Mr. Meyer and Ms. Bartolucci on appeal, recently obtained an appellate affirmance of the dismissal of a legal malpractice case in Healy v. Worobec, et al (DuPage County; Appellate Court, Second District (Rule 23 Order)). In Healy, the plaintiff claimed that the attorneys he retained subsequent to a criminal plea to challenge his sentencing failed to properly explore all avenues of relief, specifically a Strickland argument. The attorneys denied that Strickland relief was even available given the facts of the case, but moved to dismiss the legal malpractice case against them on the theory espoused by Illinois courts that a criminally convicted legal malpractice plaintiff cannot plead a cause of action unless he can also plead, and eventually prove, that he was actually innocent of the crime for which he was convicted. The trial court agreed and dismissed the legal malpractice case against the post-conviction lawyers, and the appellate court recently affirmed that dismissal.