Trial Court's Dismissal of Pro Se Legal Malpractice Claim as Being Barred by the Statute of Limitations Upheld on Appeal

The Tennessee Supreme Court has released its opinion in Garrett v. Weiss, No. E2022-01373-COA-R3-CV (Tenn. Ct. App. May 25, 2023). The syllabus from the slip opinion reads:

The pro se plaintiff appeals the trial court’s summary judgment dismissal of his legal malpractice action against his attorney and the attorney’s law firm. The trial court found that the action was barred by the applicable one-year statute of limitations. Because the plaintiff’s action accrued more than one year before he filed the lawsuit, we affirm.

Here is a link to the opinion: Bradley Garrett v William Weiss.pdf (tncourts.gov).

NOTE: This opinion addresses the standard of review for summary judgment when the movant has the burden of proof on the issue at trial (here, the defendant as to a defense based on the statute of limitations); accrual of legal malpractice actions under the discovery rule, and waiver of issues on appeal. This is a good read in my humble opinion because of these topics.