work product doctrine (Montana) · Go Syfert
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work product doctrine in Montana

20 Montana opinions name it 1 courts 1981–2018 0 in the last five years

The cases below were cited by Montana 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 (9)

CaseFollowedCited
United States v. Noblesgreen
scotus · 1975 · cited in 4 Montana opinions naming this issue, 1988–2013
2 sentences

2013Work-Product Privilege ¶37 Ugalde argues that ‘[Dr.] Dale’s disclosures violated work-product privilege, resulting in unfair and irremediable prejudice to her case.” The work-product doctrine protects against the disclosure of ‘the mental processes of an attorney, providing a privileged area within which [the attorney] can analyze and prepare [a] client’s case.” State v. Miller, 231 Mont. 497, 513 , 757 P.2d 1275, 1285 (1988) (citing U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ‘The reality of our legal system demands that the embraces of the protection also extend to agen

2013Work-Product Privilege ¶37 Ugalde argues that ‘[Dr.] Dale’s disclosures violated work-product privilege, resulting in unfair and irremediable prejudice to her case.” The work-product doctrine protects against the disclosure of ‘the mental processes of an attorney, providing a privileged area within which [the attorney] can analyze and prepare [a] client’s case.” State v. Miller, 231 Mont. 497, 513 , 757 P.2d 1275, 1285 (1988) (citing U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ‘The reality of our legal system demands that the embraces of the protection also extend to agen

24
Hickman v. Taylorgreen
scotus · 1947 · cited in 4 Montana opinions naming this issue, 1981–2012
2 sentences

2012By contrast, the work product doctrine serves the adversarial process directly ‘by enabling attorneys to prepare cases without fear that their work product will be used against their clients.” Westinghouse, 951 F.2d at 1428 (citing Hickman v. Taylor, 329 U.S. 495, 510-11 , 67 S. Ct. 385, 393-94 (1947)).

2012By contrast, the work product doctrine serves the adversarial process directly ‘by enabling attorneys to prepare cases without fear that their work product will be used against their clients.” Westinghouse, 951 F.2d at 1428 (citing Hickman v. Taylor, 329 U.S. 495, 510-11 , 67 S. Ct. 385, 393-94 (1947)).

14
State v. Millergreen
mont · 1988 · cited in 1 Montana opinions naming this issue, 2013–2013
2 sentences

2013Work-Product Privilege ¶37 Ugalde argues that ‘[Dr.] Dale’s disclosures violated work-product privilege, resulting in unfair and irremediable prejudice to her case.” The work-product doctrine protects against the disclosure of ‘the mental processes of an attorney, providing a privileged area within which [the attorney] can analyze and prepare [a] client’s case.” State v. Miller, 231 Mont. 497, 513 , 757 P.2d 1275, 1285 (1988) (citing U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ‘The reality of our legal system demands that the embraces of the protection also extend to agen

2013Work-Product Privilege ¶37 Ugalde argues that ‘[Dr.] Dale’s disclosures violated work-product privilege, resulting in unfair and irremediable prejudice to her case.” The work-product doctrine protects against the disclosure of ‘the mental processes of an attorney, providing a privileged area within which [the attorney] can analyze and prepare [a] client’s case.” State v. Miller, 231 Mont. 497, 513 , 757 P.2d 1275, 1285 (1988) (citing U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ‘The reality of our legal system demands that the embraces of the protection also extend to agen

11
Cantrell v. Hendersongreen
mont · 1986 · cited in 1 Montana opinions naming this issue, 2013–2013
2 sentences

2013Cantrell v. Henderson, 221 Mont. 201, 208 , 718 P.2d 318, 322 (1986).

2013Cantrell v. Henderson, 221 Mont. 201, 208 , 718 P.2d 318, 322 (1986).

11
In Re Grand Jury Subpoenagreen
ca1 · 2001 · cited in 1 Montana opinions naming this issue, 2012–2012
2 sentences

2012“Common sense suggests that there can be no joint defense agreement when there is no joint defense to pursue.” In re Grand Jury Subpoena, 274 F.3d 563, 575 (1st Cir. 2001). ¶29 The District Court did not apply the correct legal standard to the work product analysis, but it reached the proper conclusion.

2012Given the law expressly excluding Roscoe from participation in and liability for the claim, there could be no basis for either a confidentiality agreement or assurances of confidentiality. ‘Common sense suggests that there can be no joint defense agreement when there is no joint defense to pursue.” In re Grand Jury Subpoena, 274 F.3d 563, 575 (1st Cir. 2001). ¶29 The District Court did not apply the correct legal standard to the work product analysis, but it reached the proper conclusion.

11
Westinghouse Electric Corporation v. The Republic Of The Philippinesgreen
ca3 · 1991 · cited in 1 Montana opinions naming this issue, 2012–2012
2 sentences

2012By contrast, the work product doctrine serves the adversarial process directly “by enabling attorneys to prepare cases without fear that their work product will be used against their clients.” Westinghouse, 951 F.2d at 1428 (citing Hickman v. Taylor, 329 U.S. 495, 510-11 , 67 S. Ct. 385, 393-94 (1947)).

2012By contrast, the work product doctrine serves the adversarial process directly ‘by enabling attorneys to prepare cases without fear that their work product will be used against their clients.” Westinghouse, 951 F.2d at 1428 (citing Hickman v. Taylor, 329 U.S. 495, 510-11 , 67 S. Ct. 385, 393-94 (1947)).

11
Boettcher v. Montana Guaranty Fundgreen
mont · 2007 · cited in 1 Montana opinions naming this issue, 2008–2008
2 sentences

2008See Boettcher v. Montana Guaranty Fund, 2007 MT 69, ¶ 14 , 336 Mont. 393, ¶ 14 , 154 P.3d 629, ¶ 14 . 10 Of course, we recognize that some portions of an insurer’s records may be inadmissible pursuant to overriding rules regarding the work-product doctrine or the attorney-client privilege.

2008See Boettcher v. Montana Guaranty Fund, 2007 MT 69, ¶ 14 , 336 Mont. 393, ¶ 14 , 154 P.3d 629, ¶ 14 . 10 Of course, we recognize that some portions of an insurer’s records may be inadmissible pursuant to overriding rules regarding the work-product doctrine or the attorney-client privilege.

11
United States v. MITgreen
ca1 · 1997 · cited in 1 Montana opinions naming this issue, 2000–2000
1 sentence

2000On cross-appeal, the IRS argued that the district court erred in concluding that the three minutes contained privileged material. ¶60 The court in Mass. Inst. of Technology concluded that “decisions do tend to mark out, although not with perfect consistency, a small circle of‘others’ with whom information may be shared without loss of the privilege (e.g., secretaries, interpreters, counsel for a cooperating co-defendant, a parent present when a child consults a lawyer).” Mass. Inst. of Technology, 129 F.3d at 684.

11
Admiral Insurance Company v. United States District Courtgreen
ca9 · 1989 · cited in 1 Montana opinions naming this issue, 1989–1989
2 sentences

1989As Professor Saltzburg explained: “ ‘The principal difference between the attorney-client privilege and the work product doctrine, in terms of the protections each provides, is that the privilege cannot be overcome by a showing of need, whereas a showing of need may justify discovery of an attorney’s work product.’ Saltzburg, Corporate and Related Attorney-Client Privilege: A Suggested Approach, 12 Hofstra, L.Rev. 279, 299 (1984).” Admiral Ins., 881 F.2d at 1494-95. * * * “The attorney-client privilege, like all other evidentiary privileges, may obstruct a party’s access to the truth.

1989As Professor Saltzburg explained: “ ‘The principal difference between the attorney-client privilege and the work product doctrine, in terms of the protections each provides, is that the privilege cannot be overcome by a showing of need, whereas a showing of need may justify discovery of an attorney’s work product.’ Saltzburg, Corporate and Related Attorney-Client Privilege: A Suggested Approach, 12 Hofstra, L.Rev. 279, 299 (1984).” Admiral Ins., 881 F.2d at 1494-95. * * * “The attorney-client privilege, like all other evidentiary privileges, may obstruct a party’s access to the truth.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (10)

CaseCitedYears
Kuiper v. District Court of the Eighth Judicial District green
mont · 1981
2 sentences

2013The core purpose of the work product doctrine is to “ ‘shelter[ ] the mental processes of the attorney, providing a privileged area within which he can analyze and prepare his client’s case.’ ”Palmer by Diacon, 261 Mont. at 116 , 861 P.2d at 910 (quoting U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ¶45 In Kuiper , we held that work product protects ‘impressions [of an attorney] rendered during the investigation of a claim where no litigation is in progress.” 193 Mont, at 465 , 632 P.2d at 701 .

2013The core purpose of the work product doctrine is to “ ‘shelter[ ] the mental processes of the attorney, providing a privileged area within which he can analyze and prepare his client’s case.’ ”Palmer by Diacon, 261 Mont. at 116 , 861 P.2d at 910 (quoting U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ¶45 In Kuiper , we held that work product protects ‘impressions [of an attorney] rendered during the investigation of a claim where no litigation is in progress.” 193 Mont, at 465 , 632 P.2d at 701 .

51986–2013
Palmer v. Farmers Insurance Exchange green
mont · 1993
2 sentences

2013The core purpose of the work product doctrine is to “ ‘shelter[ ] the mental processes of the attorney, providing a privileged area within which he can analyze and prepare his client’s case.’ ”Palmer by Diacon, 261 Mont. at 116 , 861 P.2d at 910 (quoting U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ¶45 In Kuiper , we held that work product protects ‘impressions [of an attorney] rendered during the investigation of a claim where no litigation is in progress.” 193 Mont, at 465 , 632 P.2d at 701 .

2013The core purpose of the work product doctrine is to “ ‘shelter[ ] the mental processes of the attorney, providing a privileged area within which he can analyze and prepare his client’s case.’ ”Palmer by Diacon, 261 Mont. at 116 , 861 P.2d at 910 (quoting U.S. v. Nobles, 422 U.S. 225, 238 , 95 S. Ct. 2160, 2170 (1975)). ¶45 In Kuiper , we held that work product protects ‘impressions [of an attorney] rendered during the investigation of a claim where no litigation is in progress.” 193 Mont, at 465 , 632 P.2d at 701 .

32012–2018
Martin v. Paunovich green
fladistctapp · 1994
2 sentences

2010Jur. 2d Depositions and Discovery § 45 (2002) (citing Martin v. Paunovich, 632 So. 2d 611 (Fla. 5th Dist.

2010Jur. 2d Depositions and Discovery § 45 (2002) (citing Martin v. Paunovich, 632 So. 2d 611 (Fla. 5th Dist.

32010–2010
Huether v. District Court of the Sixteenth Judicial District of Montana green
mont · 2000
2 sentences

2010Dist., 2000 MT 158, ¶ 22 , 300 Mont. 212 , 4 P.3d 1193 . ¶37 Equally unpersuasive is Tacke’s argument that the work-product doctrine also prohibits the use of billing statements to support an attorneys’ fees claim.

2010Dist., 2000 MT 158, ¶ 22 , 300 Mont. 212 , 4 P.3d 1193 . ¶37 Equally unpersuasive is Tacke’s argument that the work-product doctrine also prohibits the use of billing statements to support an attorneys’ fees claim.

32010–2010
In Re Department Of Investigation Of The City Of New York green
· 1988
1 sentence

2006In re Dept. of Investigation of City of New York (2d Cir. 1988), 856 F.2d 481, 484 .

12006–2006
Jaap v. District Court of Eighth Judicial Dist. green
mont · 1981
2 sentences

1997In a second case, Jaap v. District Court (1981), 191 Mont. 319 , 623 P.2d 1389 , this Court granted a writ because the district court had exceeded its authority by allowing defendant’s attorney to privately interview plaintiff’s physicians.

1997In a second case, Jaap v. District Court (1981), 191 Mont. 319 , 623 P.2d 1389 , this Court granted a writ because the district court had exceeded its authority by allowing defendant’s attorney to privately interview plaintiff’s physicians.

11997–1997
Handgards, Inc. v. Johnson & Johnson green
cand · 1976
2 sentences

1993In discussing exceptions to the work product doctrine, the Ninth Circuit, in Holmgren , relied on Handgards, Inc. v. Johnson & Johnson (N.D.Cal. 1976), 413 F. Supp. 926 .

1993In discussing exceptions to the work product doctrine, the Ninth Circuit, in Holmgren , relied on Handgards, Inc. v. Johnson & Johnson (N.D.Cal. 1976), 413 F. Supp. 926 .

11993–1993
State Ex Rel. Carkulis v. District Court of the Thirteenth Judicial District green
mont · 1987
2 sentences

1990D. (1988), 229 Mont. 265 , 746 P.2d 604 , wherein we upheld the validity of § 46-15-323, MCA, both against a constitutional challenge and a claim that it violated the work product doctrine.

1990D. (1988), 229 Mont. 265 , 746 P.2d 604 , wherein we upheld the validity of § 46-15-323, MCA, both against a constitutional challenge and a claim that it violated the work product doctrine.

11990–1990
Williams v. Florida green
scotus · 1970
2 sentences

1990In Carkulis, we began by noting the rationale stated in Williams v. Florida (1970), 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 , as follows: “The United States Supreme Court in Williams v. Florida (1970), 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 , upheld a state statute requiring the disclosure of an alibi defense and alibi witnesses to the state prior to trial as not violating the federal right against self-incrimination.

1990In Carkulis, we began by noting the rationale stated in Williams v. Florida (1970), 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 , as follows: “The United States Supreme Court in Williams v. Florida (1970), 399 U.S. 78 , 90 S.Ct. 1893 , 26 L.Ed.2d 446 , upheld a state statute requiring the disclosure of an alibi defense and alibi witnesses to the state prior to trial as not violating the federal right against self-incrimination.

11990–1990
In Re Murphy green
ca8 · 1977
2 sentences

1981The question of whether “terminated litigation” is contemplated by the work product rule, was determined in In re Murphy (8th Cir. 1977), 560 F.2d 326 .

1981The question of whether “terminated litigation” is contemplated by the work product rule, was determined in In re Murphy (8th Cir. 1977), 560 F.2d 326 .

11981–1981

Statutes the citing opinions construe

MT § Mont. Code Ann. § 26-1-803 (5) CFR § 29c.f.r.541.201 (3) CFR § 29c.f.r.541.202 (3) CFR § 29c.f.r.790.22 (3) MT § Mont. Code Ann. § 1-3-225 (3) MT § Mont. Code Ann. § 25-10-201 (3) MT § Mont. Code Ann. § 33-18-201 (3) MT § Mont. Code Ann. § 39-3-214 (3) MT § Mont. Code Ann. § 46-15-323 (3) USC § 28u.s.c.1920 (3) USC § 29u.s.c.260 (3) USC § 42u.s.c.1988 (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 160 (1962–2026) TX 159 (1984–2026) FL 155 (1961–2026) OH 131 (1978–2026) PA 109 (1973–2026) IL 76 (1980–2025) WA 72 (1975–2025) MA 54 (1980–2025) NJ 52 (1950–2026) IN 46 (1976–2025) MO 43 (1977–2025) NC 40 (1990–2024) NY 40 (1964–2024) VA 37 (1970–2018) CT 34 (1969–2021) MI 34 (1975–2025) AL 26 (1987–2014) CO 26 (1981–2025) WV 25 (1984–2025) AZ 25 (1970–2025) TN 24 (1968–2024) MD 23 (1977–2025) IA 21 (1993–2024) MT 20 (1981–2018) RI 19 (1978–2025) DE 18 (1967–2025) GA 18 (1970–2021) KY 17 (1985–2024) NV 16 (1997–2019) LA 16 (1983–2025) OK 14 (1983–2026) DC 13 (1977–2023) MS 13 (1992–2023) NH 13 (1967–2021) NM 13 (1966–2025) ME 13 (2007–2019) WI 10 (1975–2003) UT 8 (1990–2023) HI 7 (1982–2023) AK 7 (1978–2018) KS 6 (1999–2019) ND 5 (1978–2022) MN 5 (1979–2024) OR 4 (1998–2023) AR 4 (1996–2009) SC 4 (1997–2019) VT 3 (1990–2023) SD 3 (1989–1999)

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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