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Missouri Supreme Court Railroad Case’s Upjohn Analysis Goes Off the Tracks: Part II

Last week’s Privilege Point described the Missouri Supreme Court’s understandable conclusion that a railroad employee did not have a personal attorney-client relationship with railroad lawyers who interviewed her about an...more

No Lawyer Required: Part I

The very term “attorney-client privilege” would seem to necessitate a lawyer’s involvement in any communications deserving that evidentiary protection. But in some critical intra-corporate situations, the protection covers...more

Does Disclosing Legal Advice to Financial Advisors Waive Privilege? Part II

Last week’s Privilege Point described S.D.N.Y. Judge Lewis Liman’s conclusion that a company waived privilege protection for legal advice it received from its counsel by disclosing the advice to its financial advisor China...more

Another Court Finds Public Relations Consultants Outside Privilege Protection

Companies dealing with the pandemic (and finding themselves in pandemic-triggered future litigation) may seek public relations consultants’ assistance. Companies and their lawyers should remember that most courts reject...more

Can Non-Practicing Lawyers Ever Deserve Privilege Protection?

Attorney-client privilege protection normally involves a client and a lawyer. Must the “lawyer” side of that dialogue always be a fully authorized lawyer?...more

Can a Lawyer Represent Only a Subset of a Corporate Client’s Board?

All ethics and privilege issues in the corporate context start with a basic question -- who is the lawyer’s client? The default answer is that lawyers represent the incorporeal entity, acting through its “duly authorized”...more

Court Applies Unique Government Attorney-Client Privilege Principle

In the corporate world, the attorney-client privilege does not protect communications to or from corporate lawyers acting in a business role. An analogous principle can deprive governments of their attorney-client privilege...more

How Do Courts Decide If Employees CC'ing a Lawyer are Implicitly Seeking Legal Advice?

Electronic communications exacerbate judges' already difficult task of determining if employees copying lawyers on their communications with fellow employees are implicitly seeking legal advice – and thus deserve privilege...more

Court Affirms the Comforting Bevill Backstop

Lawyers representing corporations should in nearly every circumstance provide an Upjohn warning to avoid accidentally creating attorney-client relationships with company employees. Upjohn v. United States, 449 US 383 (1981)....more

What Client Agents Deserve Privilege Protection?

Nearly every court considers client agents outside privilege protection unless those agents are necessary for facilitating privileged communications between clients and their lawyers. Some courts occasionally take a broader...more

Southern District of New York Issues a Troublesome Corporate Privilege Case

Most courts applying privilege principles automatically treat wholly-owned subsidiaries' employees as if they were the parent's employees. However, occasionally courts take a narrower view. In Au New Haven, LLC v. YKK...more

Two Decisions Issued the Same Day Highlight Choice of Laws Issues: Part II

Last week's Privilege Point described a Maine case applying the narrow pre-Upjohn "control group" standard for corporate communications. Harris Mgmt., Inc. v. Coulombe, 2016 ME 166, ---A.3d---. Illinois is by far the largest...more

Two Decisions Issued the Same Day Highlight Choice of Laws Issues: Part I

Every privilege analysis should start with determining the applicable law. In the corporate context, federal courts handling federal question cases and nearly every state follow the Upjohn standard. Upjohn v. United States,...more

Court Nixes Privilege Protection for Former Employee Interviews – Is This a Big Deal?: Part III

The last two Privilege Points described the Washington Supreme Court's 5-4 rejection of privilege protection for communications with former corporate employees (Newman v. Highland School Dist., 186 Wash. 2d 769, 381 P.3d 1188...more

Court Nixes Privilege Protection for Former Employee Interviews – Is This a Big Deal?: Part II

Last week's Privilege Point described the Washington Supreme Court's 4-3 rejection of privilege protection for communications with former corporate employees.Newman v. Highland Sch. Dist., No. 90194-5, 2016 Wash. LEXIS 1135...more

Court Nixes Privilege Protection for Former Employee Interviews – Is This a Big Deal?: Part I

In a 4-3 vote, the Washington Supreme Court held that an institution's lawyers' communications with former employees did not deserve privilege protection. Newman v. Highland Sch. Dist., No. 90194-5, 2016 Wash. LEXIS 1135...more

Courts Wrestle with Work Product Protection for Interview-Related Documents: Part I

Companies' lawyers frequently interview third-party witnesses. Companies' adversaries often seek the resulting interview transcripts, notes, summaries, reports, statements or affidavits — which can generate disputes over fact...more

How Far Does the "Functional Equivalent" Standard Extend?

Many previous Privilege Points have addressed the corporate-friendly "functional equivalent" doctrine, under which non-employees who essentially act as employees are inside privilege protection. An equal number of Privilege...more

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