Extending Legal Malpractice Liability to Nonclients—The Washington Supreme Court Considers the Privity Requirement—Bowman v. John Doe Two, 104 Wn. 2d 181, 704 P.2d 140 (1985)

In Bowman v. John Doe Two, the Washington Supreme Court considered whether an attorney owes a duty of reasonable care to a third party in the absence of privity of contract. The attorney in Bowman represented a seventeen-year-old boy in juvenile court against charges brought by his mother. The boy\u27s mother subsequently sued the attorney for acts of professional negligence that allegedly resulted in injury to the parent-child relationship. The court in Bowman held that the attorney owed no duty to the parent. However, dicta in the opinion indicates that the privity requirement may soon be relaxed in Washington. The court suggested that in the future, an attorney\u27s duty to third parties in Washington may arise under one of two tests: a multi-criteria balancing test, or a third-party beneficiary test