Gilbert v. National Corp. for Housing Partnerships

84 Cal. Rptr. 2d 204, 71 Cal. App. 4th 1240, 99 Cal. Daily Op. Serv. 3121, 99 Daily Journal DAR 4019, 1999 Cal. App. LEXIS 375
CourtCalifornia Court of Appeal
DecidedApril 29, 1999
DocketA080116
StatusPublished
Cited by19 cases

This text of 84 Cal. Rptr. 2d 204 (Gilbert v. National Corp. for Housing Partnerships) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gilbert v. National Corp. for Housing Partnerships, 84 Cal. Rptr. 2d 204, 71 Cal. App. 4th 1240, 99 Cal. Daily Op. Serv. 3121, 99 Daily Journal DAR 4019, 1999 Cal. App. LEXIS 375 (Cal. Ct. App. 1999).

Opinion

Opinion

McGUINESS, P. J.

On the eve of trial, the trial court disqualified appellant Eloise Gilbert’s attorney because of a conflict of interest created by his simultaneous representation of her and other clients in a different case. The trial court found that in attempting to advance appellant’s interests by calling one or more of his other clients as witnesses in appellant’s case, the attorney risked harming his other clients’ interests in violation of the terms of a settlement agreement he had negotiated in the other case. Appellant now contends that by disqualifying her attorney, the trial court denied her due process and a fair hearing. We conclude the trial court was within its broad discretion and acted appropriately to maintain ethical standards of professional responsibility and to preserve public trust in the administration of justice and the integrity of the bar. We therefore affirm.

I. Factual and Procedural Background

In the summer of 1994, Edwin “Teddy” Franklin and three other maintenance supervisors employed by respondent National Corporation for Housing Partnerships (NHP) retained the Law Offices of Robert H. Blumenthal *1244 (appellant’s attorney) to file a complaint against NHP alleging unequal pay, racial harassment and discrimination in the workplace. In response to demand letters from appellant’s attorney, NHP proposed that the dispute be resolved through private mediation. The parties selected a mediator through the American Arbitration Association.

Prior to mediation, appellant’s attorney requested certain personnel information from respondent NHP. In response, NHP provided confidential information on the NHP salary structure and the race of individual NHP employees. NHP provided this information on the express conditions that it was “for the sole purpose of the mediation,” and that “[t]he California Evidence Code with respect to confidentiality will be adhered to.” 1 (Italics in original.)

The parties proceeded to mediation, in which appellant’s attorney successfully negotiated a settlement with NHP on behalf of Franklin and his coemployees. The mediator drafted a “Memorandum of Agreement” (MOA) setting forth the essential terms of the settlement. Among other things, the MOA provided that the complaining employees would receive payments for personal injuries and their salaries would be adjusted upward. The MOA *1245 included a statement that “[s]aid payments shall not constitute an admission of any wrongdoing by [NHP] but are solely made to avoid costly and time-consuming litigation,” and provided that “[t]he terms of this MOA and of the final settlement agreement to be executed within 7 days are to be kept strictly confidential by all parties.” Each of the four complaining NHP employees signed the MOA, as did appellant’s attorney.

Pursuant to the MOA, the parties prepared four separate settlement agreements (the Settlement Agreement), one for each of the four complaining employees. Each Settlement Agreement contained substantively the same provisions, including a confidentiality clause (the Confidentiality Clause) stating: “The parties agree to keep the fact of this Settlement and this Agreement, and each of its terms, strictly confidential. This provision does not apply to discussions between the Employee and his counsel, the Law Offices of Robert Henry Blumenthal.” Immediately following this Confidentiality Clause in the text of each Settlement Agreement was a penalty clause (the Penalty Clause) stating: “The Employee agrees that in the event of a breach by him of the confidentiality provision of the preceding paragraph, then the Employer [NHP] shall be entitled to recover from the Employee the amounts paid under . . . this Agreement, together with costs, expenses and attorney’s fees associated with enforcement of the Agreement.” All four of the employees represented by appellant’s counsel signed individual Settlement Agreements containing this same Confidentiality Clause and Penalty Clause. In October 1994, appellant’s attorney requested final executed copies of each Settlement Agreement, “along with four checks payable to Robert Blumenthal and the respective Claimant.”

In April 1995, Attorney Blumenthal sent a letter to counsel for NHP stating that he represented appellant, “another employee of NHP . . . , who has a discrimination claim of underpayment similar to the claims of Edwin Franklin and others, which was settled last year, ffl] If you are authorized to act in this case, I would like to proceed with settlement negotiations.” (Italics added.)

Appellant was terminated from her employment at NHP in June 1995. On July 21, 1995, she filed a complaint for damages against NHP, alleging wrongful termination, discrimination in promotion and pay based on race and age, and retaliation for filing administrative complaints under the California Fair Employment and Housing Act (Gov. Code, § 12900 et seq.) (FEHA). On NHP’s motion for summary judgment or summary adjudication, the trial court denied summary judgment but granted summary adjudication as to appellant’s causes of action for discrimination based on unequal pay and failure to promote, breach of an implied contract of continued employment, and breach of the implied covenant of good faith and fair dealing. In *1246 the context of opposing these motions, appellant offered a declaration by Franklin alleging that NHP failed to pay salaries according to company guidelines for reasons based on racial discrimination and retaliation.

At the outset of trial on March 7, 1997, NHP moved in limine to exclude Franklin’s testimony on the ground any dispute he may have had with NHP had already been resolved pursuant to the confidential Settlement Agreement, and Franklin should not be permitted to testify about any matters made confidential by that Settlement Agreement. 2 In response to questions from the trial court, appellant’s attorney stated he intended to call Franklin to testify about complaints he had heard from other NHP employees and his own observation of alleged racial discrimination and harassment in the workplace environment; NHP’s failure to take action in response to complaints about this alleged discrimination and harassment; NHP’s alleged retaliatory actions against employees who took legal action; and NHP’s allegedly racially motivated failure to pay employees’ salaries in accordance with NHP’s own guidelines. 3 Because appellant wanted Franklin to testify even though Franklin might violate the Settlement Agreement’s Confidentiality Clause if he did so, the trial court expressed serious concern that *1247 appellant’s counsel had a conflict of interest in continuing to represent both of them. The court therefore requested further briefing on this issue. 4

In response, appellant submitted declarations by herself, Franklin, and her attorney. NHP submitted a formal motion to disqualify appellant’s counsel, supported by declarations and extensive briefing.

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Bluebook (online)
84 Cal. Rptr. 2d 204, 71 Cal. App. 4th 1240, 99 Cal. Daily Op. Serv. 3121, 99 Daily Journal DAR 4019, 1999 Cal. App. LEXIS 375, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gilbert-v-national-corp-for-housing-partnerships-calctapp-1999.