The U.S. District Court for the Eastern District of Michigan dismisses a malpractice action by a Michigan woman under guardianship against a Colorado estate planning firm that continued to represent her despite her wish that it cease its representation. Constantakis v. Law Off. of Patricia Lester Clowdus(U.S. Dist. Ct., E.D. Mich, So. Div., No. 07-15350, April 14, 2008).
While visiting her daughter in Colorado, Michigan resident Lillian Constantakis became ill. Mrs. Constantakis subsequently hired the Colorado firm of Patricia Lester Clowdus to prepare estate planning documents. Believing that his wife was being taken advantage of, Mrs. Constantakis' husband, Clarence, filed guardianship proceedings in Colorado and Michigan and brought her back to Michigan. Upon her return, Mrs. Constantakis informed the law firm several times that she no longer wanted it to represent her. Nevertheless, the firm continued to represent her, entering an appearance in the Colorado guardianship case and continuing to send her correspondence in Michigan. Mrs. Constantakis sued for legal malpractice.
The U.S. District Court for the Eastern District of Michigan dismisses the suit, finding that because the law firm's alleged malpractice took place in Colorado and the firm did not initiate the representation, its contacts with Michigan were insufficient to give the court personal jurisdiction.
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