Bay Cities Paving & Grading, Inc. v. Lawyers Mutual Insur. Co

In Bay Cities Paving & Grading, Inc. v. Lawyers Mutual Insur. Co., 5 Cal. 4th 854 (1993), the Supreme Court of California defined the term related in a similar insurance policy. There, a general contractor sued his attorney for two failures to perfect the contractors mechanics lien on a single construction project. As a result of the attorneys malpractice, the contractor was unable to collect the money he was owed for the project. The attorneys professional liability insurance policy provided that two or more claims arising out of a single act, error or omission or a series of related acts, errors or omissions shall be treated as a single claim. Id. at 857. The court held that the term related is broad enough to include both logical and causal connections. Id. at 873. It went on to find that the contractors two claims were logically related because they: (1) arose out of the same transaction, the collection of a debt; (2) arose as to the same client; (3) were committed by the same attorney; and (4) resulted in a single injury, the loss of the debt. Id.