Glamm v. Allen

In Glamm v. Allen, 57 NY2d 87 (1982), the court enunciated the theory behind applying the concept of the continuous treatment rule in medical malpractice cases to continuous representation in legal malpractice suits as follows (pp. 93-94): "As this court recently stated, the rule recognizes that a person seeking professional assistance has a right to repose confidence in the professional's ability and good faith, and realistically cannot be expected to question and assess the techniques employed or the manner in whch the services are rendered .... Neither is a person expected to jeopardize his pending case or his relationship with the attorney handing that case during the period that the attorney continues to represent the person. Since it is impossible to envision a situation where commencing a malpractice suit would not affect the professional relationship, the rule of continuous representation tolls the running of the Statute of Limitations on the malpractice claim until the ongoing representation is completed."