Pugsley v. Tueth, 966 N.E.2d 330 (Ill. Ct. App. 2012)

(legal malpractice case based on attorney's failure to take proper legal steps to insure client's land was transferred to intended beneficiaries before client's death; client instructed attorney to sever joint tenancy on two tracts held with spouse, deed client's portion to the client’s daughters; lawyer advised that these steps were unnecessary because the client’s will would “take care of it”; client died with the tracts held in joint tenancy; surviving spouse renounced will, and daughters sued attorney claiming his error caused the spouse to receive the intended tracts of land against their mother’s intentions; district court dismissed case on statute of limitations grounds; the court agreed state statute (735 ILCS 5/13-214.3(d)) applied and established a six-month statute of limitations for malpractice actions when the attorney’s omission occurs upon the death of the client; on appeal, the court determined that the six-month statute of limitations did not apply because the injury alleged in the petition was not caused by the client’s death, but between when she directed the deeds to be changed in March 2007 and her death in May 2007; because the petition was filed within the two year statute of limitations; case reversed and remanded).