Snyder v. Heidelberger

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Based on the six-year statute of repose, (735 ILCS 5/13–214.3(c), the trial court dismissed a malpractice claim alleging that defendant negligently prepared a quitclaim deed in 1997 that failed to convey real estate to plaintiff and her husband as joint tenants with right of survivorship. In 2007, when her husband died, plaintiff discovered that the property was still in trust and that ownership would pass to her stepson. The appellate court reversed and remanded. The Illinois Supreme Court reinstated the dismissal. The statute of repose is not tied to discovery of injury; the period of repose in a legal malpractice case begins to run on the last date on which the attorney performs the work involved in the alleged negligence.