In
understanding the In re Grand Jury Subpoena case, it is important to
begin with the scope of the attorney-client privilege in cases of joint
representation of two individual clients. Normally the presence of a
non-privileged party at the time of a communication would make it
non-privileged. But that would mean that no communication when
representing two clients jointly would ever be privileged, because each
would destroy the other's privilege. This will not do. This is how the
Restatement of the Law Governing Lawyer puts the way this problem has
been resolved:
§ 75. The Privilege Of Co–Clients
(1)
If two or more persons are jointly represented by the same lawyer in a
matter, a communication of either co-client that otherwise qualifies as
privileged under §§ 68-72 [which are the normal requirements for the
privilege for an individual] and relates to matters of common interest
is privileged as against third persons, and any co-client may invoke
the privilege, unless it has been waived by the client who made the
communication.
(2) Unless the co-clients have agreed otherwise,
a communication described in Subsection (1) is not privileged as
between the co-clients in a subsequent adverse proceeding between them.
Notice
that this rule applies even concerning matters one co-client says to the
lawyer in private, provided that it concerns the matter of joint
representation.
Here is an example from the Restatement:
Client
X and Client Y jointly consult Lawyer about establishing a business,
without coming to any agreement about the confidentiality of their
communications to Lawyer. X sends a confidential memorandum to Lawyer
in which X outlines the proposed business arrangement as X understands
it. The joint representation then terminates, and Y knows that X sent
the memorandum but not its contents. Subsequently, Y files suit against
X to recover damages arising out of the business venture. Although X's
memorandum would be privileged against a third person, in the
litigation between X and Y the memorandum is not privileged. That
result follows although Y never knew the contents of the letter during
the joint representation.
Concerning actions by third parties
against X or Y, either can assert the privilege. It is generally
accepted that the waiver of the privilege as to third parties requires
all joint clients' consent, not just the consent of the client who made
the communication, despite the language in § 75(1) that the client
who makes the communication can waive it unilaterally. An the court put
it in In re Teleglobe Communications Corp., 493 F.3d 345 (3d Cir.
2007): "A wrinkle here is that a client may unilaterally waive the
privilege as to its own communications with a joint attorney, so long
as those communications concern only the waiving client; it may not,
however, unilaterally waive the privilege as to any of the other joint
clients' communications or as to any of its communications that relate
to other joint clients." See also Wright & Miller Federal Practice
and Procedure § 5505.
There is a similar rule for cases not involving joint representation, called the common interest privilege:
§ 76. The Privilege In Common–Interest Arrangements
(1)
If two or more clients with a common interest in a litigated or
nonlitigated matter are represented by separate lawyers and they agree
to exchange information concerning the matter, a communication of any
such client that otherwise qualifies as privileged under §§ 68-72 that
relates to the matter is privileged as against third persons. Any such
client may invoke the privilege, unless it has been waived by the
client who made the communication.
(2) Unless the clients have
agreed otherwise, a communication described in Subsection (1) is not
privileged as between clients described in Subsection (1) in a
subsequent adverse proceeding between them.
Now let us move on to joint representation of an entity and a
constituent. We know that, under the Model Rules, such joint
representation is possible. But if that is so, then how can we explain
the result in In re Grand Jury Subpoena? Doesn't that put greater
requirements for the assertion of an attorney-client privilege for an
individual in an joint representation context with an
organization/employer than in the usual context?
How is this puzzle solved by the notion, as Hazard puts it, by the
imputed-knowledge doctrine? And if it is solved, then didn't the lawyer
in the In re Grand Jury Subpoena case commit malpractice by not warning
his individual client's of this fact?