Pennsylvania courts have long held that a cause of action for legal malpractice cannot be brought against an attorney when a case has settled absent proof of fraud or attorney error in providing advice on the legal implications of the settlement. See, Muhammad v. Strassburger, McKenna, Messer, Shilobod and Gutnick, 526 Pa. 541, 587 A.2d 1346 (Pa. 1991), rehearing denied, 528 Pa. 345, 598 A.2d 27 (Pa. 1991), cert denied    U.S.   , 112 S.Ct. 196, (1991) (“Simply stated, we will not permit a suit to be filed by a dissatisfied plaintiff against his attorney following a settlement to which that plaintiff agreed, unless that plaintiff can show he was fraudulently induced to settle the original action.”).

Muhammad foreclosed claims based on dissatisfaction with the terms of a settlement: “We foreclose the ability of dissatisfied litigants to agree to a settlement and then file suit against their attorneys in the hope that they will recover additional moneys.” In Muhammad the Pennsylvania Supreme Court considered a legal malpractice claim stemming from dissatisfaction with the settlement of prior litigation. The Supreme Court decided not to allow lawsuits against lawyers that are premised upon the client’s determination a settlement was inadequate.