A client dissatisfied with her attorneys’ work in a personal injury case cannot bring a legal misconduct claim under state Judiciary Law because her lawyers were not also convicted of a crime in connection with her representation, a federal magistrate judge concluded.

Western District Magistrate Judge Hugh Scott said he agreed with the defense’s contention that a claim under Judiciary Law §487 cannot succeed without a lawyer’s conviction on a misdemeanor offense contained in the same statute for deceiving or defrauding clients.