Negligent Attorney Referral not a Cause of Action in New Jersey

Sheppard v Lentz the plaintiff had alleged that Attorney Perskie negligently referred a traffic personal injury case to Attorney Lentz.  Perskie had determined that he had a conflict of interest prior to taking Sheppard on as a client and referred the case to Lentz.  Perskie had taken no referral fee and had no case sharing arrangement with Lentz.

The original personal injury case did not result in a recover for Sheppard.  Sheppard then sued Lentz for attorney malpractice and Perskie.  Lentz separately settled with Sheppard.  Sheppard continue to pursue a malpractice claim against Perskie for ‘Negligent Referral’.  

The trial court granted a summary judgement for Perskie citing that New Jersey does not have a cause of action of ‘Negligent Referral’.  The New Jersey Appellant Court affirmed the trial court’s decision.