What are the elements of a cause of action in professional negligence?

"The elements of a cause of action in tort for professional negligence are: (1) the duty of the professional to use such skill, prudence, and diligence as other members of his profession commonly possess and exercise; (2) a breach of that duty; (3) a proximate causal connection between the negligent conduct and the resulting injury; and (4) actual loss or damage resulting from the professional's negligence." (Budd v. Nixen (1971) 6 Cal.3d 195, 200, 98 Cal.Rptr. 849, 491 P.2d 433.) This dispute concerns the third element whether any loss suffered by plaintiff was proximately caused by defendant's negligence. California follows the majority rule that a malpractice plaintiff must prove not only negligence on the

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part of his or her attorney but that careful management of the case-within-a-case would have resulted in a favorable judgment "and collection of same ...." (Campbell v. Magana (1960) 184 Cal.App.2d 751, 754, 8 Cal.Rptr. 32, italics added.)