St. Luke's Magic Valley Regional Medical Center v. Luciani

Summary

The Idaho Supreme Court answered a certified question concerning whether a legal malpractice claim may be assigned in a commercial transaction. The court held that although legal malpractice claims are generally not assignable, such a claim is assignable when transferred to a successor in interest along with other business assets and liabilities. St. Luke’s therefore could pursue Magic Valley’s malpractice claim against its former counsel.

Holdings

1. Although legal malpractice claims are generally not assignable in Idaho, a legal malpractice claim transferred to an assignee in a commercial transaction together with other business assets and liabilities is assignable.
2. St. Luke's could step into the shoes of Magic Valley and pursue Magic Valley's legal malpractice claim against Luciani.

Questions Presented

1. Whether a legal malpractice claim is assignable under Idaho law when transferred to a successor in interest as part of a commercial transaction involving the transfer of other business assets and liabilities.
2. Whether St. Luke's, as Magic Valley's successor under the commercial transaction, could assert Magic Valley's legal malpractice claim against Luciani.

Disposition

other