LLC’s Counsel Isn’t Liable for Owner/Manager’s Theft

Attorneys for an investment services company didn’t engage in malpractice by supposedly allowing its principal manager/owner to misappropriate clients’ funds and by failing to report his wrongdoing to government officials, the U.S. Court of Appeals for the Eleventh Circuit decided Oct. 5 (Hays v. Page Perry, LLC, 2015 BL 327426, 11th Cir., 15-11506, 10/5/15, unpublished, aff’g 2105 BL 71863, 31 Law. Man. Prof. Conduct 176).

The court’s nonprecedential per curiam order affirms a district court’s conclusion there was no plausible inference from the plaintiff’s allegations that the lawyers knew of the owner/manager’s theft or that they violated their legal ...