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Accountants’ Professional Liability

The attorneys in our Accountants’ Professional Liability Practice Group focus on the defense of accounting firms, persons, or practices in both the federal and state courts. In addition to defending civil matters, our attorneys represent accountants in disciplinary matters and provide counseling and risk management advice to individual CPAs, accountants, bookkeepers and their related firms.

With a CPA on our legal team, members of our group are intimately familiar with the nuances of accounting practices. From an attest engagement to a provision of bookkeeping services, our attorneys are well-versed in the various types of claims and litigation an accounting professional may face.

In all cases, our attorneys seek to present creative solutions to traditional legal issues. Whenever possible, we look for “business solutions” and often structure the resolution of cases by resurrecting the underlying transaction giving rise to the malpractice claim. Our attorneys have been successful in obviating claims and litigation by appearing in Tax Court to assist an insured’s client in successfully reversing an audit finding or assessment by the IRS.

Because many liability claims are resolved outside of the courtroom, we are accustomed to and skilled in alternative dispute resolution (ADR) proceedings. We often assess which cases belong in ADR versus traditional litigation, with the goal of directing matters to the appropriate forum for the most expedient, cost-efficient resolution.

Results

Legal and Accounting Malpractice Claims Successfully Dismissed

We obtained a dismissal of plaintiff’s legal and accounting malpractice claims, in which the plaintiff claimed a prior unrelated legal settlement led to an avoidable tax liability. The plaintiff alleged that our attorney client was negligent in providing legal and accounting advice in regard to corrective tax filings following a legal settlement with a state entity. After multiple rounds of amended pleadings and briefing, the court entered an order adopting our lack of subject matter jurisdiction argument and dismissed the plaintiff’s complaints based upon a Rule 8 violation. 

Accounting Malpractice Claim Barred by Statute of Limitations

We obtained dismissal of an accounting malpractice claim on preliminary objections in the Philadelphia Court of Common Pleas. The plaintiffs alleged that their accountant improperly prepared their tax returns—as married filing jointly—and failed to claim business losses, that resulted in an unexpected tax liability being owed. Although the plaintiffs attempted to rely on the discovery rule to toll the statute of limitations, the defense successfully argued that the plaintiffs were on notice of the alleged negligence by the time they received the prepared tax returns, and that their failure to investigate potential claims at that time was a failure to exercise due diligence as a matter of law. We further argued that because they were under a duty to investigate earlier, the plaintiffs could not successfully allege that they could not have known of their claims until they hired a tax attorney to investigate. Because the plaintiffs did not bring their negligence claim until more than two years after they received their prepared tax returns, their claims were barred by the Statute of Limitations.

Thought Leadership

Defense Digest

Develop the Helpful Habits to Ward Off Litigation

June 1, 2023

Reprinted with permission from the Pennsylvania CPA Journal, a publication of the Pennsylvania Institute of Certified Public Accountants. CPAs provide services in an environment that is susceptible to litigation, as they often work on or with financial information on behalf of individual or corporate clients. Any accounting litigation is predicated on a theory of professional malpractice based on the facts surrounding the services provided. This article offers insight into how to prepare for the potential of unforeseen litigation.  A CPA can do little after the fact to prevent a plaintiff’s perception that the services provided damaged the plaintiff in some way. The time to prepare for unforeseen litigation is during the opening of an engagement, before any possible litigation tornado begins to swirl. This task requires a basic understanding of the roots of a malpractice claim.  A plaintiff can establish litigation upon very little, even an inconspicuous act suggesting advice beyond your training. There could be an extensive menu of facts or incidents that can be molded into a sustainable cause of action.  Acts are evaluated against various accounting standards, such as generally accepted accounting principles (GAAP). A malpractice claim could arise if there is a perceived deviation from a standard. Unfortunately, a plaintiff’s perception becomes a CPA’s litigation reality.  A deviation from established standards is characteristically the result of either an affirmative or a negligent act. The prospective plaintiff’s malpractice claim must prove that the CPA violated some standard in one of two causes of action: breach of contract or negligence.  When an accountant has affirmatively (intentionally or otherwise) performed or omitted an act that is a departure from a recognized standard, it is a cause of action for breach of contract. The elements of a cause of action for a breach of contract require the following:  An agreement for the CPA to provide their professional services.  A breach of duty owed under the contract (failure to meet an appropriate standard of professional care).  The failure of the CPA results in damages to the plaintiff.  When a CPA breaches a duty of care owed to the plaintiff it is a cause of action for negligence. A cause of action for negligence requires the following:  The CPA owed a duty of care. The CPA failed to exercise ordinary skills and knowledge.  The failure is the proximate cause of the harm. The plaintiff sustained damages.  The common thread for breach of contract and negligence causes of action is the assertion that the CPA deviated from the standard of care by violating some accounting standard. This means the CPA failed to use the skill, learning, and care normally used in similar circumstances. In many cases of malpractice, the CPA will present a fact derivative of the accounting services, and that fact is later determined to be incorrect. The rub is that the perceived deviation from the standard is that the CPA should have known the fact was incorrect. While all risks cannot be contained, some can be minimized by trusting your experience, insight, and pre-litigation preparation habits.  The first step in developing a defense is in the pre-engagement phase; the cornerstone of which is the engagement letter. The scope of the engagement should be clear and not open for interpretation. Describe the scope of work, how the work will be executed, and the parties’ individual responsibilities. Just as crucial, identify the scope of services excluded to reduce any possible misunderstanding or an expansion of services.  You can avoid claims by avoiding engagements outside your professional competency. A modest task can develop into an enormous mistake. Providing extraordinary services to a client may seem appropriate, but the risk is significant. Avoid the risk; instead, make a referral to a colleague with the required skill set and experience.  The second step is to communicate and manage your client’s expectations. Communication and the development of expectations are critical to meeting the client’s needs and avoiding misunderstandings – the seeds of future litigation. The parameters of accounting services are finite, and you must explain the limitations. Once boundaries have been established, take the next step to manage realistic expectations through a clear and concise explanation of what your services are, and what they are not.  Continuous communication with clients allows you to ensure their understanding and keeps them informed of the unanticipated. Clients are often more accepting of changes or issues when these are presented as soon as possible. Keep the client in the decision-making process, so they are part of any resolution.  The last critical step is to document, document, document. Contemporaneously record everything. A key document prepared during the engagement is an invaluable tool to defend a professional malpractice claim. Develop the habit of keeping records of appointments, correspondence, telephone logs, and notes (amongst other things). You will have a roadmap of dates, topics discussed, and decisions made to refer back to if you are targeted with a professional negligence claim.  It can be a burden to hang up the phone with a client and prepare correspondence to memorialize the discussions and decisions. Often, we believe this is not necessary and slows the process. Don’t fall into that perception trap. Protect yourself and your reputation from unfounded claims and misunderstandings. Document everything!  *Raymond is a shareholder in our Mount Laurel, New Jersey, office. He can be reached at 856.414.6306 or rjmichaud@mdwcg.com.     Defense Digest, Vol. 29, No. 2, June 2023, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. ATTORNEY ADVERTISING pursuant to New York RPC 7.1. © 2023 Marshall Dennehey. All Rights Reserved. This article may not be reprinted without the express written permission of our firm. For reprints, contact tamontemuro@mdwcg.com.

Develop the Helpful Habits to Ward Off Litigation

March 3, 2023

CPAs provide services in an environment that is susceptible to litigation, as they often work on or with financial information on behalf of individual or corporate clients. Any accounting litigation is predicated on a theory of professional malpractice based on the facts surrounding the services provided. This article offers insight into how to prepare for the potential of unforeseen litigation.

Firm Highlights

Thought Leadership

Two Tracks, No Preclusion: Ohio Supreme Court Preserves Separate Damages Claims After Chapter 2506 Appeals

The Supreme Court of Ohio has clarified that an administrative appeal under Ohio Revised Code Chapter 2506 does not bar a separate action for damages and declaratory relief that could not have been pursued in the administrative appeal. The Ohio Supreme Court considered Sheetz, Inc. v. Centerville (2026-Ohio-3531) as a result of a certified question from the Southern District of Ohio. The question was whether Sheetz, the gas station/convenience store brand, was barred from seeking damages in a separate action since damages were not sought in their administrative appeal. Ultimately, the Ohio Supreme Court ruled that res judicata does not bar a separate action for damages after ruling on an administrative appeal because R.C. Chapter 2506 is limited to judicial review and cannot grant affirmative relief. The case arose after Centerville’s city council rejected a site plan proposed by Sheetz, Inc. that had received unanimous approval from the City’s planning commission. Sheetz filed an administrative appeal pursuant to R.C. 2506 in the Montgomery County Court of Common Pleas, and two months later filed a complaint for damages and declaratory relief under 42 USC § 1983 as a takings action with the city, city council, and other objectors as improper takings and a violation of due process, as well as interference with business and contractual relationship. The city and city council removed the § 1983 action for damages to federal court. Montgomery County Court of Common Pleas reversed the city council’s denial, and allowed the Sheetz project to move forward. Upon that ruling, the federal court issued a show-cause order questioning whether the § 1983 action was barred by the doctrine of res judicata via claim preclusion (which includes all theories of recovery).  Sheetz argued that Ohio courts of common pleas do not have authority to award damages or declaratory relief as party of the R.C. Ch. 2506 appeal, therefore res judicata could not be triggered to apply to the § 1983 action. Additionally, Sheetz moved to certify the issue to the Ohio Supreme Court, citing differing results between the second and sixth districts on this same issue. Centerville approached the question, not from a claim preclusion standpoint, but from the holding in Grava v. Parkman, Twp which states that a final judgment rendered on the merits bars all subsequent action based on the same transaction or occurrence.  In yet another approach, an objector argued that claim preclusion was satisfied because Sheetz could have raised its damages claims in the administrative appeal – Sheetz disagrees. In their analysis, the Supreme Court of Ohio broke down the elements of a claim preclusion analysis: 1) a prior final, valid decision on the merits by a court of competent jurisdiction; (2) a second action involving the same parties, or their privies, as the first; (3) a second action raising claims that were or could have been litigated in the first action; and (4) a second action arising out of the transaction or occurrence that was the subject matter of the previous action. The Court held that R.C. Ch. 2506 does not permit a party to argue damages as R.C. Ch. 2506 limits the common pleas jurisdiction as if it were sitting on appeal, and therefore can only affirm, reverse, vacate, or modify the appealed order, or can remand the case to the administrative body. Further, the Court held that Grava’s conclusion that a final judgment precludes additional litigation for different relief is inapplicable under this fact pattern because it was meant only to apply to those matters in which the plaintiff brings the exact same case twice, but for new relief. The Court found Grava was inapplicable because Sheetz could have requested damages or declaratory relief in the R.C. 2506 appeal. Therefore, Grava would be nothing more than dicta if it even did apply. Going further, the Ohio Supreme Court disavowed Sixth Circuit precedent which, in reliance on Grava and other district court decisions, permitted an owner to seeking relief under 42 U.S.C. § 1983 alongside an administrative appeal. See Moore v Hiram Twp., 988 F.3d 353 (6th Cir.2021). The Ohio Supreme Court found that the Sixth Circuit had disregarded a critical decision in Community Concerned Citizens, Inc. v. Union Twp. Bd. of Zoning Appeals, 1993-Ohio-115, which clearly held that a R.C. Ch. 2506 appeal cannot be combined with a complaint seeking other claims for relief. Id. at ¶ 11. To that end, the Ohio Supreme Court has determined that the decisions Moore relied on (outside of Grava) are no longer good law, and that Moore was wrongly decided. The decision draws a clear procedural boundary: Chapter 2506 provides judicial review of an administrative decision, not a forum for independent claims seeking affirmative relief. Although Grava may place claims arising from a single transaction within the potential scope of claim preclusion, those claims are not barred unless the complete claim-preclusion test is satisfied. Because Sheetz could not have pursued damages or declaratory relief in its Chapter 2506 appeal, the separate action was not precluded. The remaining question for practitioners looking to apply or defend against this exception is when does the statute of limitations begin to run on damages and declaratory relief claims related to an administrative decision on appeal? A takings action in federal court has a 2-year statute of limitations, or as a state claim, 4 years (like the other tortious claims raised therein). Correlating this case with others, an administrative appeal will not likely toll the statute of limitations on claims based on a final decision by a municipal authority. Therefore, practitioners should look for these cases to be brought simultaneously.

Thought Leadership

The Search-Incident-to-Arrest Doctrine Does Not License Strip Searches

In Beatty v. Gardner, No. 25-2860 (3d Cir. Sept. 16, 2026), Kyle Beatty sued police officers Clinton Gardner and Calvin Irvin under 42 U.S.C. § 1983 after they stopped, arrested, and searched him three times during a drug investigation in Williamsport, Pennsylvania. The officers initially smelled marijuana coming from the car in which Beatty was sitting and observed marijuana residue, giving them probable cause to arrest him. Beatty consented to the first pat-down, and the second search was conducted incident to his lawful arrest; neither search uncovered weapons or contraband. The officers then transported Beatty to the police station solely to strip-search him, but the strip search also revealed nothing. The District Court granted the officers summary judgment, concluding that the initial stop, arrest, and first two searches were reasonable and that qualified immunity protected the officers from liability for the strip search. The Third Circuit affirmed, but held that the strip search itself violated the Fourth Amendment. The court concluded that the search-incident-to-arrest doctrine does not automatically permit officers to strip-search an arrestee outside the jail or prison setting. Because strip searches are highly intrusive and the traditional justifications for searches incident to arrest (officer safety and preservation of evidence) did not justify the search of Beatty, the officers generally needed either the arrestee’s consent, exigent circumstances, or a warrant supported by probable cause to believe that a search beneath the clothing would reveal weapons, contraband, or evidence. Here, the officers had none of those justifications. Nevertheless, the court held that qualified immunity barred damages liability because, at the time of the search, the right against a warrantless strip search of an arrestee outside the institutional setting was not clearly established by Supreme Court or Third Circuit precedent. The court likewise upheld qualified immunity on Beatty’s First Amendment retaliation claim and affirmed summary judgment for the officers.

Thought Leadership

Pennsylvania Supreme Court to Review Whether Legal Malpractice Claims May Be Recast as Breach of Contract Claims

The Pennsylvania Supreme Court recently granted allowance of appeal to consider whether a plaintiff may pursue a breach of contract claim against an attorney based on allegations that the attorney failed to provide competent legal services. The issue is significant in professional liability litigation because it concerns whether a plaintiff may avoid the statute of limitations applicable to professional negligence claims by characterizing the alleged misconduct as a breach of contract. Antoine Poteat retained attorneys Gary Asteak and Nino V. Tinari to represent him in a criminal matter. After his conviction was subsequently overturned through a Post Conviction Relief Act proceeding, Poteat filed suit against his former attorneys alleging that they breached their retainer agreements by failing to provide competent legal services. The attorneys argued that the claims sounded in professional negligence, rather than breach of contract, and were therefore time-barred. The trial court dismissed Poteat’s complaint, but the Superior Court, sitting en banc, reversed. The Superior Court held that the gist-of-the-action doctrine did not bar Poteat’s breach of contract claim because the alleged failure to provide competent legal services could constitute a breach of the parties’ agreement. The Court further held that a legal-services agreement contains an implied duty requiring an attorney to provide competent legal services, even where the agreement does not contain an express provision requiring such services. The Pennsylvania Supreme Court granted review in July 2026 and will consider whether the Superior Court’s decision conflicts with Pennsylvania precedent distinguishing contract and tort claims, including Bruno v. Erie Insurance Co. The Supreme Court will also address whether a plaintiff may maintain a breach of contract claim based on an implied duty to provide competent legal services without identifying a specific contractual provision that was breached. The Supreme Court’s decision could have significant implications for professional liability litigation in Pennsylvania, particularly where plaintiffs seek to characterize claims arising from alleged professional negligence as contractual claims.