Emerson Electric v. Ouellette, et al.

CourtDistrict Court, D. New Hampshire
DecidedMay 12, 1998
DocketCV-96-364-B
StatusPublished

This text of Emerson Electric v. Ouellette, et al. (Emerson Electric v. Ouellette, et al.) 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
Emerson Electric v. Ouellette, et al., (D.N.H. 1998).

Opinion

Emerson Electric v. Ouellette, et a l . CV-96-364-B 05/12/98 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Emerson Electric C o .

v. Civil Action No. 96-364-B

Raymond R. Ouellette; Ouellette, Hallisey, Dibble & Tanguay, P.A.

MEMORANDUM AND ORDER

Emerson Electric Co., a manufacturer of electrical equip­

ment, retained attorney Raymond R. Ouellette of the law firm of

Ouellette, Hallisey, Dibble & Tanguay, P.A. (collectively the

"defendants") to represent Emerson in a product liability case.

After the jury in that case found Emerson liable, Emerson brought

this action asserting that Ouellette was negligent in preparing

Emerson's defense. In response, defendants sought discovery of

certain communications involving Emerson's in-house and post­

verdict counsel. Emerson declined to comply, arguing that the

communications are privileged. The magistrate judge, however,

granted defendants' motion to compel the desired discovery and

subsequently denied Emerson's motion for reconsideration. Emerson now asks that I set aside the magistrate judge's order,

asserting that he erred: (1) in interpreting certain New

Hampshire evidentiary principles to exclude the communications at

issue from the attorney-client privilege; and (2) in finding,

alternatively, that Emerson waived the privilege by failing to

serve defendants with a privilege log pursuant to Fed. R. Civ. P.

26 (b) (5) .

I. BACKGROUND

In the suit underlying the instant action, developer CMB

Construction Co. sued Emerson and another party, Weil-McLain,

Inc., for manufacturing defective heating systems. Emerson made

the igniters and Weil-McLain the overall heating systems for The

Links, a CMB Construction condominium development in Lincoln, New

Hampshire. In December 1988 and January 1989, the heating

systems in several condominiums failed. Pipes froze and burst

causing extensive damage to half the condominium units. Repairs

were not completed until May 1989, after the prime winter-selling

season had ended. Although CMB Construction sold all the damaged

units the next winter, it could not command the same sales price

for the units that it had during the winter of 1988-89 because of

changed market conditions. CMB Construction sought to recover its economic losses and repair costs in its suit against Emerson

and Weil-McLain.

Emerson's assistant general counsel, Michael Keating,

retained Ouellette and his firm to prepare what proved to be an

unsuccessful defense. The jury returned a verdict against both

Emerson and Weil-McLain, finding Emerson liable for repair costs

and $1.4 million in economic-loss damages. Emerson retained new

counsel, James Crawford, to work with Ouellette in arguing

Emerson's post-verdict motions. After the court entered final

judgment against Emerson, it unsuccessfully appealed the decision

represented by Crawford alone.

Emerson argues in the instant action that Ouellette failed

to adeguately address the issue of economic-loss damages at trial

and failed to preserve crucial issues for consideration on

appeal. In response, defendants have sought to discover

Emerson's post-verdict communications with Crawford and any post­

verdict communications between Keating and other Emerson

employees.1 Defendants assert that such discovery will help them

establish that Emerson failed to take reasonable steps to avoid

1 Defendants also sought to discover communications between Emerson and Weil-McLain and between Weil-McLain and Crawford. Emerson does not challenge the magistrate judge's rulings with respect to these communications.

- 3 - or limit its damages on appeal, and that its appellate counsel's

negligence was a superseding cause of Emerson's injuries.

Emerson has declined both to produce the reguested communi­

cations and to allow Keating and Crawford to testify about them,

asserting that communications between Keating or Crawford and any

Emerson employees taking place after June 7, 1994 (the date of

the jury verdict) are protected by the attorney-client privilege.

The magistrate judge disagreed, interpreting certain New

Hampshire evidentiary principles to exclude the communications

from the attorney-client privilege. Alternatively, the

magistrate judge found that Emerson waived the privilege by

failing to serve defendants with a privilege log, pursuant to

Fed. R. Civ. P. 26(b)(5), describing how each communication at

issue was privileged.

II. STANDARD OF REVIEW

Emerson asks me to set aside the magistrate judge's order

granting defendants' motion to compel discovery. A district

court's review of discovery-related decisions made by a

magistrate judge is governed by Fed. R. Civ. P. 72(a), which

provides: "'The district judge to whom the case is assigned shall

consider such objections and shall modify or set aside any portion of the magistrate judge's order found to be clearly

erroneous or contrary to law.'" Weeks v. Samsung Heavy Indus.

C o ., 126 F.3d 926, 943 (7th Cir. 1997) (guoting Fed. R. Civ. P.

72(a)); accord 28 U.S.C.A. § 636(b) (1) (A) (West 1993); see also

Commodity Futures Trading Comm'n v. Standard Forex, Inc., 882 F.

Supp. 40, 42 (E.D.N.Y 1995) (stating that pre-trial matters

involving discovery, even of privileged materials, are subject to

clearly-erroneous or contrary-to-law standard).

Pursuant to this highly deferential standard, a magistrate

judge is afforded broad discretion in resolving discovery

disputes, and reversal is ordinarily appropriate only if that

discretion is abused. Commodity Futures Trading Comm'n, 882 F.

Supp. at 42; Ellison v. American Nat'l Red Cross, 151 F.R.D. 8,

9-10 (D.N.H. 1993). When the determination in dispute is purely

legal, however, the district court exercises plenary review. See

Cooter & Cell v. Hartmarx Corp., 496 U.S. 384, 402 (1990)

(reviewing court may set aside findings based on "incorrect view

of relevant law"), superseded by rule on other grounds as stated

in Photocircuits Corp. v. Marathon Agents, Inc., 162 F.R.D. 449,

452 (E.D.N.Y. 1995); Mace v. Van Ru Credit Corp., 109 F.3d 338,

340 (7th Cir. 1997) (pure legal determinations reviewed de novo);

United States v. Adlman, 68 F.3d 1495, 1499, 1502 (2d Cir. 1995) (abuse of discretion found where court applied incorrect legal

standard in deciding whether to allow discovery of attorney "work

product"). Similarly, in considering mixed guestions of law and

fact, where the meaning of an applicable legal principle is in

dispute, "the reviewing court is not bound by the clearly

erroneous standard," but has a "duty to look carefully" at the

findings to "detect infection from legal error." LoVuolo v.

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