McGlynn v. Burns & Harris, Esq.
In this legal malpractice action, William McGlynn sued attorneys Burns & Harris, Esq., and Allison R. Keenan for failing to notify insurance carriers in a prior personal injury case, preventing him from collecting a judgment. The defendants moved for summary judgment, arguing judicial estoppel applied due to McGlynn's workers' compensation claim with an inconsistent injury theory. The Supreme Court granted summary judgment to the defendants and denied McGlynn's cross-motion to strike their answer for spoliation of evidence. On appeal, the Appellate Division, Second Department, reversed the summary judgment for the defendants, finding that multiple proximate causes for injuries are possible and the judicial estoppel doctrine might not preclude recovery. The court affirmed the denial of McGlynn's cross-motion for spoliation of evidence, determining he failed to show an obligation to preserve the evidence or a culpable state of mind.