Whether the circuit court improperly determined the operative bar date for claim preclusion in conflict with prior Supreme Court and Third Circuit precedents

1 Whether the circuit court improperly determined that a subsequent pleading rather than the initial complaint, is the operative bar date for claim preclusion in conflict with Lawlor v. National Screen Service Corp. , 349 U.S. 322 (1955), Lucky Brand Dungarees, Inc. v. Marcel Fashions Group, Inc. , 590 U.S. 405 (2020), and the Third Circuit’s own precedent in Morgan v. Covington Township , 648 F.3d 172 (3d Cir. 2011) . Question 2 Whether the Due Process Clause is violated when a court dismisses a legal-malpractice claim with prejudice at the pleading stage by resolving a disputed factual issue concerning the existence of an attorney–client relationship against the plaintiff, notwithstanding documentary evidence submitted in opposition to dismissal, without leave to amend. Question 3 Whether, under Semtek International Inc. v. Lockheed Martin Corp. , 531 U.S. 497 (2001), federal courts must apply the forum state’s claim-preclusion and accrual rules when evaluating state-law claims, rather than federal common-law preclusion principles.