Genet v Buzin 2018 NY Slip Op 01878 Decided on March 20, 2018 Appellate Division, First Department is an example of a pro-se legal malpractice case wiped off the board. In a short decision, which gives few clues, the AD affirmed in about the shortest way possible.
“Order, same court and Justice, entered January 20, 2017, which, insofar as appealed from as limited by the briefs, denied plaintiffs’ motion to renew so much of defendants’ motion to dismiss as was based on lack of personal jurisdiction, and for leave to serve an amended complaint, unanimously affirmed, without costs.
Plaintiffs’ proposed amendment is “palpably insufficient” (MBIA Ins. Corp. v Greystone & Co., Inc., 74 AD3d 499, 499 [1st Dept 2010]). The allegations underlying the legal malpractice claim merely “reflect plaintiff[s’] dissatisfaction with defendants’ strategic choices and tactics; there is no showing that those choices and tactics were unreasonable” (Kassel v Donohue, 127 AD3d 674, 674 [1st Dept 2015], lv dismissed 26 NY3d 940 [2015]; see also Rosner v Paley, 65 NY2d 736, 738 [1985]).”