to a client for intentional torts. The attorney argued that the client failed to prove causation. Disagreeing, the Fourth Appellate District concluded that claims of fraudulent concealment and intentional breach of fiduciary duty brought against an attorney are subject to the substantial-factor causation standard, not the trial-within-a-trial or but-for standard employed in cases of legal malpractice based on negligence. The panel also held that the testimony of the client alone sufficed here to support her emotional distress damages.