In Apex Towing Co. v. Tolin, 41 S.W.3d 118, 118 (Tex. 2001), the Texas Supreme Court "reexamine[d] when the statute of limitations in a legal-malpractice cause should be tolled." In that case, an attorney was sued for mishandling the defense of a maritime personal-injury lawsuit. Id. at 119. Specifically, the attorney failed to file a timely maritime limitation-of-liability pleading which would have imposed a limit on the amount of damages that could be recovered by the plaintiff. Id. Ultimately, a judgment was rendered on a jury verdict for an amount in excess of the limit that would have been imposed if the attorney had timely filed the maritime-limitation pleading. Id. The case was settled on appeal. Id. When Apex sued the attorney for malpractice, the attorney contended that limitations began to run at least by the date of the settlement. Id. The Texas Supreme Court, however, held that limitations was tolled until the court of appeals issued its order on May 19, 1995, dismissing the pending appeal based on the settlement. Id. at 123. Since Apex filed its malpractice lawsuit within two years of that date, the lawsuit was timely filed. Id. In reaching its holding in Apex, the Texas Supreme Court noted the two policy considerations articulated in Hughes v. Mahaney & Higgins, 821 S.W.2d 154, 155 (Tex. 1991) to support tolling, namely: (a) a client should not have to adopt inherently inconsistent postures in the underlying case and the malpractice case; and (2) the viability of the malpractice case depends on the outcome of the underlying litigation. 41 S.W.3d at 121. The court further noted that it had elaborated on the first policy in a subsequent case when it stated "that attorney-client trust would be eroded if the client had to scrutinize every stage of the case for possible missteps." Id. Noting that the tolling rule adopted in Hughes is not universally followed in other states, the court asserted that it continued to believe bright-line rules in the area of limitations represent the better approach. Id. at 122. The court concluded, "without re-examining whether the policy reasons behind the tolling rule apply in each legal-malpractice case matching the Hughes paradigm, courts should simply apply the Hughes tolling rule to the category of legal-malpractice cases encompassed within its definition." Id. The court then held, "In this case, Apex alleges that [the attorney] committed malpractice while defending Apex in the underlying personal-injury litigation. The Hughes rule thus applies to this case." Id. at 123.