Jennings v. Shuler, No. 2012-CA-01122-COA, 2014 Miss. App. LEXIS 55 (Miss. Ct. App. Feb. 4, 2014)

(a client engaged an attorney to draft a security agreement for loans she made to her son; although the attorney drafted the agreement, the client did not provide him with an equipment list, and he did not file a financing statement; after the son declared bankruptcy, the client sued the attorney for malpractice for failing to file the financing statement; the circuit court granted summary judgment to the attorney, finding that he owed no duty to the client to file the statement; on appeal, the court disagreed that the duty question could be decided on summary judgment; nonetheless, the court affirmed the judgment on the grounds that the client suffered no damage and that she filed her claim outside of the three-year limitations period for a legal malpractice claim; the client succeeded in recovering from the son’s bankruptcy estate more than the appraised value of the collateral she claimed was jeopardized by the attorney’s alleged negligence).