Pelham v. Griesheimer

In Pelham v. Griesheimer (1982), 92 Ill. 2d 13, 440 N.E.2d 96, 64 Ill. Dec. 544, the supreme court established the standard for pleading the liability of attorneys to nonclients in legal-malpractice actions. The court extended the traditional concept of attorney liability to include third parties who were 'intended beneficiaries of the relationship between the client and the attorney.' (Pelham, 92 Ill. 2d at 20, 440 N.E.2d at 99.) A nonclient must prove that the primary purpose and intent of the attorney-client relationship is to benefit or influence the third party. (Pelham, 92 Ill. 2d at 21, 440 N.E.2d at 100.) Finally, the court held that where the attorney-client relationship is involved in an adversarial proceeding, there must be a 'clear indication that the attorney's representation is intended to directly confer a benefit upon the third party.' Pelham, 92 Ill. 2d at 23, 440 N.E.2d at 100.