prima facie showing privilege (Arizona) · Go Syfert
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prima facie showing privilege in Arizona

5 Arizona opinions name it 2 courts 2020–2026 4 in the last five years

The cases below were cited by Arizona 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 (4)

CaseFollowedCited
United States v. Zolingreen
scotus · 1989 · cited in 2 Arizona opinions naming this issue, 2022–2023
2 sentences

2023“Upon a prima facie showing of privilege, the party contesting the privilege must demonstrate a good faith basis that an in camera review . . . would reveal waiver of the privilege or establish an applicable exception.” Id. at 361 ¶ 15 (citing Clements, 249 Ariz. at 438 ¶ 1); see also United States v. Zolin, 491 U.S. 554, 572 (1989) (“Before engaging in in camera review to determine the applicability of the crime-fraud exception, ‘the judge should require a showing of a factual basis adequate to support a good faith belief by a reasonable person,’ that in camera review of the materials may rev

2022Clements, 249 Ariz. at 438 ¶ 1 (quoting United States v. Zolin, 491 U.S. 554, 572 (1989)).

22
Christopher Matthew Clements v. Hon. bernini/stategreen
ariz · 2020 · cited in 3 Arizona opinions naming this issue, 2022–2026
2 sentences

2023“Upon a prima facie showing of privilege, the party contesting the privilege must demonstrate a good faith basis that an in camera review . . . would reveal waiver of the privilege or establish an applicable exception.” Id. at 361 ¶ 15 (citing Clements, 249 Ariz. at 438 ¶ 1); see also United States v. Zolin, 491 U.S. 554, 572 (1989) (“Before engaging in in camera review to determine the applicability of the crime-fraud exception, ‘the judge should require a showing of a factual basis adequate to support a good faith belief by a reasonable person,’ that in camera review of the materials may rev

2023“Upon a prima facie showing of privilege, the party contesting the privilege must demonstrate a good faith basis that an in camera review . . . would reveal waiver of the privilege or establish an applicable exception.” Id. at 361 ¶ 15 (citing Clements, 249 Ariz. at 438 ¶ 1); see also United States v. Zolin, 491 U.S. 554, 572 (1989) (“Before engaging in in camera review to determine the applicability of the crime-fraud exception, ‘the judge should require a showing of a factual basis adequate to support a good faith belief by a reasonable person,’ that in camera review of the materials may rev

13
State of Arizona Ex Rel Adel v. Hon. Adlemangreen
ariz · 2022 · cited in 1 Arizona opinions naming this issue, 2022–2022
1 sentence

2022See Adleman, 252 Ariz. at 361 ¶ 15.

11
State v. Moodygreen
ariz · 2004 · cited in 1 Arizona opinions naming this issue, 2020–2020
1 sentence

2020See Moody, 208 Ariz. at 448-49 ¶¶ 76, 80; Warner, 150 Ariz. at 127 ; State v. Pecard, 196 Ariz. 371 , 378 ¶ 32 (App. 1999). ¶16 Here, as the proponent of the privilege, the burden to make a prima facie showing of privilege lies with Clements.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
State v. Warner green
ariz · 1986
1 sentence

2020See Moody, 208 Ariz. at 448-49 ¶¶ 76, 80; Warner, 150 Ariz. at 127 ; State v. Pecard, 196 Ariz. 371 , 378 ¶ 32 (App. 1999). ¶16 Here, as the proponent of the privilege, the burden to make a prima facie showing of privilege lies with Clements.

12020–2020
State v. Pecard green
arizctapp · 1999
1 sentence

2020See Moody, 208 Ariz. at 448-49 ¶¶ 76, 80; Warner, 150 Ariz. at 127 ; State v. Pecard, 196 Ariz. 371 , 378 ¶ 32 (App. 1999). ¶16 Here, as the proponent of the privilege, the burden to make a prima facie showing of privilege lies with Clements.

12020–2020

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 13-4062 (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

IN 40 (1920–2025) TX 28 (1997–2026) CA 23 (1962–2025) OR 13 (1921–2019) NM 7 (1993–2022) AZ 5 (2020–2026) MO 5 (1966–1994) HI 4 (2007–2022) WA 4 (1976–2018) MA 3 (2013–2017) FL 3 (1979–2023) GA 2 (1969–1978) IL 2 (1976–2022) DC 2 (2021–2021) WY 2 (2026–2026) KS 2 (1911–1968) MN 2 (2014–2014) LA 2 (1992–2009)

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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