Only Exceptional Circumstances Allow Attorneys to be Sued by Non-Clients for What Attorneys Did on Behalf of Their Clients

The Missouri Court of Appeals affirmed dismissal of tortious interference and civil conspiracy claims brought by a resort against attorneys who advised timeshare owners to stop payments. The court held that when a non-client sues attorneys for actions taken on behalf of clients, the plaintiff must plead specific facts showing “exceptional circumstances”—such as fraud or malicious conduct—to overcome attorneys’ qualified privilege from suit. Conclusory allegations were insufficient to state a claim.