Does an attorney have a duty to non-clients?

The Court of Appeals of Kentucky has issued an opinion that illustrates one of the few instances where attorneys are sometimes held to owe a duty to a non-client. In that case, the court held that although the plaintiff was not a client, the attorney owed a duty because the plaintiff may have been an intended beneficiary of the lawyers' conduct and the lawyers failed to do a proper title search. The case is called Tipton v. Porter and it is available here.

Meanwhile, a court in New Jersey reached the opposite result in a case called Holvenstot v. Nusbaum (available here).