Legal malpractice actions often arise out of a client's belief that they were not adequately compensated in an underlying matter, and a belief that but for the actions of their attorney the client would have received something more. While many practitioners in Pennsylvania are aware of the Muhammad Doctrine that generally precludes clients from suing after settlement, legal malpractice complaints will often assert that a better settlement could have been achieved, but for the attorney's conduct. These cases can proceed outside of the Muhammad Doctrine if there was no settlement of the underlying action, or if the matter falls into one of the several exceptions to the Muhammad Doctrine. However, there is still a very good argument- with very good reasons behind it—that speculation regarding settlement cannot be the basis for damages in a legal malpractice action. It is almost always true that in order to succeed in a legal malpractice action in Pennsylvania, the plaintiff must prove that but for the attorney's alleged negligence they would have won the underlying action.