attorney work product privilege (California) · Go Syfert
← California issues

attorney work product privilege in California

72 California opinions name it 3 courts 1979–2026 14 in the last five years

The cases below were cited by California 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 (48)

CaseFollowedCited
BP Alaska Exploration, Inc. v. Superior Courtgreen
calctapp · 1988 · cited in 8 California opinions naming this issue, 2000–2024
2 sentences

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

68
Coito v. Superior Courtgreen
cal · 2012 · cited in 9 California opinions naming this issue, 2017–2026
2 sentences

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

59
Fellows v. Superior Courtgreen
calctapp · 1980 · cited in 4 California opinions naming this issue, 1985–2017
2 sentences

2017Section 2018.020 declares: 'It is the policy of the state to do both of the following: [¶] (a) Preserve the rights of attorneys to prepare cases for trial with that degree of privacy necessary to encourage them to prepare their cases thoroughly and to investigate not only the favorable but the unfavorable aspects of those cases. [¶](b) *390 Prevent attorneys from taking undue advantage of their adversary's industry and efforts.' Toward that end, section 2018.030 provides: '(a) A writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discove

2017Section 2018.020 declares: 'It is the policy of the state to do both of the following: [¶] (a) Preserve the rights of attorneys to prepare cases for trial with that degree of privacy necessary to encourage them to prepare their cases thoroughly and to investigate not only the favorable but the unfavorable aspects of those cases. [¶](b) *390 Prevent attorneys from taking undue advantage of their adversary's industry and efforts.' Toward that end, section 2018.030 provides: '(a) A writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discove

44
Citizens for Ceres v. Superior Courtgreen
calctapp · 2013 · cited in 5 California opinions naming this issue, 2017–2024
2 sentences

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

35
Wellpoint Health Networks, Inc. v. Superior Court of Los Angeles Countygreen
calctapp · 1997 · cited in 4 California opinions naming this issue, 1998–2016
2 sentences

2015(Dowden v. Superior Court (1999) 73 Cal.App.4th 126, 135 [ 86 Cal.Rptr.2d 180 ].) “[I]n camera inspection is the proper procedure to evaluate the applicability of the [attorney] work product doctrine to specific documents, and categorize whether each document should be given qualified or absolute protection.” (Wellpoint Health Networks, Inc. v. Superior Court (1997) 59 Cal.App.4th 110, 121 [ 68 Cal.Rptr.2d 844 ] (Wellpoint).) The person claiming protection under the attorney work product doctrine bears the burden of proving the preliminary facts to show the doctrine applies.

2015(Dowden v. Superior Court (1999) 73 Cal.App.4th 126, 135 [ 86 Cal.Rptr.2d 180 ].) “[I]n camera inspection is the proper procedure to evaluate the applicability of the [attorney] work product doctrine to specific documents, and categorize whether each document should be given qualified or absolute protection.” (Wellpoint Health Networks, Inc. v. Superior Court (1997) 59 Cal.App.4th 110, 121 [ 68 Cal.Rptr.2d 844 ] (Wellpoint).) The person claiming protection under the attorney work product doctrine bears the burden of proving the preliminary facts to show the doctrine applies.

34
Rico v. Mitsubishi Motors Corp.green
cal · 2007 · cited in 3 California opinions naming this issue, 2009–2021
2 sentences

2021The parties may then proceed to resolve the situation by agreement or may resort to the court for guidance with the benefit of protective orders or other judicial intervention as may be justified.” (State Fund, supra, 70 Cal.App.4th at pp. 656-657.) 7 In Rico v. Mitsubishi Motors Corp. (2007) 42 Cal.4th 807, 817 (Rico), our Supreme Court adopted this “State Fund rule,” describing it as a “fair and reasonable approach.” Rico extended the rule to apply not just to attorney-client privileged materials, but also materials protected by the attorney work product doctrine.

2017We do, however, hold that whenever a lawyer ascertains that he or she may have privileged attorney-client material that was inadvertently provided by another, that lawyer must notify the party entitled to the privilege of that fact.” (Ibid., italics added.) In Rico, the Supreme Court quoted the first two sentences from the foregoing quote as the State Fund rule, and extended the rule to materials protected by the attorney work product doctrine because the rule is “a fair and reasonable approach” that “holds attorneys to a reasonable standard of professional conduct when confidential or privile

33
United States v. Kenneth Olsengreen
ca9 · 2013 · cited in 3 California opinions naming this issue, 2018–2018
2 sentences

2018(See People v. Collie (1981) 30 Cal.3d 43 , 59, fn. 12, 177 Cal.Rptr. 458 , 634 P.2d 534 ; see also, e.g., United States v. Olsen (9th Cir. 2013) 704 F.3d 1172 , 1181 [contents of internal investigation were favorable to the defendant].) However, a prosecutor's work product is not discoverable under Brady unless the material contains underlying exculpatory facts .

2018(See People v. Collie (1981) 30 Cal.3d 43, 59, fn. 12 ; see also, e.g., United States v. Olsen (9th Cir. 2013) 704 F.3d 1172, 1181 [contents of internal investigation were favorable to the defendant].) However, a prosecutor’s work product is not discoverable under Brady unless the material contains underlying exculpatory facts.

33
County of Los Angeles v. Superior Courtgreen
calctapp · 2000 · cited in 4 California opinions naming this issue, 2001–2018
2 sentences

2018It applies as well to writings prepared by an attorney while acting in a nonlitigation capacity." ( County of Los Angeles v. Superior Court, supra, 82 Cal.App.4th at p. 833 , 98 Cal.Rptr.2d 564 .) And "the attorney's absolute work product protection continues as to the contents of a writing delivered to a client in confidence." ( BP Alaska, supra, at p. 1253 , 245 Cal.Rptr. 682 .) The attorney work product privilege applies to exempt documents from Public Records Act requests. ( Ardon v. City of Los Angeles (2016) 62 Cal.4th 1176 , 1182, 199 Cal.Rptr.3d 743 , 366 P.3d 996 ( Ardon ).) In Ardon

2018It applies as well to writings prepared by an attorney while acting in a nonlitigation capacity." ( County of Los Angeles v. Superior Court, supra, 82 Cal.App.4th at p. 833 , 98 Cal.Rptr.2d 564 .) And "the attorney's absolute work product protection continues as to the contents of a writing delivered to a client in confidence." ( BP Alaska, supra, at p. 1253 , 245 Cal.Rptr. 682 .) The attorney work product privilege applies to exempt documents from Public Records Act requests. ( Ardon v. City of Los Angeles (2016) 62 Cal.4th 1176 , 1182, 199 Cal.Rptr.3d 743 , 366 P.3d 996 ( Ardon ).) In Ardon

24
People v. Colliegreen
cal · 1981 · cited in 4 California opinions naming this issue, 1985–2018
2 sentences

1985The court was correct, however, in adopting the referee’s recommendations with respect to questions and documents about the so-called “prior investigation” conducted by the RSD. *754 Relying on People v. Collie (1981) 30 Cal.3d 43 [ 177 Cal.Rptr. 458 , 634 P.2d 534 , 23 A.L.R.4th 776 ], the City contends that any conversations between RSD investigators and attorneys at the city attorney’s office are protected under the attorney work-product doctrine.

1985The court was correct, however, in adopting the referee’s recommendations with respect to questions and documents about the so-called “prior investigation” conducted by the RSD. *754 Relying on People v. Collie (1981) 30 Cal.3d 43 [ 177 Cal.Rptr. 458 , 634 P.2d 534 , 23 A.L.R.4th 776 ], the City contends that any conversations between RSD investigators and attorneys at the city attorney’s office are protected under the attorney work-product doctrine.

24
Rumac, Inc. v. Bottomleygreen
calctapp · 1983 · cited in 2 California opinions naming this issue, 2000–2024
2 sentences

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

2000(Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815 [ 192 Cal.Rptr. 104 ].) The County claims that the IRC Task Force Report, Over-detention Reports and Logs are protected by the attorney work product privilege because they were prepared in anticipation of litigation, and at the direction of counsel.

22
People v. Gonzalesgreen
cal · 2012 · cited in 2 California opinions naming this issue, 2024–2024
2 sentences

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332, 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332 , 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

22
County of Los Angeles v. Superior Courtgreen
calctapp · 2012 · cited in 2 California opinions naming this issue, 2015–2023
2 sentences

2015(County of Los Angeles v. Superior Court (2012) 211 Cal.App.4th 57, 64 [ 149 Cal.Rptr.3d 324 ].) The purpose of the attorney work product doctrine is to preserve the rights of attorneys in the preparation of their cases and to prevent attorneys from taking advantage of the industry and creativity of opposing counsel.

2015(County of Los Angeles v. Superior Court (2012) 211 Cal.App.4th 57, 64 [ 149 Cal.Rptr.3d 324 ].) The purpose of the attorney work product doctrine is to preserve the rights of attorneys in the preparation of their cases and to prevent attorneys from taking advantage of the industry and creativity of opposing counsel.

22
People v. Combsgreen
cal · 2004 · cited in 2 California opinions naming this issue, 2006–2021
2 sentences

2021Under such circumstances, the Constitution allows the prosecution to receive unredacted reports of the defendant’s examinations by defense mental experts, including any statements by the defendant to the examiners and any conclusions they have drawn therefrom.” (Maldonado v. Superior Court (2012) 53 Cal.4th 1112, 1125 .) Once a defendant calls a defense expert to the stand, she waives “any protections that the attorney- client privilege, the attorney work product doctrine, and the privilege against self-incrimination afforded [her] regarding all matters that [her testifying experts] considered

2006Although we concluded that the defendant had forfeited the issue by failing to assert the attorney-client privilege at trial, we addressed the merits of the claim, stating that “[djefendant waived any protections that the attorney-client privilege, the attorney work product doctrine, and the privilege against self-incrimination afforded him regarding all matters that [the testifying defense experts] considered or on which they relied, including Dr. Oshrin’s report.” (Combs, supra, 34 Cal.4th at p. 864.) We rejected the defendant’s argument that the defense experts could be cross-examined only

22
People Ex Rel. Lockyer v. Superior Courtgreen
calctapp · 2000 · cited in 2 California opinions naming this issue, 2017–2017
22
People v. Cromergreen
cal · 2001 · cited in 2 California opinions naming this issue, 2003–2003
22
Meza v. H. Muehlstein & Co., Inc.green
calctapp · 2009 · cited in 5 California opinions naming this issue, 2017–2024
2 sentences

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

2018Muehlstein & Co. (2009) 176 Cal.App.4th 969 , 977, 98 Cal.Rptr.3d 422 .) The attorney work product doctrine, codified at Code of Civil Procedure section 2018.030, provides: "A writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discoverable under any circumstances." ( § 2018.030, subd. (a).) All other attorney work product "is not discoverable unless the court determines that denial of discovery will unfairly prejudice the party seeking discovery in preparing that party's claim or defense or will result in an injustice." ( § 2018.030, su

15
City of Long Beach v. Superior Courtgreen
calctapp · 1976 · cited in 5 California opinions naming this issue, 1990–2021
2 sentences

2021The attorney work product privilege was not at issue, and the disclosure of the individuals with whom the Governor met could have revealed the Governor’s thought process, whereas Curtis has already disclosed Doe 1 is a plaintiffs’-side attorney he consulted to hone his trial strategy. 23 Transport Indemnity Insurance (1993) 18 Cal.App.4th 996, 1004 [name of independent insurance adjuster who had investigated a prior industrial accident at defendant’s facility was not protected work product]; but see City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 73 [compelled disclosure of the i

1993(City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 73 [ 134 Cal.Rptr. 468 ], quoting Code Civ.

15
Hernandez v. Superior Courtgreen
calctapp · 2003 · cited in 4 California opinions naming this issue, 2006–2018
2 sentences

2018Code, § 1054.6 ["Neither the defendant nor the prosecuting attorney is required to disclose any materials or information which are work product as defined in ... the Code of Civil Procedure"].) "The opinions of experts who have not been designated as trial witnesses are protected by the attorney work product rule. [Citation.] Their identity also remains privileged until they are designated as trial witnesses." ( Hernandez v. Superior Court (2003) 112 Cal.App.4th 285 , 297, 4 Cal.Rptr.3d 883 .) Nevertheless, a prosecutor has a constitutional duty to reveal exculpatory evidence-including otherwi

2018Code, § 1054.6 ["Neither the defendant nor the prosecuting attorney is required to disclose any materials or information which are work product as defined in ... the Code of Civil Procedure"].) "The opinions of experts who have not been designated as trial witnesses are protected by the attorney work product rule. [Citation.] Their identity also remains privileged until they are designated as trial witnesses." ( Hernandez v. Superior Court (2003) 112 Cal.App.4th 285 , 297, 4 Cal.Rptr.3d 883 .) Nevertheless, a prosecutor has a constitutional duty to reveal exculpatory evidence-including otherwi

14
Oxy Resources California LLC v. Superior Courtgreen
calctapp · 2004 · cited in 4 California opinions naming this issue, 2009–2018
2 sentences

2018In finding a waiver of the attorney work product privilege, the trial court misplaced its reliance on OXY Resources California LLC v. Superior Court (2004) 115 Cal.App.4th 874 , 9 Cal.Rptr.3d 621 ( OXY Resources ).

2018In finding a waiver of the attorney work product privilege, the trial court misplaced its reliance on OXY Resources California LLC v. Superior Court (2004) 115 Cal.App.4th 874 , 9 Cal.Rptr.3d 621 ( OXY Resources ).

14
People v. Zamudiogreen
cal · 2008 · cited in 3 California opinions naming this issue, 2020–2024
2 sentences

2024(See Zamudio, supra, 43 Cal.4th at pp. 352, 355.) The prosecutor did not argue that defendant had a duty to produce evidence, nor did he attempt to shift or lighten the state’s burden of proof.

2020Defendant argues that admitting this testimony violated the attorney work product doctrine, regardless of whether the work product was reduced to writing or not, because “despite the arguably contrary language of California’s absolute work product statute, the privilege also applies to non-written work product.” Disagreeing, the Attorney General argues that “[t]he prosecutor’s questions to Canty did Procedure former section 2018, subdivision (c), which then stated the absolute work product protection now stated in Code of Civil Procedure section 2018.030, subdivision (a).” (People v. Zamudio (

13
County of Los Angeles v. Superior Courtgreen
calctapp · 1990 · cited in 3 California opinions naming this issue, 2003–2021
2 sentences

2021Ordinarily, until a party’s consultants are designated to testify as expert witnesses, their opinions and reports are not discoverable. (§§ 2034.210, 2034.410, 2034.415; County of Los Angeles v. Superior Court (1990) 222 Cal.App.3d 647 , 654–655 [an expert consultant’s work is protected by the attorney work product privilege, but once it appears reasonably certain the expert will testify as a witness on a material matter in dispute, the privilege no longer applies and the expert’s opinions are subject to discovery and disclosure].) The requirements for disclosure of expert witness information

2007(Complex Asbestos, supra, 232 Cal.App.3d at p. 596 .) *409 In Shadow Traffic , the court addressed disqualification under County of Los Angeles v. Superior Court, supra, 222 Cal.App.3d 647 of an attorney who obtained information protected by the attorney work product privilege.

13
Lohman v. Superior Courtgreen
calctapp · 1978 · cited in 3 California opinions naming this issue, 1985–2017
2 sentences

2017Section 2018.020 declares: 'It is the policy of the state to do both of the following: [¶] (a) Preserve the rights of attorneys to prepare cases for trial with that degree of privacy necessary to encourage them to prepare their cases thoroughly and to investigate not only the favorable but the unfavorable aspects of those cases. [¶](b) *390 Prevent attorneys from taking undue advantage of their adversary's industry and efforts.' Toward that end, section 2018.030 provides: '(a) A writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discove

2017Section 2018.020 declares: 'It is the policy of the state to do both of the following: [¶] (a) Preserve the rights of attorneys to prepare cases for trial with that degree of privacy necessary to encourage them to prepare their cases thoroughly and to investigate not only the favorable but the unfavorable aspects of those cases. [¶](b) *390 Prevent attorneys from taking undue advantage of their adversary's industry and efforts.' Toward that end, section 2018.030 provides: '(a) A writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discove

13
People v. Steskalgreen
cal · 2021 · cited in 2 California opinions naming this issue, 2024–2024
2 sentences

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332, 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332 , 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

12
Aerojet-General Corp. v. Transport Indemnity Insurancegreen
calctapp · 1993 · cited in 2 California opinions naming this issue, 2007–2021
2 sentences

2021The attorney work product privilege was not at issue, and the disclosure of the individuals with whom the Governor met could have revealed the Governor’s thought process, whereas Curtis has already disclosed Doe 1 is a plaintiffs’-side attorney he consulted to hone his trial strategy. 23 Transport Indemnity Insurance (1993) 18 Cal.App.4th 996, 1004 [name of independent insurance adjuster who had investigated a prior industrial accident at defendant’s facility was not protected work product]; but see City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 73 [compelled disclosure of the i

2007“Nor can ‘the identity and location of persons having knowledge of relevant facts’ be concealed under the attorney work product rule .... [Citation.]” (Aerojet, supra, 18 Cal.App.4th at p. 1004 .) The defendants claimed no prejudice to their case as a result of the witness’s disclosure.

12
State Compensation Insurance Fund v. WPS, Inc.green
calctapp · 1999 · cited in 2 California opinions naming this issue, 2017–2021
2 sentences

2021(Id. at pp. 817-818.) Rico describes the State Fund rule as “an objective standard” that asks “whether reasonably competent counsel, knowing the circumstances of the litigation, would have concluded the materials were privileged, how much review was reasonably necessary to draw that conclusion, and when counsel’s examination should have ended.” (Rico, at p. 818.) In State Fund, the Court of Appeal also addressed the circumstance where the materials do not “obviously” or “clearly” appear to be confidential or privileged: “[W]henever a lawyer ascertains that he or she may have privileged attorne

2017(State Fund, supra, 70 Cal.App.4th at p. 657 ; see Clark, supra, 196 Cal.App.4th at p. 48 .) The rule also is designed to discourage unprofessional conduct (State Fund, at p. 657), and it recognizes that “„[a]n attorney has an obligation not only to protect his client‟s interests but also to respect the legitimate interests of fellow members of the bar, the judiciary, and the administration of justice.‟”4 (Rico, supra, 42 Cal.4th at p. 818 ; see Clark, at p. 48; State Fund, at p. 657.) The parties point to different portions of the foregoing quote from State Fund as the standard for determinin

12
Ardon v. City of Los Angelesgreen
cal · 2016 · cited in 2 California opinions naming this issue, 2018–2018
12
Lasky, Haas, Cohler & Munter v. Superior Courtgreen
calctapp · 1985 · cited in 2 California opinions naming this issue, 2017–2017
12
Dowden v. Superior Courtgreen
calctapp · 1999 · cited in 2 California opinions naming this issue, 2009–2015
12
Williamson v. Superior Courtgreen
cal · 1978 · cited in 2 California opinions naming this issue, 2003–2003
12
Roberts v. Superior Courtgreen
cal · 1973 · cited in 2 California opinions naming this issue, 2003–2003
12
Aetna Casualty & Surety Co. v. Superior Courtgreen
calctapp · 1984 · cited in 1 California opinions naming this issue, 2024–2024
11
City of Petaluma v. Superior Court of Sonoma Countygreen
calctapp · 2016 · cited in 1 California opinions naming this issue, 2024–2024
11
Caldecott v. Superior Courtgreen
calctapp · 2015 · cited in 1 California opinions naming this issue, 2023–2023
11
Uber Techs., Inc. v. Google LLCgreen
calctapp5d · 2018 · cited in 1 California opinions naming this issue, 2023–2023
11
Teachers v. Chino Valley Unified Sch. Dist.green
calctapp5d · 2018 · cited in 1 California opinions naming this issue, 2023–2023
11
People v. Ledesmagreen
cal · 2006 · cited in 1 California opinions naming this issue, 2021–2021
11
TRIPLE a MACHINE SHOP, INC v. State of Californiagreen
calctapp · 1989 · cited in 1 California opinions naming this issue, 2021–2021
11
McDermott Will & Emery LLP v. Superior Court of Orange Countygreen
calctapp · 2017 · cited in 1 California opinions naming this issue, 2019–2019
11
Armenta v. Superior Courtgreen
calctapp · 2002 · cited in 1 California opinions naming this issue, 2017–2017
11
Clark v. Superior Courtgreen
calctapp · 2011 · cited in 1 California opinions naming this issue, 2017–2017
11

Distinguished, questioned or overruled (2)

CaseNegativeCited
Coito v. Superior Courtgreen
cal · 2012 · cited in 9 California opinions naming this issue, 2017–2026
2 sentences

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

2024Muehlstein & Co., Inc. (2009) 176 Cal.App.4th 969, 977 , quoting BP Alaska Exploration, Inc. v. Superior Court (1988) 199 Cal.App.3d 1240, 1253-1254, fn. 4 ; see Citizens for Ceres v. Superior Court (2013) 217 Cal.App.4th 889, 911 [“Work produced by an attorney’s agents and consultants, as well as the attorney’s own work product, is protected by the attorney work product doctrine.”].) Work product protection applies when an attorney acts in a litigation or “nonlitigation legal capacity.” (Rumac, Inc. v. Bottomley (1983) 143 Cal.App.3d 810, 815-816 .) Further, “the work product privilege is not

19
City of Long Beach v. Superior Courtgreen
calctapp · 1976 · cited in 5 California opinions naming this issue, 1990–2021
2 sentences

2021The attorney work product privilege was not at issue, and the disclosure of the individuals with whom the Governor met could have revealed the Governor’s thought process, whereas Curtis has already disclosed Doe 1 is a plaintiffs’-side attorney he consulted to hone his trial strategy. 23 Transport Indemnity Insurance (1993) 18 Cal.App.4th 996, 1004 [name of independent insurance adjuster who had investigated a prior industrial accident at defendant’s facility was not protected work product]; but see City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 73 [compelled disclosure of the i

1993(City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 73 [ 134 Cal.Rptr. 468 ], quoting Code Civ.

15

Also cited on this issue (32)

CaseCitedYears
Kallen v. Delug green
calctapp · 1984
2 sentences

2026“The law is clear that ‘an attorney’s work product belongs absolutely to the client.’ [Citation.]” (John F. Matull & Associates, Inc. v. Cloutier (1987) 194 Cal.App.3d 1049, 1056 .) This principle applies even if “the attorney has [not] been paid for his [or her] services [citation].” (Kallen v. Delug (1984) 157 Cal.App.3d 940, 950 .) Water District clearly established its “ownership or right to possession of personal property [the Reports].” (Fremont Indemnity, supra, 148 Cal.App.4th at p. 119 .) 35 Eisenberg, however, argues at length that Water District did not satisfy this element of conve

2025“The law is clear that ‘an attorney’s work product belongs absolutely to the client.’ [Citation.]” (John F. Matull & Associates, Inc. v. Cloutier (1987) 194 Cal.App.3d 1049, 1056 .) This principle applies even if “the attorney has [not] been paid for his [or her] services [citation].” (Kallen v. Delug (1984) 157 Cal.App.3d 940, 950 .) Water District clearly established its “ownership or right to possession of personal property [the Reports].” (Fremont Indemnity, supra, 148 Cal.App.4th at p. 119 .) 33 Eisenberg, however, argues at length that Water District did not satisfy this element of conve

31985–2026
Costco Wholesale Corp. v. Superior Court green
cal · 2009
2 sentences

2024Prior to disclosing the reports and investigative materials, and upon a preliminary showing under Code of Civil Procedure section 2018.030, subdivision (a), the trial court may conduct an in camera review of the materials to determine “if some protection is warranted notwithstanding the waiver [of the attorney-client privilege].” (See Costco Wholesale Corp. v. Superior Court (2009) 47 Cal.4th 725, 740 ; People v. Superior Court (Jones) (2021) 12 Cal.5th 348 , 366.) Upon completion of the review, the trial court shall disclose to Paknad any portions of the Smethurst investigations it deems to n

2016Code, § 952.) A confidential communication may include “a legal opinion formed and the advice given by the lawyer in the course of that relationship.” (Ibid.) In assessing whether a communication is privileged, the initial focus of the inquiry is on the “dominant purpose of the relationship” between attorney and client and not on the purpose served by the individual communication. ( Costco, supra, 47 Cal.4th at pp. 739–740.) If a court determines that communications were made during the course of an attorney-client relationship, the communications, including any reports of factual material, wo

32016–2024
In Re Jeanette H. green
calctapp · 1990
2 sentences

1996(Rule 1420(a), (c), (e), (g), (h).) "The court is instructed under the rules to give substantial weight to the juvenile's need for stability and prompt resolution of custody status. [Citation.] The need for expeditious handling of juvenile matters is thus recognized and statutorily mandated. . . ." ( In re Jeanette H., supra, 225 Cal.App.3d at p. 36 .) (4) Preliminarily, we question whether the legitimate purposes intended by the attorney work product doctrine would be served by allowing Tina's counsel to invoke that doctrine under the circumstances here.

1996(Rule 1420(a), (c), (e), (g), (h).) “The court is instructed under the rules to give substantial weight to the juvenile’s need for stability and prompt resolution of custody status. [Citation.] The need for expeditious handling of juvenile matters is thus recognized and statutorily mandated. . . .” (In re Jeanette H., supra, 225 Cal.App.3d at p. 36 .) Preliminarily, we question whether the legitimate purposes intended by the attorney work product doctrine would be served by allowing Tina’s counsel to invoke that doctrine under the circumstances here.

31992–1996
Fremont Indemnity Co. v. Fremont General Corp. green
calctapp · 2007
2 sentences

2026“The law is clear that ‘an attorney’s work product belongs absolutely to the client.’ [Citation.]” (John F. Matull & Associates, Inc. v. Cloutier (1987) 194 Cal.App.3d 1049, 1056 .) This principle applies even if “the attorney has [not] been paid for his [or her] services [citation].” (Kallen v. Delug (1984) 157 Cal.App.3d 940, 950 .) Water District clearly established its “ownership or right to possession of personal property [the Reports].” (Fremont Indemnity, supra, 148 Cal.App.4th at p. 119 .) 35 Eisenberg, however, argues at length that Water District did not satisfy this element of conve

2025“The law is clear that ‘an attorney’s work product belongs absolutely to the client.’ [Citation.]” (John F. Matull & Associates, Inc. v. Cloutier (1987) 194 Cal.App.3d 1049, 1056 .) This principle applies even if “the attorney has [not] been paid for his [or her] services [citation].” (Kallen v. Delug (1984) 157 Cal.App.3d 940, 950 .) Water District clearly established its “ownership or right to possession of personal property [the Reports].” (Fremont Indemnity, supra, 148 Cal.App.4th at p. 119 .) 33 Eisenberg, however, argues at length that Water District did not satisfy this element of conve

22025–2026
John F. Matull & Associates, Inc. v. Cloutier green
calctapp · 1987
2 sentences

2026“The law is clear that ‘an attorney’s work product belongs absolutely to the client.’ [Citation.]” (John F. Matull & Associates, Inc. v. Cloutier (1987) 194 Cal.App.3d 1049, 1056 .) This principle applies even if “the attorney has [not] been paid for his [or her] services [citation].” (Kallen v. Delug (1984) 157 Cal.App.3d 940, 950 .) Water District clearly established its “ownership or right to possession of personal property [the Reports].” (Fremont Indemnity, supra, 148 Cal.App.4th at p. 119 .) 35 Eisenberg, however, argues at length that Water District did not satisfy this element of conve

2025“The law is clear that ‘an attorney’s work product belongs absolutely to the client.’ [Citation.]” (John F. Matull & Associates, Inc. v. Cloutier (1987) 194 Cal.App.3d 1049, 1056 .) This principle applies even if “the attorney has [not] been paid for his [or her] services [citation].” (Kallen v. Delug (1984) 157 Cal.App.3d 940, 950 .) Water District clearly established its “ownership or right to possession of personal property [the Reports].” (Fremont Indemnity, supra, 148 Cal.App.4th at p. 119 .) 33 Eisenberg, however, argues at length that Water District did not satisfy this element of conve

22025–2026
People v. Stevens green
cal · 2007
2 sentences

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332, 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332 , 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

22024–2024
People v. Lewis green
cal · 2001
2 sentences

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332, 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

2024“We have long held that a prosecutor may make ‘ “comments based upon the state of the evidence or upon the failure of the defense to introduce material evidence or to call anticipated witnesses.” ’ ” (People v. Steskal (2021) 11 Cal.5th 332 , 351 (Steskal); see People v. Gonzales (2012) 54 Cal.4th 1234, 1275 (Gonzales); People v. Stevens (2007) 41 Cal.4th 182, 210 ; People v. Lewis (2001) 25 Cal.4th 610, 670 .) Such comments do not invade the attorney work product privilege.

22024–2024
Brady v. Maryland green
scotus · 1963
22018–2018
Coalition of Concerned Communities, Inc. v. City of Los Angeles green
cal · 2004
22017–2017
National Steel Products Co. v. Superior Court green
calctapp · 1985
21988–2003
Kizer v. Sulnick green
calctapp · 1988
21991–2003
Wardius v. Oregon green
scotus · 1973
21992–1992
Marken v. Santa Monica-Malibu Unified School District green
calctapp · 2012
12023–2023
International Federation of Professional & Technical Engineers, Local 21 v. Superior Court green
cal · 2007
12023–2023
League of California Cities v. Superior Court green
calctapp · 2015
12022–2022
People Ex Rel. Deparment of Corporations. v. Speedee Oil Change Systems, Inc. green
cal · 1999
12022–2022
DP Pham LLC v. Cheadle green
calctapp · 2016
12022–2022
Maldonado v. Superior Court green
cal · 2012
12021–2021
SCEcorp v. Superior Court green
calctapp · 1992
12020–2020
Joyce v. Simi Valley Unified School District green
calctapp · 2003
12020–2020
Venhaus v. Shultz green
calctapp · 2007
12020–2020
Korea Supply Co. v. Lockheed Martin Corp. green
cal · 2003
12020–2020
Tucker Ellis LLP v. Superior Court of City & Cnty. of S.F. green
calctapp5d · 2017
12020–2020
D. I. Chadbourne, Inc. v. Superior Court green
cal · 1964
12017–2017
People v. Superior Court green
cal · 2001
12017–2017
California Oak Foundation v. County of Tehama green
calctapp · 2009
12013–2013
Roberts v. City of Palmdale green
cal · 1993
12013–2013
Landry v. Berryessa Union School District green
calctapp · 1995
12013–2013
Titmas v. Superior Court green
calctapp · 2001
12013–2013
In Re Complex Asbestos Litigation green
calctapp · 1991
12007–2007
Shadow Traffic Network v. Superior Court green
calctapp · 1994
12007–2007
Roland v. Superior Court green
calctapp · 2004
12006–2006

Statutes the citing opinions construe

CA § Cal. Evidence Code § 952 (11) CA § Cal. Evidence Code § 954 (11) CA § Cal. Penal Code § 187 (11) CA § Cal. Evidence Code § 912 (8) CA § Cal. Evidence Code § 951 (7) CA § Cal. Penal Code § 1054.6 (7) CA § Cal. Evidence Code § 352 (6) CA § Cal. Evidence Code § 915 (6) CA § Cal. Evidence Code § 1040 (4) CA § Cal. Evidence Code § 917 (4) CA § Cal. Penal Code § 1054 (4) CA § Cal. Penal Code § 190.2 (4)

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 72 (1979–2026) PA 37 (1973–2025) NY 31 (1984–2025) TX 27 (1990–2025) WA 15 (1981–2019) OH 13 (2006–2025) NJ 10 (1962–2024) MD 10 (1984–2021) CT 8 (1992–2011) CO 7 (1982–2020) LA 7 (1997–2025) NH 6 (1986–2025) IL 5 (1989–2007) FL 4 (2004–2018) VA 4 (1990–2005) VT 4 (1998–2025) IN 3 (1990–1997) SC 3 (2010–2016) NC 3 (2000–2012) MS 3 (1992–2010) MA 3 (1996–2015) WI 2 (1988–2025) WV 2 (1996–2015) AK 2 (1968–1982) GA 2 (2013–2016) DC 2 (2005–2015) WY 2 (2014–2014) UT 2 (2001–2020) AZ 2 (1992–2023) KY 2 (2006–2020) MI 2 (1999–2025) DE 2 (2019–2026)

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.

← Caselaw search · G Cite Topics · Brief Check