lawyer-client privilege (Florida) · Go Syfert
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lawyer-client privilege in Florida

18 Florida opinions name it 4 courts 1983–2017 0 in the last five years

The cases below were cited by Florida 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 (8)

CaseFollowedCited
Pouncy v. Stategreen
fladistctapp · 1977 · cited in 4 Florida opinions naming this issue, 1983–2001
2 sentences

1986Such expert shall report only to the attorney for the defendant and matters related to the expert shall be deemed to fall under the lawyer-client privilege. [Emphasis supplied.] Rule 3.216(a) codified the court's holding in Pouncy v. State, 353 So.2d 640 (Fla. 3d DCA 1977), that where an expert is hired solely to assist the defense and will not be called as a witness, the state may not depose the expert or call him as a witness.

1983Even as to the insanity defense, the trial court’s order that selected portions of the psychiatric reports be sent only to appellant does not satisfy the language that an expert “shall report only to attorney for the defendant” and that appellant’s evaluation “shall be deemed to fall under the lawyer-client privilege.” Cf. Pouncy v. State, 353 So.2d 640 (Fla. 3d DCA 1977) (doctrine of attorney-client privilege bars the state from deposing and calling as witnesses psychiatrists hired by the defendant for the sole purpose of aiding in preparation of an insanity defense).

14
Coffey-Garcia and Garcia v. South Miami Hospital, Inc.green
fladistctapp · 2016 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See Coffey-Garcia v. S. Miami Hosp., Inc., 194 So. 3d 533, 537-38 (Fla. 3d DCA 2016) (recognizing that because the lawyer-client privilege set forth in section 90.502 “protects only communications to and from a lawyer,” the plaintiff in a malpractice action could be compelled to answer 7 deposition questions regarding “the names of the attorneys whom she consulted with” in pursuing her claim).

11
In Re Estate of Mardengreen
fladistctapp · 1978 · cited in 1 Florida opinions naming this issue, 2016–2016
1 sentence

2016This subsection simply disallows the privilege in favor of the policies stated above”) (internal citation omitted); In re Estate of Marden, 355 So.2d 121, 127 (Fla. 3d DCA 1978) (holding that “[a]n attorney’s testimony about a Will drafted by him, after the death of the testator, is not ordinarily privileged.”) Petitioner’s assertion that the statements made to him by the testator are “confidential” under Rule 4-1.6, Rules Regulating the Florida Bar, is unavailing in this circumstance.

11
Modern Woodmen of America v. Watkinsgreen
· 1942 · cited in 1 Florida opinions naming this issue, 2007–2007
1 sentence

2007Thus, the lawyer-client privilege "does not extend to every statement made to a lawyer." Modern Woodmen of Am. v. Watkins, 132 F.2d 352, 354 (5th Cir. 1942).

11
Paskoski v. Johnsongreen
fladistctapp · 1993 · cited in 1 Florida opinions naming this issue, 2004–2004
1 sentence

2004See Paskoski v. Johnson, 626 So.2d 338, 339 (Fla. 4th DCA 1993).

11
Rose v. Stategreen
fladistctapp · 1991 · cited in 1 Florida opinions naming this issue, 2001–2001
1 sentence

2001See Rose v. State, 591 So.2d 195, 197 (Fla. 4th DCA 1991). *263 Historically, the rule was a codification of Pouncy v. State, 353 So.2d 640 (Fla. 3d DCA 1977), and has since been interpreted to mean that "the state could not make a confidential expert its witness when the attorney/client privilege had not been waived." Lovette v. State, 636 So.2d 1304, 1307 (Fla.1994).

11
Lovette v. Stategreen
fla · 1994 · cited in 1 Florida opinions naming this issue, 2001–2001
1 sentence

2001See Rose v. State, 591 So.2d 195, 197 (Fla. 4th DCA 1991). *263 Historically, the rule was a codification of Pouncy v. State, 353 So.2d 640 (Fla. 3d DCA 1977), and has since been interpreted to mean that "the state could not make a confidential expert its witness when the attorney/client privilege had not been waived." Lovette v. State, 636 So.2d 1304, 1307 (Fla.1994).

11
Procacci v. Seitlingreen
fladistctapp · 1986 · cited in 1 Florida opinions naming this issue, 1995–1995
1 sentence

1995See, e.g., Procacci v. Seitlin, 497 So.2d 969 (Fla. 3d DCA 1986) (attorney-client privilege waived by client's suit for malpractice).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (19)

CaseCitedYears
Zorc v. City of Vero Beach green
fladistctapp · 1998
2 sentences

2009Fla. 93-53 (1993). 17 722 So. 2d 891 (Fla. 4th DCA 1998). 18 722 So. 2d at 901 , quoting Final Bill Analysis Economic Impact Statement, CS/HB 491, Florida House of Representatives Committee on Governmental Operations (1993). 19 See, e.g., Freeman v. Times Publishing Company , 696 So. 2d 427 , 428 (Fla. 2d DCA 1997) ("settlement negotiations" did not encompass a 25-year-old final judgment; while it was still a pending suit, it was not in the posture to be settled before judgment or pending appeal); Brown v. City of Lauderhill , 654 So. 2d 302 (Fla. 4th DCA 1995) (city attorney may meet in priva

2009Fla. 93-53 (1993). 17 722 So. 2d 891 (Fla. 4th DCA 1998). 18 722 So. 2d at 901 , quoting Final Bill Analysis Economic Impact Statement, CS/HB 491, Florida House of Representatives Committee on Governmental Operations (1993). 19 See, e.g., Freeman v. Times Publishing Company , 696 So. 2d 427 , 428 (Fla. 2d DCA 1997) ("settlement negotiations" did not encompass a 25-year-old final judgment; while it was still a pending suit, it was not in the posture to be settled before judgment or pending appeal); Brown v. City of Lauderhill , 654 So. 2d 302 (Fla. 4th DCA 1995) (city attorney may meet in priva

22001–2009
School Bd. of Duval Cty. v. Fla. Pub. Co. green
fladistctapp · 1996
2 sentences

2001I , s. 24 , Fla. Const. (access to public records and meetings). 2 See, s. 1, Ch. 93-232, Laws of Florida, effective June 30, 1993, which added subsection (8) to s. 286.011 , Fla. Stat. 3 Cf ., s. 90.502 , Fla. Stat., recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, City of Dunnellon v. Aran , 662 So.2d 1026 (Fla. 5th DCA 1995); School Board of Duval County v. Florida Publishing Company , 670 So.2d 99 (Fla. 1st DCA 1996). 5 670 So.2d 99 (Fla. 1st DCA 1996). 6 Staff of Fla.H.R.Comm. on Government Operations, CS/HB 491 (1993) Final Bill Analysis Economic Impact State

2001I , s. 24 , Fla. Const. (access to public records and meetings). 2 See, s. 1, Ch. 93-232, Laws of Florida, effective June 30, 1993, which added subsection (8) to s. 286.011 , Fla. Stat. 3 Cf ., s. 90.502 , Fla. Stat., recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, City of Dunnellon v. Aran , 662 So.2d 1026 (Fla. 5th DCA 1995); School Board of Duval County v. Florida Publishing Company , 670 So.2d 99 (Fla. 1st DCA 1996). 5 670 So.2d 99 (Fla. 1st DCA 1996). 6 Staff of Fla.H.R.Comm. on Government Operations, CS/HB 491 (1993) Final Bill Analysis Economic Impact State

21999–2001
City of Dunnellon v. Aran green
fladistctapp · 1995
2 sentences

2001I , s. 24 , Fla. Const. (access to public records and meetings). 2 See, s. 1, Ch. 93-232, Laws of Florida, effective June 30, 1993, which added subsection (8) to s. 286.011 , Fla. Stat. 3 Cf ., s. 90.502 , Fla. Stat., recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, City of Dunnellon v. Aran , 662 So.2d 1026 (Fla. 5th DCA 1995); School Board of Duval County v. Florida Publishing Company , 670 So.2d 99 (Fla. 1st DCA 1996). 5 670 So.2d 99 (Fla. 1st DCA 1996). 6 Staff of Fla.H.R.Comm. on Government Operations, CS/HB 491 (1993) Final Bill Analysis Economic Impact State

1999Sincerely, Robert A. Butterworth Attorney General RAB/tls 1 Attorney General Opinion 94-33 (1994). 2 Cf., s. 90.502 , Fla. Stat., recognizing a lawyer-client privilege under the Florida Evidence Code. 3 Attorney General Opinion 93-53 (1993). 4 See, City of Dunnellon v. Aran , 662 So.2d 1026 (Fla. 5th DCA 1995); Board of Public Instruction of Broward County v. Doran, 224 So.2d 693 , 699 (Fla. 1969). 5 See, School Board of Duval County v. Florida Publishing Company , 670 So.2d 99 (Fla. 1st DCA 1996); Ops.

21999–2001
Board of Public Instruction of Broward Cty. v. Doran green
fla · 1969
2 sentences

1999Sincerely, Robert A. Butterworth Attorney General RAB/tls 1 Attorney General Opinion 94-33 (1994). 2 Cf., s. 90.502 , Fla. Stat., recognizing a lawyer-client privilege under the Florida Evidence Code. 3 Attorney General Opinion 93-53 (1993). 4 See, City of Dunnellon v. Aran , 662 So.2d 1026 (Fla. 5th DCA 1995); Board of Public Instruction of Broward County v. Doran, 224 So.2d 693 , 699 (Fla. 1969). 5 See, School Board of Duval County v. Florida Publishing Company , 670 So.2d 99 (Fla. 1st DCA 1996); Ops.

1995Fla. 93-53 (1993), in which the terms and intent of s. 286.011 (8), Fla. Stat., are discussed. 3 Cf., s. 90.502 , Fla. Stat. (1993), recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, Thayer v. State, 335 So.2d 815 , 817 (Fla. 1976); Dobbs v. Sea Isle Hotel, 56 So.2d 341 , 342 (Fla. 1952); Ideal Farms Drainage District v. Certain Lands, 19 So.2d 234 (Fla. 1944). 5 See, e.g., Board of Public Instruction of Broward County v. Doran, 224 So.2d 693 (Fla. 1969); Op. Att'y Gen.

21995–1999
Tripp v. Salkovitz green
fladistctapp · 2006
2 sentences

2014In chapter 2011-183, section 1, Laws of Florida, the Legislature enacted section 90.5021, Florida Statutes, which establishes a “fiduciary lawyer-client privilege.” According to • the Committee, whether a fiduciary is entitled to the lawyer-client privilege when the fiduciary employs an attorney in connection with his or her fiduciary duties has been an issue in several cases; for example, the Committee cites Jacob v. Barton, 877 So.2d 935 (Fla. 2d DCA 2004), and Tripp v. Salkovitz, 919 So.2d 716 (Fla. 2d DCA 2006).

2014In chapter 2011-183, section 1, Laws of Florida, the Legislature enacted section 90.5021, Florida Statutes, which establishes a “fiduciary lawyer-client privilege.” According to the Committee, whether a fiduciary is entitled to the lawyer-client privilege when the fiduciary employs an attorney in connection with his or her fiduciary duties has been an issue in several cases; for example, the Committee cites Jacob v. Barton, 877 So. 2d 935 (Fla. 2d DCA 2004), and Tripp v. Salkovitz, 919 So. 2d 716 (Fla. 2d DCA 2006).

12014–2014
Jacob v. Barton green
fladistctapp · 2004
2 sentences

2014In chapter 2011-183, section 1, Laws of Florida, the Legislature enacted section 90.5021, Florida Statutes, which establishes a “fiduciary lawyer-client privilege.” According to • the Committee, whether a fiduciary is entitled to the lawyer-client privilege when the fiduciary employs an attorney in connection with his or her fiduciary duties has been an issue in several cases; for example, the Committee cites Jacob v. Barton, 877 So.2d 935 (Fla. 2d DCA 2004), and Tripp v. Salkovitz, 919 So.2d 716 (Fla. 2d DCA 2006).

2014In chapter 2011-183, section 1, Laws of Florida, the Legislature enacted section 90.5021, Florida Statutes, which establishes a “fiduciary lawyer-client privilege.” According to the Committee, whether a fiduciary is entitled to the lawyer-client privilege when the fiduciary employs an attorney in connection with his or her fiduciary duties has been an issue in several cases; for example, the Committee cites Jacob v. Barton, 877 So. 2d 935 (Fla. 2d DCA 2004), and Tripp v. Salkovitz, 919 So. 2d 716 (Fla. 2d DCA 2006).

12014–2014
Freeman v. Times Pub. Co. green
fladistctapp · 1997
1 sentence

2009Fla. 93-53 (1993). 17 722 So. 2d 891 (Fla. 4th DCA 1998). 18 722 So. 2d at 901 , quoting Final Bill Analysis Economic Impact Statement, CS/HB 491, Florida House of Representatives Committee on Governmental Operations (1993). 19 See, e.g., Freeman v. Times Publishing Company , 696 So. 2d 427 , 428 (Fla. 2d DCA 1997) ("settlement negotiations" did not encompass a 25-year-old final judgment; while it was still a pending suit, it was not in the posture to be settled before judgment or pending appeal); Brown v. City of Lauderhill , 654 So. 2d 302 (Fla. 4th DCA 1995) (city attorney may meet in priva

12009–2009
Brown v. City of Lauderhill green
fladistctapp · 1995
1 sentence

2009Fla. 93-53 (1993). 17 722 So. 2d 891 (Fla. 4th DCA 1998). 18 722 So. 2d at 901 , quoting Final Bill Analysis Economic Impact Statement, CS/HB 491, Florida House of Representatives Committee on Governmental Operations (1993). 19 See, e.g., Freeman v. Times Publishing Company , 696 So. 2d 427 , 428 (Fla. 2d DCA 1997) ("settlement negotiations" did not encompass a 25-year-old final judgment; while it was still a pending suit, it was not in the posture to be settled before judgment or pending appeal); Brown v. City of Lauderhill , 654 So. 2d 302 (Fla. 4th DCA 1995) (city attorney may meet in priva

12009–2009
Ideal Farms Drainage District v. Certain Lands green
fla · 1944
1 sentence

1995Fla. 93-53 (1993), in which the terms and intent of s. 286.011 (8), Fla. Stat., are discussed. 3 Cf., s. 90.502 , Fla. Stat. (1993), recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, Thayer v. State, 335 So.2d 815 , 817 (Fla. 1976); Dobbs v. Sea Isle Hotel, 56 So.2d 341 , 342 (Fla. 1952); Ideal Farms Drainage District v. Certain Lands, 19 So.2d 234 (Fla. 1944). 5 See, e.g., Board of Public Instruction of Broward County v. Doran, 224 So.2d 693 (Fla. 1969); Op. Att'y Gen.

11995–1995
Dobbs v. Sea Isle Hotel green
fla · 1952
1 sentence

1995Fla. 93-53 (1993), in which the terms and intent of s. 286.011 (8), Fla. Stat., are discussed. 3 Cf., s. 90.502 , Fla. Stat. (1993), recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, Thayer v. State, 335 So.2d 815 , 817 (Fla. 1976); Dobbs v. Sea Isle Hotel, 56 So.2d 341 , 342 (Fla. 1952); Ideal Farms Drainage District v. Certain Lands, 19 So.2d 234 (Fla. 1944). 5 See, e.g., Board of Public Instruction of Broward County v. Doran, 224 So.2d 693 (Fla. 1969); Op. Att'y Gen.

11995–1995
Thayer v. State green
fla · 1976
1 sentence

1995Fla. 93-53 (1993), in which the terms and intent of s. 286.011 (8), Fla. Stat., are discussed. 3 Cf., s. 90.502 , Fla. Stat. (1993), recognizing a lawyer-client privilege under the Florida Evidence Code. 4 See, Thayer v. State, 335 So.2d 815 , 817 (Fla. 1976); Dobbs v. Sea Isle Hotel, 56 So.2d 341 , 342 (Fla. 1952); Ideal Farms Drainage District v. Certain Lands, 19 So.2d 234 (Fla. 1944). 5 See, e.g., Board of Public Instruction of Broward County v. Doran, 224 So.2d 693 (Fla. 1969); Op. Att'y Gen.

11995–1995
Ursry v. State green
fladistctapp · 1983
1 sentence

1986This court followed Pouncy in Ursry v. State, 428 So.2d 713 (Fla. 4th DCA), pet. for rev. denied, 438 So.2d 834 (Fla. 1983).

11986–1986
Miami Herald Pub. Co. v. City of North Miami green
fladistctapp · 1984
1 sentence

1985The Court voiced concern about the wisdom of such a police, but stated if there is to be a lawyer-client privilege exemption from the Public Records Act, the legislature would have to enact an exemption. 452 So.2d at 574 .

11985–1985
Sherer v. Rubin Memorial Chapel, Ltd. green
fladistctapp · 1984
1 sentence

1985Miami Herald, 452 So.2d 574 .

11985–1985
Wait v. Florida Power & Light Co. green
fla · 1979
1 sentence

1984Wait v. Florida Power & Light Co., 372 So.2d 420 (Fla. 1979); see § 119.07(3)(a), Fla. Stat. (1981).

11984–1984
Witt v. State green
fla · 1980
1 sentence

1984He contends that this rule change was a change in the law sufficient to meet the test announced by this Court in Witt v. State, 387 So.2d 922 (Fla.), cert. denied, 449 U.S. 1067 , 101 S.Ct. 796 , 66 L.Ed.2d 612 (1980).

11984–1984
Adams v. Peat, Marwick, Mitchell & Co. green
scotus · 1980
1 sentence

1984He contends that this rule change was a change in the law sufficient to meet the test announced by this Court in Witt v. State, 387 So.2d 922 (Fla.), cert. denied, 449 U.S. 1067 , 101 S.Ct. 796 , 66 L.Ed.2d 612 (1980).

11984–1984
Jarrett v. Jarrett green
scotus · 1980
1 sentence

1984He contends that this rule change was a change in the law sufficient to meet the test announced by this Court in Witt v. State, 387 So.2d 922 (Fla.), cert. denied, 449 U.S. 1067 , 101 S.Ct. 796 , 66 L.Ed.2d 612 (1980).

11984–1984
Hamilton v. Davis neutral
fladistctapp · 1983
1 sentence

1983The Fifth District has already addressed this provision in Hamilton v. Davis, 427 So.2d 1137 (Fla. 5th DCA 1983).

11983–1983

Statutes the citing opinions construe

FL § 90.502 (9) FL § 119.07 (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 36 (1965–2023) FL 18 (1983–2017) OR 16 (1983–2023) NJ 15 (1981–2013) TX 14 (1972–2021) WI 12 (1987–2022) CO 5 (1976–2020) ND 5 (1969–2016) NY 4 (1976–1994) PA 4 (1975–2018) KY 4 (2002–2025) HI 4 (1997–2023) SD 3 (1984–2015) MA 3 (1983–2019) AZ 3 (1981–2000) IA 3 (2016–2016) WA 3 (2003–2013) KS 3 (1986–2000) AK 2 (1990–1993) NE 2 (1985–2001) WV 2 (2003–2004) ME 2 (2011–2018) CT 2 (2004–2011)

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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