Davis v. Davis Wright Tremaine, L.L.P.

Does the six-year statute of limitations for written contracts1 apply to this legal malpractice action because of language in the letter of engagement between Dr. Andrew Davis and Davis Wright Tremaine L.L.P. (DWT)? If the six-year statute does not apply, are there genuine issues of material fact as to the time of accrual of Dr. Davis’ cause of action under the three-year statute of limitations for negligence?2

We hold that the legal malpractice claim here is not an action “upon a contract in writing” within the six-year statute. Moreover, it is not an action upon “a liability express or…