Almond v. USDC - R.I.

CourtDistrict Court, D. New Hampshire
DecidedApril 18, 1994
DocketCV-93-19-B
StatusPublished

This text of Almond v. USDC - R.I. (Almond v. USDC - R.I.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Almond v. USDC - R.I., (D.N.H. 1994).

Opinion

Almond v . USDC - R.I. CV-93-19-B 04/18/94 P UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE Lincoln C . Almond, Edwin J. Gale and Michael Davitt v. Civil N o . C . 93-19-B (D.N.H.) CA. 92-0663 (D.R.I.) U.S. District Court for the District of Rhode Island, et a l .

O R D E R

Rhode Island Rule of Professional Conduct 3.8(f) requires

prosecutors to obtain judicial approval before subpoenaing

attorneys to give evidence "concerning a person who is or was

represented by the lawyer when such evidence was obtained as a

result of the attorney-client relationship." The rule was

originally adopted by the Rhode Island Supreme Court and later incorporated by reference into the local rules of the Federal

District Court for the District of Rhode Island. The United

States Attorney for the District of Rhode Island and two of his

assistants presently challenge the state and federal versions of

Rule 3.8(f) by suing the United States District Court for the

District of Rhode Island and its sitting judges (collectively the

"federal defendants"), and the Rhode Island Supreme Court, its

sitting justices and Rhode Island's Chief Disciplinary Counsel

(collectively the "state defendants"). The prosecutors seek declaratory and injunctive relief, alleging that the federal defendants lacked the power to adopt Rule 3.8(f) as a local federal rule because it (i) is inconsistent with Fed. R. Crim. P. 1 7 , and (ii) impermissibly infringes on the independence of the grand jury. They further contend that since the local rule cannot be enforced as a matter of federal law, the state defendants cannot enforce the state version of Rule 3.8(f) against federal prosecutors without violating the Supremacy Clause.1 The matter is before me on the parties' cross-motions for summary judgment.2

I. FACTS

A. Background

This case is the latest skirmish in an on-going battle between federal prosecutors and the criminal defense bar over the

1 Although neither version of Rule 3.8(f) differentiates between grand jury and trial subpoenas, the prosecutors challenge the two rules only to the extent that they require pre-service judicial review of subpoenas issued on the grand jury's behalf. I therefore consider the validity of the two rules only to the extent that they apply to grand jury subpoenas. 2 The Rhode Island Bar Association and the Rhode Island branch of the American Civil Liberties Union have submitted amicus briefs opposing the prosecutors' motion.

2 legitimacy of attorney subpoenas. Prior to 1980, prosecutors

rarely subpoenaed attorneys to testify about their clients. In

the 1980s, however, a rising crime rate and the growing

sophistication of many forms of criminal behavior prompted

federal prosecutors to employ new tactics in their "war" on

crime. Criminal conspiracy statutes passed in the 1970s were put

to new and more frequent uses; Max D. Stern & David A . Hoffman,

Privileged Informers: The Attorney Subpoena Problem and a

Proposal for Reform, 136 U . P a . L . Rev. 1783, 1787 & n.16 (1988)

(citing the Racketeer Influenced and Corrupt Organization Act,

Pub. L . 91-452, 84 Stat. 941 (1970) (codified at 18 U.S.C. §§

1961-68), and the Continuing Criminal Enterprise Act, Pub. L . 91-

513, 84 Stat. 1265 (1970) (codified at 21 U.S.C. § 848)); new

federal laws were passed to help prosecutors track the proceeds

of illegal activity and prosecute money launderers; House Committee on Government Operations, Federal Prosecutorial

Authority in a Changing Legal Environment: More Attention

Required, H . Rep. N o . 986, 101 Cong., 2d Sess., 22-23 (1990)

(citing 26 U.S.C. § 6050I and 18 U.S.C. § 1957); and Congress

allocated additional funds to hire more federal prosecutors, id.

at 1 . This renewed emphasis on law enforcement inevitably led to

closer scrutiny of attorneys as potential witnesses to criminal

3 conduct. Stern & Hoffman, supra, at 1787-88; see also David J.

Fried, Too High A Price For Truth: The Exception to the Attorney-

Client Privilege for Contemplated Crimes and Frauds, 64 N.C.L.

Rev. 443, 471-76 (1986).

The government's increased use of attorney subpoenas has

come under heavy fire from critics who argue that any

investigative rewards the government may reap by subpoenaing

attorneys come at the "direct expense of the attorney-client

relationship." United States v . Perry, 857 F.2d 1346, 1347 (9th

Cir. 1988). The perceived costs of such subpoenas include: the

"chilling effect" produced by the concern that a subpoenaed

attorney might betray his or her client's confidential

communications; the potential conflict of interest that could

result if an attorney were forced to testify against a client;

the diversion of the subpoenaed attorney's attention and resources to the "second front" which his or her new interest in

the investigation creates; and the Due Process and Sixth

Amendment concerns raised by the risk that the attorney might

eventually be disqualified from representing his or her client.

United States v . Klubock, 832 F.2d 649, 653-54 (1st C i r . ) ,

vacated, 832 F.2d 664 (1st Cir. 1987) (en banc), aff'g by equally

divided Court 639 F. Supp. 117 (D. Mass. 1986). In addition to

4 its costs, critics also argue that the attorney subpoena is too

often "a tool of prosecutorial abuse and . . . an unethical

tactical device US Attorneys employ to go on a 'fishing

expedition' with legal counsel without first pursuing alternative

avenues to get the information." Perry, 857 F.2d at 1347.

Responding to these concerns, the American Bar Association

(the "ABA") adopted a 1988 resolution designed to "limit[] the

issuance of attorney subpoenas in grand jury and other criminal

proceedings to those situations in which there is a genuine need

to intrude into the attorney-client relationship." ABA Standing

Committee on Ethics and Prof. Resp. and Criminal Justice Section,

Report to House of Delegates 1 (1988). The resolution created an

ethical rule that: (1) required pre-service judicial approval of

attorney subpoenas; (2) specified the standards a judge should

consider before approving an attorney subpoena; and (3) provided that this evaluation should take place in the context of an

adversary proceeding. Id. Following the ABA's lead, several

state and federal courts promptly devised disciplinary rules

requiring prosecutors to submit attorney subpoenas for similar

pre-service judicial approval. Baylson v . Disciplinary Board,

764 F. Supp. 3 2 8 , 331 (E.D. P a . 1991), aff'd, 975 F.2d 102

(1992), cert. denied, 113 S . C t . 1578 (1993). The Rhode Island

5 Supreme Court and the Federal District Court for the District of

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