Crawford v. Antonacci
Plaintiff James Crawford and his wife commenced a negligence action after James Crawford suffered a torn rotator cuff due to a fall on defendants' property on November 22, 2000. The plaintiffs sought to disqualify the defendants' law firm, Hinman, Howard & Kattell (HH&K), arguing a conflict of interest due to HH&K previously representing James Crawford in a workers' compensation claim for a back injury in 1987. The Supreme Court denied the disqualification motion. On appeal, the court affirmed the Supreme Court's decision, ruling that the prior workers' compensation matter and the current negligence action were not "substantially related" under disciplinary rules, as the injuries were different, occurred 13 years apart, and any shared "loss of enjoyment of life" component was deemed speculative without specific impact descriptions. The court noted that all information regarding the prior injury would be discoverable regardless of legal representation.