Second Circuit on Legal Malpractice Based on Underlying Criminal Representation

Only the innocent need apply, well, the colorably innocent at least.  Andrew Bluestone's blog reports today on a Second Circuit case, applying New York law, which reaffirms and applies this [majority] rule on the element of causation when the "case within the case" was a criminal representation.  The court notes that this is true even for representation out of court where the underlying matter is criminal.  [Alan Childress]