Sawtelle v. Farrell

CourtDistrict Court, D. New Hampshire
DecidedApril 28, 1995
DocketCV-94-392-M
StatusPublished

This text of Sawtelle v. Farrell (Sawtelle v. Farrell) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sawtelle v. Farrell, (D.N.H. 1995).

Opinion

Sawtelle v . Farrell CV-94-392-M 04/28/95 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Arthur F. Sawtelle and Judith M . Sawtelle as Administrators of The Estate of Corey A . Sawtelle, Plaintiffs, v. Civil N o . 94-392-M

George E . Farrell, Esq.; Speiser, Krause, Madole & Lear, A Partnership; Michael S . Olin, Esq.; and Podhurst, Orseck, Josefsberg, Eaton, Meadow, Olin & Perwin, P.A., Defendants.

O R D E R

This case raises an issue of substantial interest to those

rendering professional services previously considered local in

nature, but which, due to increasing ease of travel and

communication, now routinely touch or relate to distant people

and jurisdictions. The precise question of law presented in this

case is not entirely new, but neither is it completely settled:

How much contact with a foreign client's state must a lawyer have

before he or she may properly be brought before the courts of

that state to answer charges of professional negligence? In this age of advanced telecommunications, it is not

uncommon for a lawyer to represent a geographically distant

client without meeting the client in person or traveling to the

state in which the client resides. Transactions of all sorts are

now routinely initiated, negotiated, and resolved via

teleconference. Documents are easily generated, reviewed,

edited, and transmitted by facsimile, electronic mail, or

overnight express to the remotest of locations. While ease of

communication has facilitated representation of distant clients,

it has also raised difficult questions concerning the legitimate

exercise of in personam jurisdiction when those distant clients

seek to hale their attorneys into local forums.

This is a legal malpractice action in which plaintiffs seek

to recover damages allegedly sustained as a result of negligent

representation provided by two attorneys and their law firms in

connection with litigation in the State of Florida. Plaintiffs

are residents of New Hampshire and none of the defendants resides

i n , nor is any licensed to practice law in New Hampshire. Before

the court are motions to dismiss for lack of personal

jurisdiction filed by defendants George Farrell, Esquire

("Farrell"), Michael Olin, Esquire ("Olin"), Podhurst, Orseck,

2 Josefsberg, Eaton, Meadows, Olin & Perwin, P.A. (the "Podhurst firm"), and Speiser, Krause, Madole & Lear (the "Speiser firm"). 1 Fed.R.Civ.P. 12(b)(2).

Factual Background.

Plaintiffs Arthur Sawtelle and Judith Sawtelle are residents of Jaffrey, New Hampshire. On May 2 1 , 1989, their son Corey was killed in an airplane accident following a mid-air collision over the New Hampshire and Vermont border. Several months after their son's death, plaintiffs contacted a New Hampshire attorney to discuss the possibility of bringing a wrongful death suit on behalf of their son's estate.2 The local attorney (who is not a defendant here) referred plaintiffs to Attorney Juanita Madole, of Speiser, Krause, Madole & Cook, a California based law firm, with offices in other states as well. That referral was

1 Plaintiffs initially failed to serve defendant Farrell in a timely fashion and agreed to his dismissal from this case, without prejudice. They then brought a separate action against Farrell, based upon the same underlying facts as those giving rise to this action. The court consolidated the cases and now addresses each of the pending motions to dismiss. 2 Under New Hampshire law, wrongful death claims are choses in action that belong to and are brought by and on behalf of the decedent's estate. N.H. RSA 556:12.

3 presumably based on the firm's reputation for expertise in the

field of aircraft accident litigation.

In March, 1990, Attorney Madole sent duplicate originals of a retainer agreement, which she had already executed on behalf of Speiser, Krause, Madole & Cook (not a defendant) and its Washington, D.C. affiliate, the Speiser firm. Plaintiffs signed the agreement in New Hampshire and, as instructed by Attorney Madole, returned an executed original to her. Attorney Madole then transferred the case to the Speiser firm in Washington, D.C., where it was assigned to defendant Attorney George Farrell. Although Farrell never met plaintiffs in person, he spoke to them on the telephone and sent at least fifteen letters to them in New Hampshire during the course of his representation.

After reviewing the circumstances of Corey's death and the

applicable law in various forums that might be available to the

estate, Attorney Farrell recommended Florida, where the

underlying defendants resided, as the most advantageous place to

bring the estate's wrongful death case and plaintiffs' own

related claims. Plaintiffs agreed, and Farrell engaged the

Podhurst firm to assist as local counsel. The Podhurst firm, a

4 Florida professional association, is engaged in the practice of

law in the State of Florida. Defendant Michael Olin is a

resident of Florida and is a member of the Podhurst firm. He is

licensed to practice law in Florida. He is not, however,

licensed to practice law in New Hampshire. At no time during the

course of their representation of plaintiffs and the estate did

Olin or any other member of the Podhurst firm enter New Hampshire

or solicit or conduct business in New Hampshire; all work

performed for or on behalf of plaintiffs and the estate was done

in Florida.

On March 2 6 , 1991, defendant Olin filed a wrongful death action on behalf of the estate (and plaintiffs individually) in the Broward County (Florida) Judicial Circuit Court. Olin signed the complaint for the estate on behalf of both the Speiser firm and the Podhurst firm.

Plaintiffs allege that the estate's attorneys were negligent

in their handling of the matter. They say defendants negotiated

a woefully inadequate settlement of the estate's wrongful death

claim, without having taken any depositions, without having

secured an economist's projection of the decedent's lost earning

5 capacity, and without having consulted any liability experts, or

engaging in any substantial investigative efforts. Plaintiffs

further allege that defendants negligently advised them to accept

the inadequate settlement proposal ($155,000.00) which, in

reliance upon counsels' apparent expertise, they did.

Sometime later, plaintiffs discovered that the estate of Ronald Brown (Corey's flight instructor, who was killed in the same accident) had also filed a wrongful death suit in Florida (the "Brown Action"), and that the Brown Action had been consolidated with the case brought by Corey's estate. After plaintiffs had finally settled the estate's claim for $155,000.00, they learned that the similar Brown Action had settled for $500,000.00.

Plaintiffs explain the disparity between the two settlements

as the direct result of their attorneys' negligent preparation

and handling of the wrongful death action and negligent advice to

accept an inadequate settlement offer. Defendants move to

dismiss plaintiffs' suit, asserting the absence of in personam

jurisdiction over them in New Hampshire.

6 Standard of Review.

It is well established that in a diversity case personal

jurisdiction over a nonresident defendant is governed, at least

in part, by the forum state's long-arm statute. Goldman,

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