Khalil v. Williams, No. 24 EAP 2021, 2022 WL 2824672 (Pa. 2022)

Pennsylvania Supreme Court finds no reason to overturn Muhammad.

On July 20, 2022, the Supreme Court of Pennsylvania issued its opinion in this case and determined that the case before it clearly fell under at least one of the recognized exceptions to the “Muhammad Doctrine,” which prevents clients from suing their attorneys when they are unhappy with the amounts of settlements. See, Muhammad v. Strassburger, McKenna, Messer, Shilobod & Gutnick, 526 Pa. 541, 587 A.2d 1346 (1991). The Khalil opinion threatened to overturn the Muhammad Doctrine entirely, but did not do so. The Supreme Court noted that the amicus brief submitted jointly by the Pennsylvania Bar Association, the Allegheny County Bar Association, and the Philadelphia Bar Association asserted the Khalil matter fell under the fraud exception to Muhammad and there was, thus, no compelling reason to overturn Muhammad at this time (the amicus brief’s primary author was Josh Byrne who is a co-chair of the Pennsylvania Bar Association’s Amicus Committee). A scathing concurrence by Justice Wecht suggests the continuing viability of Muhammad is likely to reappear before our Supreme Court again soon.


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