holder privilege (Arizona) · Go Syfert
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holder privilege in Arizona

11 Arizona opinions name it 2 courts 1968–2023 1 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 (10)

CaseFollowedCited
Segal v. Rochellegreen
scotus · 1966 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023That is, because a debtor’s legal claim may have value as an asset with which to satisfy the debtor’s obligations to creditors, the trustee becomes the exclusive holder of the claim to do just that. 11 U.S.C. § 323 ; Segal v. Rochelle, 382 U.S. 375, 379-80 (1966); Est. of Spirtos v. San Bernardino Cnty.

11
Estate of Spirtos v. One San Bernardino County Superior Court Case Numbered SPR 02211green
ca9 · 2006 · cited in 1 Arizona opinions naming this issue, 2023–2023
1 sentence

2023Case No. SPR 02211, 443 F.3d 1172 , 1175-76 (9th Cir. 2006) (“[T]he bankruptcy code endows the bankruptcy trustee with the exclusive right to sue on behalf of the estate.”). ¶38 Two things are true here: (1) Doe’s claims arose pre- bankruptcy and (2) the original two-year statutorily prescribed statute of limitation for the claims (as opposed to any judicially recognized period of equitable tolling) had passed by the time of her first bankruptcy petition.

11
Bain v. SUPER. CT. IN AND FOR MARICOPA CTY.green
ariz · 1986 · cited in 1 Arizona opinions naming this issue, 2017–2017
1 sentence

2017See Bain, 148 Ariz. at 334 . ¶12 The patient is the holder of the privilege and, as such, is the only person who can waive it; however, when the patient is a minor child, 4 ABDELRAHMAN v. HON.

11
Duquette v. Superior Courtgreen
arizctapp · 1989 · cited in 1 Arizona opinions naming this issue, 2016–2016
2 sentences

2016Duquette v. Superior Court, 161 Ariz. 269, 272 , 778 P.2d 634, 637 (App. 1989).

2016Duquette v. Superior Court, 161 Ariz. 269, 272 , 778 P.2d 634, 637 (App. 1989).

11
Borissoff v. Taylor & Faustgreen
cal · 2004 · cited in 1 Arizona opinions naming this issue, 2014–2014
2 sentences

2014Borissoff v. Taylor & Faust, 33 Cal.4th 523 , 15 Cal.Rptr.3d 735 , 93 P.3d 337, 343-44 (2004) (“A successor fiduciary becomes the holder of the attorney-client privilege ‘only as to those confidential communications that occurred when the predecessor, in [its] fiduciary capacity, sought the attorney’s advice for guidance in administering the trust.’ Conversely, a successor fiduciary does not become the holder of the privilege for confidential communications that occurred when a predecessor fiduciary in [its] personal capacity sought an attorney’s advice.” (emphases omitted) (quoting Moeller, 6

2014Borissoff v. Taylor & Faust, 33 Cal.4th 523 , 15 Cal.Rptr.3d 735 , 93 P.3d 337, 343-44 (2004) (“A successor fiduciary becomes the holder of the attorney-client privilege ‘only as to those confidential communications that occurred when the predecessor, in [its] fiduciary capacity, sought the attorney’s advice for guidance in administering the trust.’ Conversely, a successor fiduciary does not become the holder of the privilege for confidential communications that occurred when a predecessor fiduciary in [its] personal capacity sought an attorney’s advice.” (emphases omitted) (quoting Moeller, 6

11
cluster 676508green
ca1 · 1994 · cited in 1 Arizona opinions naming this issue, 1999–1999
1 sentence

1999See Rhone-Poulenc Rover, Inc., 32 F.3d at 863 (“Advice is not in issue merely because it is relevant, and does not necessarily become in issue merely because the attorney’s advice might affect the client’s state of mind in a relevant manner.”); Metropolitan Life Ins.

11
Frontier Refining Inc. v. Gorman-Rupp Co.green
ca10 · 1998 · cited in 1 Arizona opinions naming this issue, 1999–1999
1 sentence

1999See Frontier Refining, Inc. v. Gor-man-Rupp Co., 136 F.3d 695 (10th Cir.1998). ¶ 10 Under the most restrictive approach, which State Farm urges us to adopt, the privilege may not be deemed waived unless the holder of the privilege has expressly waived it or has impliedly waived it by directly injecting the advice of counsel into the litigation.

11
Hearn v. Rhaygreen
waed · 1975 · cited in 1 Arizona opinions naming this issue, 1999–1999
1 sentence

1999See Hearn, 68 F.R.D. at 581 .

11
Weaver v. Manngreen
ndd · 1981 · cited in 1 Arizona opinions naming this issue, 1989–1989
2 sentences

1989See Weaver v. Mann, 90 F.R.D. 443 (D.N.D. 1981); Garner v. Ford Motor Co., 61 F.R.D. 22 (D.

1989See Weaver v. Mann, 90 F.R.D. 443 (D.N.D.1981); Garner v. Ford Motor Co., 61 F.R.D. 22 (D.

11
United States v. American Telephone & Telegraph Co.green
cadc · 1980 · cited in 1 Arizona opinions naming this issue, 1988–1988
1 sentence

1988“Any voluntary disclosure by the holder of such a privilege is inconsistent with the confidential relationship and thus waives the privilege.” United States v. AT & T, 642 F.2d 1285, 1299 (D.C.Cir.1980).

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 (7)

CaseCitedYears
Tracy v. Superior Court green
ariz · 1991
2 sentences

2014Although Tracy noted broadly that the “laws [relating to professional privileges] of each jurisdiction may appropriately vary,” id. at 43 , 810 P.2d at 1050 , it is not clear whether the communications or activities at issue in that case took place in Arizona (outside of tribal land), and the opinion in fact can be read to suggest that Tracy’s conduct took place on the Navajo reservation.

2014Although Tracy noted broadly that the “laws [relating to professional privileges] of each jurisdiction may appropriately vary,” id. at 43 , 810 P.2d at 1050 , it is not clear whether the communications or activities at issue in that case took place in Arizona (outside of tribal land), and the opinion in fact can be read to suggest that Tracy’s conduct took place on the Navajo reservation.

22014–2014
Spurlock v. Santa Fe Pacific Railroad green
arizctapp · 1984
2 sentences

2020As we noted in Spurlock, when a deed contains a mineral exception or reservation, other provisions may regulate how the holder of that exception or reservation may exercise its rights to take the minerals. 143 Ariz. at 479 .

2020Here, paragraph seven establishes Paulden’s right to take 2 Because the issue is not raised in this appeal, we do not address whether paragraph four’s reference to “all other hydrocarbon substances” narrows the scope of the reservation to something less than “all minerals.” See Spurlock, 143 Ariz. at 475 n.4. 6 PAULDEN v. BIG CHINO, et al.

12020–2020
Moeller v. Superior Court green
cal · 1997
2 sentences

2014Borissoff v. Taylor & Faust, 33 Cal.4th 523 , 15 Cal.Rptr.3d 735 , 93 P.3d 337, 343-44 (2004) (“A successor fiduciary becomes the holder of the attorney-client privilege ‘only as to those confidential communications that occurred when the predecessor, in [its] fiduciary capacity, sought the attorney’s advice for guidance in administering the trust.’ Conversely, a successor fiduciary does not become the holder of the privilege for confidential communications that occurred when a predecessor fiduciary in [its] personal capacity sought an attorney’s advice.” (emphases omitted) (quoting Moeller, 6

2014Borissoff v. Taylor & Faust, 33 Cal.4th 523 , 15 Cal.Rptr.3d 735 , 93 P.3d 337, 343-44 (2004) (“A successor fiduciary becomes the holder of the attorney-client privilege ‘only as to those confidential communications that occurred when the predecessor, in [its] fiduciary capacity, sought the attorney’s advice for guidance in administering the trust.’ Conversely, a successor fiduciary does not become the holder of the privilege for confidential communications that occurred when a predecessor fiduciary in [its] personal capacity sought an attorney’s advice.” (emphases omitted) (quoting Moeller, 6

12014–2014
Handgards, Inc. v. Johnson & Johnson green
cand · 1976
1 sentence

1999See, e.g., Rhone-Poulenc Rorer, Inc.; Handgards, Inc. v. Johnson & Johnson, Inc., 413 F.Supp. 926 (N.D.Cal.1976); Transamerica Title Ins.

11999–1999
Garner v. Ford Motor Co. green
akd · 1973
2 sentences

1989See Weaver v. Mann, 90 F.R.D. 443 (D.N.D. 1981); Garner v. Ford Motor Co., 61 F.R.D. 22 (D.

1989See Weaver v. Mann, 90 F.R.D. 443 (D.N.D.1981); Garner v. Ford Motor Co., 61 F.R.D. 22 (D.

11989–1989
Wartman v. Pecka green
· 1902
2 sentences

1968Trading Company, 47 Ariz. 47 , 53 P.2d 734 ; and Wartman v. Pecka, 8 Ariz. 8 , 68 P. 534—the attachment in the instant case was made after death and therefore is governed by A.R.S. § 14 — 577, which reads as follows: “The holder of a claim against an estate shall not maintain an action thereon unless the claim is first presented to the executor or administrator, but an action may be brought by the holder of a mortgage or lien to enforce it against the property of the estate subject thereto where all recourse against other property of the estate is expressly waived in the complaint, but no coun

1968Trading Company, 47 Ariz. 47 , 53 P.2d 734 ; and Wartman v. Pecka, 8 Ariz. 8 , 68 P. 534—the attachment in the instant case was made after death and therefore is governed by A.R.S. § 14 — 577, which reads as follows: “The holder of a claim against an estate shall not maintain an action thereon unless the claim is first presented to the executor or administrator, but an action may be brought by the holder of a mortgage or lien to enforce it against the property of the estate subject thereto where all recourse against other property of the estate is expressly waived in the complaint, but no coun

11968–1968
Guarantee Title & Trust Co. v. Babbitt Bros. Trading Co. green
ariz · 1936
2 sentences

1968Trading Company, 47 Ariz. 47 , 53 P.2d 734 ; and Wartman v. Pecka, 8 Ariz. 8 , 68 P. 534—the attachment in the instant case was made after death and therefore is governed by A.R.S. § 14 — 577, which reads as follows: “The holder of a claim against an estate shall not maintain an action thereon unless the claim is first presented to the executor or administrator, but an action may be brought by the holder of a mortgage or lien to enforce it against the property of the estate subject thereto where all recourse against other property of the estate is expressly waived in the complaint, but no coun

1968Trading Company, 47 Ariz. 47 , 53 P.2d 734 ; and Wartman v. Pecka, 8 Ariz. 8 , 68 P. 534—the attachment in the instant case was made after death and therefore is governed by A.R.S. § 14 — 577, which reads as follows: “The holder of a claim against an estate shall not maintain an action thereon unless the claim is first presented to the executor or administrator, but an action may be brought by the holder of a mortgage or lien to enforce it against the property of the estate subject thereto where all recourse against other property of the estate is expressly waived in the complaint, but no coun

11968–1968

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-2234 (3) AZ § Ariz. Rev. Stat. § 12-2236 (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 157 (1906–2025) IL 41 (1919–2024) TX 37 (1878–2025) NJ 30 (1895–2021) ID 26 (1909–2020) CO 22 (1963–2026) PA 17 (1924–2025) LA 16 (1845–2025) OH 15 (1907–2024) AL 13 (1876–2014) MA 13 (1900–2020) NY 12 (1862–2016) NM 12 (1999–2018) FL 12 (1994–2024) KS 11 (1878–2020) AZ 11 (1968–2023) CT 10 (1992–2022) WA 7 (1915–2019) OR 7 (1961–2021) MD 7 (1904–2026) SD 7 (1927–2016) NC 6 (1905–2022) GA 6 (1915–2019) MS 6 (1877–2017) IN 5 (1877–2012) DE 5 (2016–2022) NV 4 (2015–2022) MO 4 (1904–1992) ME 4 (2010–2020) NE 4 (1934–2018) MT 4 (1940–2020) IA 4 (1930–2010) MN 4 (1919–2006) MI 4 (1989–2015) VA 3 (1987–2022) UT 3 (1914–2011) KY 3 (1952–2003) WI 3 (1995–2014) AK 3 (2012–2023) NH 3 (2006–2011) HI 2 (2003–2005) OK 2 (1917–1940) VT 2 (2005–2005) SC 2 (1900–1975)

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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