Previously, this author had written on numerous occasions that the statute of limitations for legal malpractice actions is in flux. Now more than ever that volatility is coming to bear.

In Coleman v. Duane Morris, 58 A.3d 833 (Pa. Super. 2012), the Superior Court precedentially established two causes arising from legal malpractice: negligence; and breach of contract. While there may be ancillary causes (i.e., breach of fiduciary duty, fraud, etc.), the Superior Court held there firmly exists legal malpractice negligence and legal malpractice breach of contract causes effectively emanating from the same attorney misconduct.