Pennsylvania state and federal courts are issuing opinions regarding legal malpractice claims at a rapid rate. Many of the opinions do not add significantly to existing jurisprudence, but the appellate courts show a significant continued interest in questions regarding legal malpractice claims. In this column we review two of the most recent Superior Court opinions.

Pro Se Certificate of Merit

In Winslow v. Goldberg, Meanix & Muth, No. 3606 EDA 2017, 2018 Pa. Super. Unpub. LEXIS 2539 (Pa. Super. 2018), the Superior Court affirmed the denial of a petition to open judgment of non pros by the trial court. Winslow is more interesting for what the Superior Court did not address rather than the basis for the opinion. The plaintiff in Winslow had an underlying criminal conviction. Randall Winslow unsuccessfully appealed his criminal conviction. Acting pro se, Winslow filed an action against the criminal defense attorney who represented him on his direct appeal. Although the claims in Winslow’s pro se complaint were titled “breach of contract” and “fraudulent inducement,” the trial court determined they in fact sounded in professional negligence.