attorney-client privilege (Iowa) · Go Syfert
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attorney-client privilege in Iowa

39 Iowa opinions name it 2 courts 1969–2024 3 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (55)

CaseFollowedCited
Horsfield Materials, Inc. v. City of Dyersvillegreen
iowa · 2013 · cited in 2 Iowa opinions naming this issue, 2016–2024
2 sentences

2024Dist., 569 N.W.2d 125, 127 (Iowa 1997) (en banc); see also Horsfield, 834 N.W.2d at 463 (recognizing the City of Dyersville “properly asserted the attorney- client privilege”).

2024We extended this holding to documents broadly protected by the attorney–client privilege in Horsfield, where we held that Iowa Code section 622.10 protected emails exchanged with counsel for the City of Dyersville notwithstanding section 22.2’s disclosure requirement. 834 N.W.2d at 450–51, 463 (“[T]he [Open Records] Act does not affect other specific statutory privileges recognized by the legislature, such as the attorney-client privilege.”).

22
Squealer Feeds v. Pickeringgreen
iowa · 1995 · cited in 2 Iowa opinions naming this issue, 2004–2018
2 sentences

2018Id. at 684-85 (noting a withdrawal of the witness designation would "reestablish the attorney-client privilege").

2004The attorney-client privilege protects against the disclosure of “ ‘[a]ny confidential communication between an attorney and the attorney’s client ... against the will of the client.’ ” Squealer Feeds v. Pickering, 530 N.W.2d 678, 684 (Iowa 1995) (citation omitted).

22
State v. Tensleygreen
iowa · 1977 · cited in 2 Iowa opinions naming this issue, 1984–2017
2 sentences

2017See State v. Tensley, 249 N.W.2d 659, 661 (Iowa 1977).

1984State v. Tensley, 249 N.W.2d 659, 661-62 (Iowa 1977).

22
Bengford Ex Rel. Bengford v. Carlem Corp.green
iowa · 1968 · cited in 2 Iowa opinions naming this issue, 2015–2015
2 sentences

2015On the other hand, the work product concept refers to material prepared or acquired in anticipation of litigation not necessarily privileged but immune from discovery . . . .” (Citation omitted.)); Bengford v. Carlem Corp., 156 N.W.2d 855, 867 (Iowa 1968) (“[S]uch questions are not objectionable either as privileged or work product.”); Schaap v. Chi. & N.W.

2015On the other hand, the work product concept refers to material prepared or acquired in anticipation of litigation not necessarily privileged but immune from discovery....” (Citation omitted.)); Bengford v. Carlem Corp., 156 N.W.2d 855, 867 (Iowa 1968) (“[S]uch questions are not objectionable either as privileged or work product.”); Schaap v. Chi. & N.W.

22
In Re the Rules of Professional Conductgreen
mont · 2000 · cited in 2 Iowa opinions naming this issue, 2010–2010
2 sentences

2010See Emle Indus., Inc. v. Patentex, Inc., 478 F.2d 562 , 572-73 (2d Cir.1973) ("[T]he client's privilege in confidential information disclosed to his attorney `is not nullified by the fact that the circumstances to be disclosed are part of a public record, or that there are other available sources for such information, or by the fact that the lawyer received the same information from other sources.'" (quoting Henry S. Drinker, Legal Ethics 135 (1953))); In re Rules of Prof'l Conduct & Insurer Imposed Billing Rules & Procedures, 299 Mont. 321 , 2 P.3d 806, 822 (2000) (holding rule of confidentia

2010See Emle Indus., Inc. v. Patentex, Inc., 478 F.2d 562 , 572-73 (2d Cir.1973) ("[T]he client's privilege in confidential information disclosed to his attorney `is not nullified by the fact that the circumstances to be disclosed are part of a public record, or that there are other available sources for such information, or by the fact that the lawyer received the same information from other sources.'" (quoting Henry S. Drinker, Legal Ethics 135 (1953))); In re Rules of Prof'l Conduct & Insurer Imposed Billing Rules & Procedures, 299 Mont. 321 , 2 P.3d 806, 822 (2000) (holding rule of confidentia

22
Emle Industries, Inc. v. Patentex, Inc.green
ca2 · 1973 · cited in 2 Iowa opinions naming this issue, 2010–2010
2 sentences

2010See Emle Indus., Inc. v. Patentex, Inc., 478 F.2d 562 , 572-73 (2d Cir.1973) (“[T]he client’s privilege in confidential information disclosed to his attorney ‘is not nullified by the fact that the circumstances to be disclosed are part of a public record, or that there are other available sources for such information, or by the fact that the lawyer received the same information from other sources.’ ” (quoting Henry S. Drinker, Legal Ethics 135 (1953))); In re Rules of Prof'l Conduct & Insurer Imposed Billing Rules & Procedures, 299 Mont. 321 , 2 P.3d 806, 822 (2000) (holding rule of confidenti

2010See Emle Indus., Inc. v. Patentex, Inc., 478 F.2d 562 , 572-73 (2d Cir.1973) ("[T]he client's privilege in confidential information disclosed to his attorney `is not nullified by the fact that the circumstances to be disclosed are part of a public record, or that there are other available sources for such information, or by the fact that the lawyer received the same information from other sources.'" (quoting Henry S. Drinker, Legal Ethics 135 (1953))); In re Rules of Prof'l Conduct & Insurer Imposed Billing Rules & Procedures, 299 Mont. 321 , 2 P.3d 806, 822 (2000) (holding rule of confidentia

22
Samaritan Foundation v. Goodfarbgreen
ariz · 1993 · cited in 2 Iowa opinions naming this issue, 2009–2009
2 sentences

2009Id. at 880–81.

2009See Samaritan Found., 862 P.2d at 876 (“It is universally accepted that communications directly initiated by an employee to corporate counsel seeking legal advice on behalf of the corporation are privileged.”).

22
Diversified Industries, Inc. v. The Honorable James H. Meredith, Chief Judge of the United States District Court for the Eastern District of Missourigreen
ca8 · 1978 · cited in 2 Iowa opinions naming this issue, 2009–2009
2 sentences

2009Id. at 609 .

2009Cf. Diversified, 572 F.2d at 609 (material protected if “not disseminated beyond those persons who, because of the corporate structure, need to know its contents” (emphasis added)).

22
In the Matter of Grand Jury Proceeding. Appeal of Marty Bartongreen
ca7 · 1995 · cited in 2 Iowa opinions naming this issue, 2008–2008
2 sentences

2008However, "[a] client does not lose the [attorney-client] privilege merely because his attorney serves a dual role." In re Matter of Grand Jury Proceeding, 68 F.3d 193, 196 (7th Cir.1995).

2008However, “[a] client does not lose the [attorney-client] privilege merely because his attorney serves a dual role.” In re Matter of Grand Jury Proceeding, 68 F.3d 193, 196 (7th Cir.1995).

22
Bailey v. Chicago, Burlington & Quincy Railroad Co.green
iowa · 1970 · cited in 3 Iowa opinions naming this issue, 1971–2024
2 sentences

2024Iowa has enshrined its attorney–client privilege in Iowa Code 16 section 622.10, and our caselaw recognizes that this provision effectuates a priv- ilege “of ancient origin.” Bailey v. Chi., Burlington & Quincy R.R., 179 N.W.2d 560, 563 (Iowa 1970).

1971Such prohibition shall not apply to cases where the party in whose favor the same is made waives the rights conferred.” In Bailey v. Chicago, Burlington & Quincy Railroad Co., Iowa, 179 N.W.2d 560 , filed September 2, 1970, supported by many cited authorities, we analyze and discuss the purpose, necessity and importance of the attorney-client privilege.

13
Shook v. CITY OF DAVENPORT, IOWAgreen
iowa · 1993 · cited in 3 Iowa opinions naming this issue, 2009–2021
2 sentences

2021Our law recognizes that a “confidential communication between an attorney and the attorney’s client is absolutely privileged from disclosure against the will of the client.” Fenceroy, 903 N.W.2d at 242–43 (citing Shook v. City of Davenport, 497 N.W.2d 883, 886 (Iowa 1993), abrogated on other grounds by Wells Dairy, Inc. v. Am.

2009“Any confidential communication between an attorney and the attorney’s client is absolutely privileged from disclosure against the will of the client.” Shook, 497 N.W.2d at 886 .

13
Robbins v. IOWA-ILLINOIS GAS AND ELECTRIC COMPANYgreen
iowa · 1968 · cited in 3 Iowa opinions naming this issue, 2014–2015
2 sentences

2015Co., 160 N.W.2d 847 , 855–56 (Iowa 1968) (“[T]he work product of an attorney is clearly distinguishable from the attorney-client privilege.

2015Co., 160 N.W.2d 847, 855-56 (Iowa 1968) (“[T]he work product of an attorney is clearly distinguishable from the attorney-client privilege.

13
Walker v. County of Contra Costagreen
cand · 2005 · cited in 2 Iowa opinions naming this issue, 2018–2021
2 sentences

2021“If Defendants assert as an affirmative defense the adequacy of their pre-litigation investigation into Walker’s claims of discrimination, then they waive the attorney-client privilege and the work product doctrine with respect to documents reflecting that investigation.” Id. (emphasis added).

2018Colo. 2008) ("The Court agrees that to the extent that Defendants have asserted the Faragher / Ellerth affirmative defense, they have waived the protections of the attorney-client privilege and work product doctrine regarding investigations into complaints made by female employees."); Walker v. County of Contra Costa , 227 F.R.D. 529 , 535 (N.D.

12
Upjohn Co. v. United Statesgreen
scotus · 1981 · cited in 2 Iowa opinions naming this issue, 2009–2009
2 sentences

2009Upjohn Co. v. United States, 449 U.S. 383, 390 , 101 S. Ct. 677, 683 , 66 L.

2009Upjohn Co. v. United States, 449 U.S. 383, 390 , 101 S. Ct. 677, 683 , 66 L.

12
State v. Craneygreen
iowa · 1984 · cited in 2 Iowa opinions naming this issue, 1988–1994
2 sentences

1994Craney, 347 N.W.2d at 679 .

1988In State v. Craney, 347 N.W.2d 668 (Iowa 1984), the supreme court reviewed Alvarez and expressly rejected a “constitutionalized attorney-client privilege for a defendant’s communications to a mental expert” Id. at 677-78.

12
Tausz v. Clarion-Goldfield Community School Districtgreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2024–2024
1 sentence

2024Dist., 569 N.W.2d 125, 127 (Iowa 1997) (en banc); see also Horsfield, 834 N.W.2d at 463 (recognizing the City of Dyersville “properly asserted the attorney- client privilege”).

11
United States v. Zolingreen
scotus · 1989 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022“It is the purpose of the crime-fraud exception to the attorney-client privilege to assure that the ‘seal of secrecy’ between lawyer and client does not extend to communications ‘made for the purpose of getting advice for the commission of a fraud’ or a crime.” United States v. Zolin, 491 U.S. 554, 563 (1989) (citations omitted).

11
In Re BANKAMERICA CORP. SECURITIES LITIGATION Petition of Bank of America Corporationgreen
ca8 · 2001 · cited in 1 Iowa opinions naming this issue, 2022–2022
1 sentence

2022Litig., 270 F.3d 639, 642 (8th Cir. 2001).

11
In Re Grand Jury Investigationgreen
vaed · 2006 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020If the desired testimony is of marginal value, the grand jury can pursue other avenues of inquiry; if the testimony is thought sufficiently important, the grand jury can seek a judicial determination as to the bona fides of the witness’ Fifth Amendment claim . . . .”); In re Grand Jury Subpoena, 831 F.2d 225, 227, 228 (11th Cir. 1987) (holding “an attorney seeking to quash a subpoena must assert the attorney-client privilege on a document-by-document basis” and reversing district court order quashing grand jury subpoena); In re Grand Jury Investigation, 431 F. Supp. 2d 584, 592 (E.D.

11
MATTER OF BEACH v. Shanleygreen
ny · 1984 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020Instead, the attorney should be called upon to appear and assert the attorney-client privilege after hearing the question or questions addressed to him.” (Citation omitted.)); Beach v. Shanley, 465 N.E.2d 304, 307 (N.Y. 1984) (“To the extent that a subpoena seeks testimony, the assertion that the contemplated testimony is subject to a privilege will not usually justify quashing the subpoena.

11
In Re Grand Jury Subpoena. Appeal of United States of Americagreen
ca11 · 1987 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020If the desired testimony is of marginal value, the grand jury can pursue other avenues of inquiry; if the testimony is thought sufficiently important, the grand jury can seek a judicial determination as to the bona fides of the witness’ Fifth Amendment claim . . . .”); In re Grand Jury Subpoena, 831 F.2d 225, 227, 228 (11th Cir. 1987) (holding “an attorney seeking to quash a subpoena must assert the attorney-client privilege on a document-by-document basis” and reversing district court order quashing grand jury subpoena); In re Grand Jury Investigation, 431 F. Supp. 2d 584, 592 (E.D.

11
Movants to Quash Grand Jury Subpoenas v. Powersgreen
okla · 1992 · cited in 1 Iowa opinions naming this issue, 2020–2020
1 sentence

2020In that event, litigation must await such time as when the witness refuses to answer the question on the ground that privileged information is concerned and an attempt is made to compel a response.” (Citations omitted.)); Movants to Quash Grand Jury Subpoenas v. Powers, 839 P.2d 655, 657 (Okla. 1992) (“We hold that assuming, but without deciding, that while such a First Amendment privilege may come into existence under particular facts, it does not authorize the quashing of these grand jury subpoenas.

11
Hoffman v. Outback Steakhouse of Florida, Inc.green
cod · 2008 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Ind. June 2, 2009) (“[A] defendant may also waive the attorney-client privilege if it asserts its investigation as part of its defense.”); EEOC v. Outback Steakhouse of Fla., Inc., 251 F.R.D. 603, 612 (D.

2018Ind. June 2, 2009) ("[A] defendant may also waive the attorney-client privilege if it asserts its investigation as part of its defense."); EEOC v. Outback Steakhouse of Fla., Inc. , 251 F.R.D. 603 , 612 (D.

11
Harding v. Dana Transport, Inc.green
njd · 1996 · cited in 1 Iowa opinions naming this issue, 2018–2018
11
Reitz v. City of Mt. Julietgreen
tnmd · 2010 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Juliet, 680 F. Supp. 2d 888, 894 (M.D.

2018Juliet , 680 F.Supp.2d 888 , 894 (M.D.

11
Union County v. Piper Jaffray & Co.green
iasd · 2008 · cited in 1 Iowa opinions naming this issue, 2017–2017
11
Andrews v. Ridco & Twin City Fire Ins. Co.green
sd · 2015 · cited in 1 Iowa opinions naming this issue, 2017–2017
11
Avgoustis v. Shinsekigreen
cafc · 2011 · cited in 1 Iowa opinions naming this issue, 2016–2016
11
Johnny Lee Johnson, applicant-appellee/cross-appellant v. State of Iowa, respondent-appellant/cross-appellee.green
iowactapp · 2014 · cited in 1 Iowa opinions naming this issue, 2016–2016
11
Foster v. Hillgreen
ca10 · 1999 · cited in 1 Iowa opinions naming this issue, 2014–2014
11
Gutshall v. New Prime, Inc.green
vawd · 2000 · cited in 1 Iowa opinions naming this issue, 2014–2014
11
Burton v. University of Iowa Hospitals & Clinicsgreen
iowa · 1997 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
People v. Smaysgreen
nysupct · 1993 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
Wemark v. Stategreen
iowa · 1999 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
People v. Ianniellogreen
ny · 1968 · cited in 1 Iowa opinions naming this issue, 2013–2013
11
Tahoe Regional Planning Agency v. Brian McKay Attorney General of the State of Nevadagreen
ca9 · 1985 · cited in 1 Iowa opinions naming this issue, 2012–2012
11
In Re Advisory Opinion No. 544 of the New Jersey Supreme Court Advisory Committee on Professional Ethicsgreen
nj · 1986 · cited in 1 Iowa opinions naming this issue, 2010–2010
11
Freedman v. Coopergreen
nj · 1941 · cited in 1 Iowa opinions naming this issue, 2010–2010
11
Alpha Beta Co. v. Superior Courtgreen
calctapp · 1984 · cited in 1 Iowa opinions naming this issue, 2004–2004
11
Hickman v. Taylorgreen
scotus · 1947 · cited in 1 Iowa opinions naming this issue, 2004–2004
11

Distinguished, questioned or overruled (2)

CaseNegativeCited
Robbins v. IOWA-ILLINOIS GAS AND ELECTRIC COMPANYgreen
iowa · 1968 · cited in 3 Iowa opinions naming this issue, 2014–2015
2 sentences

2015Co., 160 N.W.2d 847 , 855–56 (Iowa 1968) (“[T]he work product of an attorney is clearly distinguishable from the attorney-client privilege.

2015Co., 160 N.W.2d 847, 855-56 (Iowa 1968) (“[T]he work product of an attorney is clearly distinguishable from the attorney-client privilege.

13
Brainerd Daily Dispatch v. Dehengreen
minnctapp · 2005 · cited in 1 Iowa opinions naming this issue, 2015–2015
11

Also cited on this issue (16)

CaseCitedYears
Bernard M. Decker, United States District Judge v. Harper & Row Publishers, Inc. green
scotus · 1971
2 sentences

2009We need not reach this issue, however, because we hold below that the memorandum was not protected by McFarland Clinic’s attorney-client privilege. 12 v. Decker, 423 F.2d 487 (7th Cir. 1970), aff’d by an equally divided court, 400 U.S. 348 , 91 S. Ct. 479 , 27 L.

2009We need not reach this issue, however, because we hold below that the memorandum was not protected by McFarland Clinic’s attorney-client privilege. 12 v. Decker, 423 F.2d 487 (7th Cir. 1970), aff’d by an equally divided court, 400 U.S. 348 , 91 S. Ct. 479 , 27 L.

22009–2009
Harper & Row Publishers, Inc. v. Honorable Bernard M. Decker, United States District Judge green
ca7 · 1970
2 sentences

2009In Harper & Row Publishers, Inc. v. Decker, 423 F.2d 487 (7th Cir.1970), aff'd by an equally divided court, 400 U.S. 348 , 91 S.Ct. 479 , 27 L.Ed.2d 433 (1971), the Seventh Circuit rejected the “control group” test.

2009We need not reach this issue, however, because we hold below that the memorandum was not protected by McFarland Clinic’s attorney-client privilege. 12 v. Decker, 423 F.2d 487 (7th Cir. 1970), aff’d by an equally divided court, 400 U.S. 348 , 91 S. Ct. 479 , 27 L.

22009–2009
Kracht v. Perrin, Gartland & Doyle green
calctapp · 1990
1 sentence

2020Kracht, 268 Cal. Rptr. at 640–41.

12020–2020
Blumenthal Investment Trusts v. City of West Des Moines green
iowa · 2001
2 sentences

2019Viewing the facts in the light most favorable to the plaintiffs, we conclude the district properly granted the defendants’ motion for summary judgment on claims IV and VI to the extent those claims allege the defendants deprived the Blazek family of their substantive due process rights under article I, section 9 of the Iowa Constitution. “[U]nder substantive due process analysis, the state is 13 given great leeway in achieving its legitimate goals, particularly related to public safety.” Id. (citing Mackey v. Montrym, 443 U.S. 1 , 17–19 (1979)).

2019Situations that meet the shocks-the- conscience test include “outrageous utilization of physical force; state-sponsored imposition of uncalled-for embarrassment or ridicule; or intolerable, disreputable, and underhanded tactics that may arise from government action deliberately designed to penetrate the attorney-client privilege.” Id.

12019–2019
MacKey v. Montrym green
scotus · 1979
1 sentence

2019Viewing the facts in the light most favorable to the plaintiffs, we conclude the district properly granted the defendants’ motion for summary judgment on claims IV and VI to the extent those claims allege the defendants deprived the Blazek family of their substantive due process rights under article I, section 9 of the Iowa Constitution. “[U]nder substantive due process analysis, the state is 13 given great leeway in achieving its legitimate goals, particularly related to public safety.” Id. (citing Mackey v. Montrym, 443 U.S. 1 , 17–19 (1979)).

12019–2019
McGrath v. Nassau County Health Care Corp. green
nyed · 2001
12018–2018
Wells Dairy, Inc. v. American Industrial Refrigeration, Inc. green
iowa · 2004
1 sentence

2018Id.

12018–2018
Keefe v. Bernard green
iowa · 2009
12017–2017
State v. Tate green
iowa · 2006
12016–2016
City of Coralville v. Iowa District Court for Johnson County green
iowa · 2001
12004–2004
Dillon v. City of Davenport green
iowa · 1985
11997–1997
Sacramento Newspaper Guild, Local 92 v. Sacramento County Board of Supervisors green
calctapp · 1968
11997–1997
United States v. Wilfredo Alvarez Appeal of John A/K/A Jorge Martinez green
ca3 · 1975
11988–1988
State v. Mickle green
iowa · 1925
11984–1984
Dunn v. Commonwealth green
kyctapphigh · 1961
11971–1971
State Ex Rel. Schuler v. Tahash green
minn · 1967
11969–1969

Statutes the citing opinions construe

IA § Iowa Code § 622.10 (10) IA § Iowa Code § 17A.19 (4) IA § Iowa Code § 22.10 (4) IA § Iowa Code § 22.7 (4) IA § Iowa Code § 17A.9 (3) IA § Iowa Code § 22.2 (3) IA § Iowa Code § 22.8 (3) IA § Iowa Code § 4.4 (3) IA § Iowa Code § 804.20 (3) IA § Iowa Code § 85.27 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 532 (1954–2026) NY 467 (1952–2026) TX 375 (1972–2026) IL 319 (1956–2026) PA 304 (1976–2026) OH 291 (1971–2026) FL 270 (1967–2026) NJ 171 (1953–2026) WA 167 (1964–2025) MA 138 (1973–2025) CT 134 (1963–2024) CO 109 (1968–2026) MI 98 (1953–2025) AZ 97 (1964–2026) MO 88 (1971–2024) NC 85 (1973–2026) MD 81 (1968–2025) IN 78 (1976–2025) GA 78 (1974–2025) DE 74 (1963–2026) AL 71 (1971–2024) OR 63 (1974–2026) LA 62 (1973–2026) KY 55 (1979–2026) MN 52 (1954–2026) WV 50 (1986–2025) NV 49 (1975–2024) VA 46 (1978–2026) NM 42 (1967–2026) IA 39 (1969–2024) DC 38 (1979–2025) MS 38 (1974–2024) NH 36 (1966–2025) AK 34 (1974–2025) MT 34 (1972–2025) TN 34 (1976–2023) WI 33 (1974–2025) RI 30 (1978–2017) HI 28 (1980–2026) SC 28 (1977–2024) KS 27 (1959–2022) ME 19 (1977–2024) OK 19 (1976–2026) UT 19 (1990–2023) ID 18 (1977–2024) SD 17 (1966–2026) WY 14 (1985–2022) NE 14 (1979–2020) AR 13 (1971–2013) VT 12 (1986–2025) ND 11 (1963–2022) VI 5 (1990–2026) PR 2 (2006–2013)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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