Gray v. St. Martins Press

District Court, D. New Hampshire·Decided June 2, 1998·No. CV-95-285-M·Published

Opinion

Gray v. St. Martins Press CV-95-285-M 06/02/98 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Robert K. Gray, Plaintiff

v. Civil No. 95-285-M

St. Martin's Press, Inc. and Susan Trento, Defendants

O R D E R

Plaintiff and defendants have moved the court to reconsider

certain aspects of a non-dispositive pretrial order entered by

the Magistrate Judge. Pursuant to 28 U.S.C. § 636(b)(1)(A), this

court's review of that order is highly deferential and the relief

reguested by the parties may be granted only if it is

demonstrated that the order is "clearly erroneous or contrary to

law." Id. See also Fed. R. Civ. P. 72(a).

Discussion

The parties to this defamation action have been embroiled in

numerous discovery disputes, reguiring the intervention of both

the Magistrate Judge and the undersigned. Their current

disagreements relate to certain aspects of the Magistrate Judge's

order dated September 30, 1997, which addressed many of the

outstanding discovery issues (the "Discovery Order") .

Defendants contend that the Magistrate Judge erred when he

ruled that New Hampshire's law of attorney-client privilege. rather than federal common law or the law of the Commonwealth of

Virginia, applies in this action. Plaintiff, on the other hand,

claims that the Magistrate Judge erred when he denied plaintiff's

motion to compel defendants to reveal the identities of

confidential sources used by Susan Trento in the course of

researching and writing The Power House, the publication at issue

in this action.

The parties do, however, share a modicum of common ground.

Perhaps not surprisingly, they agree that they disagree -- this

time with the Magistrate Judge. Specifically, they join in

asserting that the Magistrate Judge erred when he concluded that

"the parties agreed in oral argument that the suit was brought

under New Hampshire's defamation laws." Discovery Order at 6.

Both plaintiff and defendants say that they had made no such

concession and, in fact, claim that neither party had briefed or

even addressed the issue.

In light of the parties' agreement on this issue, to the

extent that the Magistrate Judge ruled that New Hampshire

defamation law governs plaintiff's substantive claims, the court

holds that such a conclusion was premature. While the court may

eventually conclude that New Hampshire law governs plaintiff's

state law claims, the court will afford the parties the

opportunity to brief the issue before rendering any decision.

That portion of the Discovery Order is, therefore, vacated.

2 I. Attornev-Client Privilege.

The Magistrate Judge ruled that, under Rule 501 of the

Federal Rules of Evidence, New Hampshire's privilege law governs

claims of privilege asserted by defendants in this action.

Discovery Order at 6-7. He then concluded that under New

Hampshire's law, defendants' assertions of attorney-client

privilege must fail.

Defendants have also asserted a joint or common interest privilege, which in New Hampshire is found at Rule 502 (b) (3) . Defendants have alleged all the ingredients of a joint defense privilege but one; at the time of the communications at issue they had no "pending action." The implicit threat in the Baine letter may have motivated the communications at issue. However, Rule 502(b)(3) does not refer to possible or likely actions, and the defendants have made no argument that pending action means anything but filed action.

Discovery Order at 10-11.

Defendants assert that the "pending action" element of New

Hampshire's common interest privilege is immaterial in the

present case. They contend that because their defense is based

upon principles of federal law (i.e., the First Amendment), Rule

501 of the Federal Rules of Evidence reguires the court to apply

the federal common law of privilege, rather than New Hampshire's

privilege law. And, because federal common law relating to the

common interest privilege does not contain a "pending action"

element, defendants claim to have carried their burden and

demonstrated that the privilege applies. The court disagrees.

3 While defendants may well invoke constitutional principles

articulated by the Supreme Court in New York Times Co. v.

Sullivan, 376 U.S. 254 (1964), their defense(s) to plaintiff's

state law defamation claims will necessarily be based upon state

law (as constrained by constitutional principles). Accordingly,

the Magistrate Judge properly concluded that Rule 501 of the

Federal Rules of Evidence reguires the court to apply state,

rather than federal, law of privilege to this matter. Rule 501

provides, in pertinent part, that:

[I]n civil actions and proceedings, with respect to an element of a claim or defense as to which State law supplies the rule of decision, the privilege of a witness, person, government. State, or political subdivision thereof shall be determined in accordance with State law.

Fed. R. Evid. 501 (emphasis supplied). Thus, Rule 501 states the

general rule that in diversity cases, such as this, the

applicability and scope of privileges are determined in

accordance with state law.

Having concluded that state, rather than federal, law

governs resolution of this dispute concerning defendants'

invocation of the attorney-client privilege, the court must next

determine which state law applies. Again, however, the parties

disagree. Plaintiff contends that the Magistrate Judge properly

concluded that New Hampshire's law of attorney-client privilege

applies. Defendants, on the other hand, assert that if state

4 rather than federal law governs the parties' discovery dispute,

the court should apply the law of Virginia.

At a hearing held on September 4, 1997, the Magistrate Judge

stated that "my inclination is to conclude from [the cases

previously discussed] that the privileges to be applied here are

state privileges and not federal privileges." (Tr. at 23) .1 The

Magistrate Judge then added that if New Hampshire's law of

privilege governs the parties' discovery dispute, the materials

sought by plaintiff are not protected by the so-called joint

enterprise or common interest privilege. Counsel for defendant

agreed, stating "I think that's right if New Hampshire law

applies." (Tr. at 25). In light of that concession, counsel for

defendants vigorously argued that federal, rather than state, law

governed the scope and application of the privilege at issue.

Importantly, prior to filing the pending motion to

reconsider the Magistrate Judge's order, defendants never argued

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