California, United States of America
The following excerpt is from Wiley v. County of San Diego, 58 Cal.App.4th 434, 68 Cal.Rptr.2d 193 (Cal. App. 1997):
For these reasons, we decline to alter the traditional elements of a malpractice cause of action for claims arising out of criminal proceedings. (See also Duncan v. Campbell (App.1997) 123 N.M. 181, 936 P.2d 863, 865-868.)
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