Doe v. San Jose Unified School District Board

CourtDistrict Court, N.D. California
DecidedApril 21, 2022
Docket4:20-cv-02798
StatusUnknown

This text of Doe v. San Jose Unified School District Board (Doe v. San Jose Unified School District Board) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe v. San Jose Unified School District Board, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 FELLOWSHIP OF CHRISTIAN Case No. 20-cv-02798-HSG (VKD) ATHLETES, et al., 8 Plaintiffs, ORDER RE MARCH 7, 2022 DISPUTE 9 RE PLAINTIFF'S PRIVILEGE v. CLAIMS 10 SAN JOSE UNIFIED SCHOOL DISTRICT Re: Dkt. No. 159 11 BOARD OF EDUCATION, et al., Defendants. 12 13 The parties ask the Court to resolve a dispute concerning plaintiffs’ claim that that certain 14 communications between an employee of plaintiff Fellowship of Christian Athletes (“FCA”) and 15 employees of defendant San Jose Unified School District (“the District”) are privileged or 16 otherwise protected and not subject to discovery. The Court held a hearing on the matter on April 17 5, 2022. Dkt. No. 174. 18 For the reasons explained below, the Court concludes that items 1, 33, 35, 38, and 42 on 19 plaintiffs’ privilege log are not privileged or protected and must be produced. 20 I. BACKGROUND 21 Plaintiffs Fellowship of Christian Athletes (“FCA”) and two former student members of 22 the local chapter, Elizabeth Sinclair and Charlotte Klarke, have withheld from discovery five 23 email communications between FCA employee Rigo Lopez and three District employees, Marc 24 Cooper, Kristen Borup, and Scott Rudolph, all of whom are former faculty advisors to FCA clubs 25 at high schools within the District. Dkt. No. 159 at 3, 8. Plaintiffs do not dispute that the withheld 26 documents are responsive to defendants’ discovery requests. 27 Plaintiffs concede that Mr. Cooper, Ms. Borup, and Mr. Rudolph were employees of the 1 these District employees request that plaintiffs’ counsel represent them, and that no such 2 representation was ever undertaken. Plaintiffs say that they intended for the disputed 3 communications to be confidential; however, no plaintiff entered into any confidentiality 4 agreement (written or oral) with any of the District employees. Dkt. No. 174. According to the 5 parties, no claims have been made by or against any of the District employees concerning their 6 roles as former advisors to the FCA clubs, and no such claims were contemplated at the time each 7 of them participated in the disputed communications. Id. 8 At the Court’s direction (Dkt. No. 164), plaintiffs lodged the five disputed documents with 9 the Court for in camera review: privilege log items 1, 33, 35, 38, and 42. Per the undersigned’s 10 Standing Order, the Court considers only the discovery responses at issue (Exhibit A) and the 11 relevant privilege logs (Exhibits B-D). See Standing Order for Civil Cases, section 4. The Court 12 does not consider the parties’ correspondence or discovery requests and responses that are not at 13 issue in this dispute (Exhibits E-I). 14 II. LEGAL STANDARD 15 A. Attorney-Client Privilege and Work Product Doctrine 16 The attorney-client privilege protects from discovery communications concerning legal 17 advice sought from an attorney in his or her capacity as a professional legal advisor, where the 18 communication is made in confidence, is intended to be maintained in confidence by the client, 19 and is not disclosed to a third party. United States v. Sanmina Corp., 968 F.3d 1107, 1116 (9th 20 Cir. 2020). The privilege extends to a client’s confidential disclosures to an attorney in order to 21 obtain legal advice, as well as an attorney’s advice in response to such disclosures. United States 22 v. Ruehle, 583 F.3d 600, 607 (9th Cir. 2009) (citations and quotations omitted). “Because it 23 impedes full and free discovery of the truth, the attorney-client privilege is strictly construed.” Id. 24 The work product doctrine protects from discovery materials that are prepared by or for a 25 party or its representative in anticipation of litigation. Fed. R. Civ. P. 26(b)(3). Typically, the 26 doctrine provides qualified protection against discovery of the legal strategies and mental 27 impressions of a party’s attorney. Upjohn Co. v. United States, 449 U.S. 383, 390-91 (1981); 1 the protection where such disclosure is made to an adversary in litigation or where the disclosure 2 is made in a manner that substantially increases the opportunities for potential adversaries to 3 obtain the work product. Sanmina Corp., 968 F.3d at 1121. 4 The party asserting attorney-client privilege or work product protection bears the burden of 5 proving that the privilege or protection applies. See Ruehle, 583 F.3d at 607-08; In re Appl. of 6 Republic of Ecuador, 280 F.R.D. 506, 514 (N.D. Cal. 2012). 7 B. Common Interest Doctrine 8 The voluntary disclosure of a privileged or protected document or information to a third 9 party ordinarily waives that privilege or protection. Ruehle, 583 F.3d at 612; Weil v. 10 Inv./Indicators, Research & Mgmt., Inc., 647 F.2d 18, 25 (9th Cir. 1981). The “common interest” 11 or “joint defense” doctrine is an exception to ordinary waiver rules that applies when parties 12 represented by separate counsel communicate in confidence about a matter of common legal 13 interest, in furtherance of that common legal interest. See In re Pac. Pictures Corp., 679 F.3d 14 1121, 1129 (9th Cir. 2012). The doctrine does not create a privilege but comes into play only if a 15 privilege or protection already covers the material disclosed to the third party. Id.; see also Nidec 16 Corp. v. Victor Co. of Japan, 249 F.R.D. 575, 578-79 (N.D. Cal. 2007) (describing boundaries and 17 application of common interest doctrine). 18 III. DISCUSSION 19 According to their privilege log, plaintiffs assert that the disputed communications in items 20 1 and 33 are protected from disclosure by the attorney-client privilege and the work product 21 doctrine, and that items 35, 38, and 42 are protected from disclosure only by the attorney-client 22 privilege. See Dkt. No. 159-1 at 93-98. As to all five items, plaintiffs contend that the privilege or 23 protection is not waived because the three District employees who were parties to the 24 communications share a “common interest” with plaintiffs. Id. 25 A. Items 35, 38, and 42 26 The privilege log describes items 35 and 38 as “[e]mail[s] from M[arc] Cooper to R[igo] 27 Lopez” in which the participants are “[d]iscussing a matter of common legal interest and for 1 describes item 42 in similar terms as “[e]mails between M[arc] Cooper and R[igo] Lopez” in 2 which the participants are “[d]iscussing legal issue where the parties hare a common interest.” Id. 3 at 98. These descriptions are incomplete. The Court’s review of the documents lodged in camera 4 reveals that, in each of the disputed communications, Mr. Cooper (a District employee) forwarded 5 to Mr. Lopez a communication he received from either Jennifer Thomas (a Risk Manager for the 6 District), Tina VanLaarhoven (the principal of Willow Glen High School), or Kasmira Brough (an 7 attorney for the District). Plaintiffs’ privilege log omits this information. However, at the hearing 8 plaintiffs acknowledged that the District communications Mr. Cooper forwarded to Mr. Lopez are 9 not subject to any privilege held by plaintiffs. Instead, plaintiffs argue that the attorney-client 10 privilege applies to Mr. Cooper’s forwarding emails to Mr. Lopez, and to the fact that he 11 forwarded these specific District communications, because Mr. Cooper and FCA had a common 12 legal interest, and Mr. Lopez was FCA’s representative. Dkt. No. 159 at 9. 13 The common interest doctrine does not support this result.

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Upjohn Co. v. United States
449 U.S. 383 (Supreme Court, 1981)
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16 F.3d 929 (Eighth Circuit, 1994)
Jones v. Walgreen Co.
679 F.3d 9 (First Circuit, 2012)
United States v. Ruehle
583 F.3d 600 (Ninth Circuit, 2009)
United States v. Sanmina Corporation
968 F.3d 1107 (Ninth Circuit, 2020)
Edwards v. United States
249 F.R.D. 25 (D. Connecticut, 2008)
Nidec Corp. v. Victor Co. of Japan
249 F.R.D. 575 (N.D. California, 2007)
In re the Republic of Ecuador
280 F.R.D. 506 (N.D. California, 2012)

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Bluebook (online)
Doe v. San Jose Unified School District Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-v-san-jose-unified-school-district-board-cand-2022.