Delgado v. City of Portland

CourtDistrict Court, D. Oregon
DecidedOctober 11, 2024
Docket3:23-cv-00529
StatusUnknown

This text of Delgado v. City of Portland (Delgado v. City of Portland) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Delgado v. City of Portland, (D. Or. 2024).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

SKYLER DELGADO, in his capacity as C ase No. 3:23-cv-529-AR personal representative of the Estate of Robert Delgado, and ROBERT DELGADO, OPINION AND ORDER deceased,

Plaintiffs,

v.

CITY OF PORTLAND, ZACHARY DELONG, and JOHN DOES 1-5,

Defendants. _____________________________________

ARMISTEAD, Magistrate Judge

Robert Delgado was shot and killed by Portland Police Officer Zachary DeLong in April 2021. Robert Delgado and his son, Skyler Delgado (as personal representative of his father’s estate), bring this action against the City of Portland, Delong, and unnamed defendants. They bring federal claims under 42 U.S.C. § 1983 for violations of the Fourth and Fourteenth

Page 1 – OPINION AND ORDER Amendments to the United States Constitution, as well as state-law claims for battery and wrongful death. (Compl., ECF No. 1.) Skyler Delgado was named personal representative of his father’s estate on July 30, 2021. After that appointment, he attended meetings with prospective attorneys and eventually engaged the Oregon Justice Resource Center to represent him. Both before and after he engaged counsel to represent him, Skyler Delgado attended meetings with attorneys during which his aunt, Tina Delgado (Robert Delgado’s sister), was present. Now before the court is defendants’ motion to compel testimony about the substance of any conversations between Skyler Delgado and his attorneys while Tina Delgado was present, as

well as any conversations between Tina Delgado and attorneys regarding her brother’s death. For the reasons explained below, defendants’ motion is GRANTED IN PART and DENIED IN PART. LEGAL STANDARD Federal privilege law applies in federal question cases, including with respect to pendent state law claims. Agster v. Maricopa County, 422 F.3d 836, 839 (9th Cir. 2005); see also Fed. R. Evid. 501, Advisory Committee Notes. Accordingly, the court looks first to federal common law to resolve a privilege dispute, but may also look to state privilege law “if it is enlightening.” Tennenbaum v. Deloitte & Touche, 77 F.3d 337, 340 (9th Cir. 1996).

In the Ninth Circuit, an eight-part test determines whether information is covered by attorney-client privilege: (1) Where legal advice of any kind is sought (2) from a professional legal adviser in his capacity as such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his instance permanently protected (7)

Page 2 – OPINION AND ORDER from disclosure by himself or by the legal adviser, (8) unless the protection be waived. United States v. Ruehle, 583 F.3d 600, 607 (9th Cir. 2009). “The burden is on the party asserting the privilege to establish all the elements of the privilege.” United States v. Martin, 378 F.3d 988, 999–1000 (9th Cir.2002). DISCUSSION Defendants ask this court to resolve two issues: (1) Did Skyler Delgado waive the privilege as to communications with attorneys when his aunt, Tina Delgado, was present? (2) Are Tina Delgado’s communications with the estate’s attorneys privileged? (Def.’s Mot. at 1, ECF No. 25.) A. Did Skyler Delgado Waive Privilege? The court first considers whether Skyler Delgado waived attorney-client privilege by meeting with attorneys while his aunt was present. A waiver by voluntary disclosure occurs when a party discloses privileged information to a third party who is not bound by the privilege. Bittaker v. Woodford, 331 F.3d 715, 719 & n.4 (9th Cir. 2003). “One of the elements

that the [party asserting privilege] must prove is that it has not waived the privilege.” Weil v. Investment/Indicators, Rsch. & Mgmt., Inc., 647 F.2d 18, 24 (9th Cir. 1980). “Because it ‘impedes the full and free discovery of the truth, the attorney-client privilege is strictly construed’ and ‘applies only where necessary to achieve its purpose.’” Montgomery v. eTreppid Techs., LLC, 548 F. Supp. 2d 1175, 1178 (D. Nev. 2008) (quoting United States v. Talao, 222 F.3d 1133, 1140 (9th Cir. 2000)). That is, the privilege applies “only to those disclosures necessary to obtain informed legal advice which might not have been made absent the privilege.” Fisher v. United States, 425 U.S. 391, 403 (1976). In determining whether a

Page 3 – OPINION AND ORDER waiver has occurred, the court must examine whether recognizing a waiver would undermine the purpose of attorney-client privilege to “encourage full and frank communication between attorneys and their clients.” In re Pac. Pictures Corp., 679 F.3d 1121, 1126-30 (9th Cir. 2012). Neither party points to Ninth Circuit case law addressing whether a family member’s attendance at attorney-client meetings constitutes a waiver of attorney-client privilege, and the court has found none. Accordingly, the court considers Ninth Circuit precedent to the extent it is instructive, as well as federal common law from outside this circuit, and state law that the court finds “enlightening.” After doing so, the court concludes that Tina Delgado’s attendance at meetings between Skyler Delgado and attorneys does not constitute waiver of attorney-client

privilege. Although federal cases are inconsistent in recognizing waiver of attorney-client privilege when a family member attends attorney-client meetings, see 1 MCCORMICK ON EVID. § 91 (8th ed. 2022) (collecting cases), this court is persuaded by the line of cases that has recognized that “While . . . the presence of a third party commonly destroys [attorney-client] privilege, it does so only insofar as it is indicative of the intent of the parties that the communication not be confidential.” Kevlik v. Goldstein, 724 F.2d 844, 849 (1st Cir. 1984) (holding that client’s father’s presence in attorney-client meetings did not waive privilege). That reasoning, as applied in this context, aligns with the Ninth Circuit’s practice of focusing its analysis of privilege and

waiver on the purpose of the attorney-client privilege. See Pac. Pictures Corp., 679 F.3d at 1126- 30. There is no indication that Skyler Delgado intended, by attending meetings with his aunt, that his discussions with attorneys would not be confidential. Instead, the facts suggest that Tina Delgado’s presence facilitated “disclosures necessary to obtain informed legal advice which

Page 4 – OPINION AND ORDER might not have been made absent the privilege.” Fisher, 425 U.S. at 403. To recognize a waiver in these circumstances would risk undermining the purpose of attorney-client privilege to “encourage full and frank communication between attorneys and their clients.” Pac. Pictures Corp., 679 F.3d at 1126. State law further supports the court’s conclusion.

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