Harline’s sole claim in these proceedings is that Vlahos’ initial failure to list assets that Harline disclosed to the firm caused Harline’s denial of discharge. However, “[d]emonstrating material issues of fact with respect to defendants’ negligence is not sufficient to preclude summary judgment if there is no evidence that establishes a direct causal connection between that alleged negligence and the injury.” Mitchell, 697 P.2d at 245. Under the doctrine of issue preclusion, the bankruptcy court’s finding that Harline acted with fraudulent intent despite his reliance on Vlahos is binding. That finding defeats the causation element of Harline’s negligence claim against Vlahos, thereby defeating the malpractice claim. See Lane v. Sullivan, 900 F.2d 1247, 1250-51 & n. 5 (8th Cir.) (<HOLDING>), cert. denied, 498 U.S. 847, 111 S.Ct. 134,
holding transfer restriction granted right of first refusal in event of voluntary or involuntary transfer of stock holding that earlier judgment that plaintiffs understood a stock transfer precluded malpractice claim against attorney for misrepresenting or failing to represent true nature of transfer holding that transfer was proper remedy for improper venue even though the issue of transfer was not raised until the motion hearing in circuit court holding stock transfer restriction in corporate bylaws did not prevent levy against and sale of stock by third party in order to pay judgment holding that the failure to condition a transfer on death or remarriage of the wife was a factor showing that the transfer was not in the nature of alimony