Summary
The Supreme Court of New Jersey adopts Section 51 of the Restatement (Third) of the Law Governing Lawyers as the standard for determining when an attorney owes a duty of care to a non-client. The Court holds that attorney Anthony Boyadjis did not owe plaintiff Helen Christakos a duty of care because she neither relied on his legal services nor presented clear and convincing evidence that he knew the 2018 wills were intended to benefit her. The Court affirms the Appellate Division's judgment.
Court
Supreme Court of New Jersey
Jurisdiction
Supreme Court of New Jersey
Decision date
January 20, 2026
Docket number
A-42-24; 090214
Disposition
affirmed
Questions Presented
- What standard governs when an attorney owes a duty of care to a nonclient who seeks to bring a legal-malpractice claim?
- Whether Boyadjis owed Helen Christakos a duty of care under Restatement (Third) of the Law Governing Lawyers § 51(2), based on an invitation to rely and actual reliance.
- Whether Boyadjis owed Helen Christakos a duty of care under Restatement § 51(3), based on the clients' intent that the attorney's services benefit her.
- Whether an alleged heir may establish an attorney's duty by claiming that the attorney negligently assisted an incompetent client to execute a will.
- Whether summary judgment was appropriate on Helen's duty-of-care claim.
Holdings
- New Jersey adopts Restatement (Third) of the Law Governing Lawyers § 51(2) and § 51(3) as the standards for determining when an attorney owes a duty of care to a nonclient.
- Boyadjis owed Helen no duty of care under § 51(2) because neither he nor his clients invited her to rely on his legal opinion or services, and she did not rely on them.
- Boyadjis owed Helen no duty of care under § 51(3) because no reasonable jury could find by clear and convincing evidence that Peter and Nicholas intended their 2018 wills to benefit Helen and communicated that intent to Boyadjis.
- An attorney does not owe a purported heir a duty of care based on an allegation that the attorney negligently assisted an incompetent client to execute a will.
Court Document
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