Zok v. Collins
In Zok v. Collins, 18 P.3d 39 (Alaska 2001), the court held that, even though expert testimony was typically required to establish a claim of legal malpractice (i.e., an attorney's breach of the applicable duty of care or fidelity), the claim can be supported by the testimony of lay witnesses "where the negligence would be evident to lay people, or where the fault is so clear as to constitute negligence as a matter of law."
In Zok, the court held that the evidence of the attorney's "general laxity in prosecuting Zok's lawsuit was so obviously a breach of an attorney's duty to his client that the average juror untrained in the law would be able to make a finding of negligence." Id. at 42.