The concept of negligence was late in developing in the common law. Perhaps the first group of cases in which the idea began to take shape involved the liability of persons who professed competence in certain callings.' One of these "callings" was that of the attorney,and cases as early as the middle of the eighteenth century hold an attorney liable on this basis.
John W. Wade,
The Attorney's Liability for Negligence,
12 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol12/iss3/9