KRAKLIO v. SIMMONS

No. 16-1392.

909 N.W.2d 427 (2018)

Ray J. KRAKLIO, Appellant, v. Kent SIMMONS, Appellee.

Supreme Court of Iowa.

Filed March 16, 2018.


Attorney(s) appearing for the Case

Curtis R. Dial of Law Office of Curtis Dial, Keokuk, for appellant.

Alfredo Parrish of Parrish Kruidenier Dunn Boles Gribble Gentry Brown & Bergmann L.L.P., Des Moines, and Kent A. Simmons, Bettendorf, pro se, for appellee.


This appeal presents the narrow question of whether the relief-required rule (also called the exoneration rule) applies to a convicted criminal suing one of his defense attorneys for legal malpractice over an alleged missed opportunity to shorten his period of supervised probation. This rule ordinarily requires proof the client...

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