Laker Airways Ltd. v. Pan American World Airways

103 F.R.D. 22, 1984 U.S. Dist. LEXIS 15513, 1984 WL 306905
CourtDistrict Court, District of Columbia
DecidedJune 26, 1984
DocketCiv. A. Nos. 82-3362, 83-0416 and 83-2791
StatusPublished
Cited by36 cases

This text of 103 F.R.D. 22 (Laker Airways Ltd. v. Pan American World Airways) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Laker Airways Ltd. v. Pan American World Airways, 103 F.R.D. 22, 1984 U.S. Dist. LEXIS 15513, 1984 WL 306905 (D.D.C. 1984).

Opinion

OPINION

HAROLD H. GREENE, District Judge.

This is a motion to disqualify plaintiff’s counsel. Several of the defendants1 have cited various incidents in the past career of Donald A. Farmer, Esq. which they claim give rise to his disqualification from his current representation of Laker.2 There is no question that Farmer, both during his government service and in private practice, [27]*27has specialized in the areas of law involved in the instant lawsuit. He has also encountered or had contact with the parties to this lawsuit, both in a regulatory capacity and as a private attorney. One way to look at the issues raised by the motion would be to assume that with this kind of experience and specialization, there must be something in Farmer’s career to disqualify him now. But when his relationships are examined in detail, it becomes apparent that defendants’ charges do not require disqualification.3

I

Before discussing the specific facts, it is appropriate to relate some of the applicable policy considerations.

It is true, of course, that where there are conflicts of interest, the particular attorney or attorneys must be ordered disqualified. Conflicts of interest by attorneys give rise to many substantive evils (e.g., unfair advantage in litigation, neglect of duties to the client) and they tend to diminish the bar’s image in the mind of the public. But the mere claim of a conflict is not enough; there must be proof. Moreover, the Court must make its decision4 in the interest of justice to all concerned,5 and it must balance the need to ensure proper conduct on the part of lawyers appearing before it against the harm to other social interests which may ensue if disqualification is improvidently granted.6 There are several such competing interests in this case.

First. A litigant has a right to freely chosen, competent counsel.7 The protection of that right is particularly important in this case, where the attorneys sought to be disqualified have a unique and probably irreplaceable value to their client. Robert Beckman, one of the attorneys whose disqualification defendants seek (see note 2 supra), has served as Laker's counsel on all aviation matters in this country and most aviation matters worldwide for over ten years. Moreover, the subject matter of this lawsuit is quite specialized, and without Farmer and Beckman plaintiff would be dealt a significant, perhaps irreparable, setback. See also, note 80 infra.8

Second. Related to the interest in allowing plaintiff to proceed through its own counsel is the public interest in a speedy resolution of this lawsuit. See Black v. Missouri, supra, 492 F.Supp. at 873-74. The complaint alleges an international conspiracy among a number of foreign and domestic airlines in violation of the United States antitrust laws, and that conspiracy is claimed to have resulted ultimately in plaintiff’s financial collapse. The case may have important consequences both for the many American consumers of the services of transatlantic carriers and for Laker’s creditors. Despite the public interest in the expeditious resolution of this lawsuit, the action has already been charac[28]*28terized by extraordinary delay due to defendants’ litigation tactics. See, e.g., notes 78 and 79. Were the motion to disqualify to be granted, the resulting additional delay might well be crippling. In fact, defendants have requested that all work product prepared by counsel to date be withheld from substitute counsel, and that steps be taken to insulate disqualified counsel from any new counsel.

Third. The Court may appropriately consider an attorney’s right freely to practice his profession. Woods v. Covington County Bank, supra, 537 F.2d at 812. The judicial system benefits from attorneys who have a specialized expertise, for such attorneys bring to the process both experience and a special insight into those problems which are encountered within the areas of their expertise. Yet questions concerning conflict of interest are likely to arise more frequently when an attorney has a specialized practice, especially in an area as narrow as that in which Farmer has practiced, since the same parties and similar issues of law will frequently be encountered in subsequent lawsuits. A court must be careful not to penalize attorneys who chose such specialties, and it therefore should not order disqualification without carefully examining whether a genuine conflict exists.

Fourth. When the motion is based upon an attorney’s government service—as this motion is in primary part—a court must also be wary not to take action which will discourage other attorneys from entering government employ. As Judge Kaufman admonished in his seminal article, The Former Government Attorney and the Canon of Professional Ethics, 70 Harv.L.Rev. 657, 668 (1957):

If the Government service will tend to sterilize an attorney in too large an area of law for too long a time, or will prevent him from engaging in the practice of a technical specialty which he had devoted years in acquiring, and if that sterilization will spread to the firm with which he becomes associated, the sacrifice of entering government service will be too great for most men to make.

See also, Cutler, New Rule Goes Too Far, 63 A.B.A.J. 725 (1977).

Fifth. Disqualification motions “have become increasingly popular ‘tools of the litigation process, being used ... for purely strategic purposes.’ ” Rice v. Baron, 456 F.Supp. 1361, 1368 (S.D.N.Y.1978), quoting Allegaert v. Perot, 565 F.2d 246, 251 (2d Cir.1977). Accord Williamsburg Wax Museum v. Historic Figures, Inc., supra, 501 F.Supp. at 331. See also Part VI infra. Accordingly, courts have in recent years become more and more skeptical of motions to disqualify counsel, and they now approach them with cautious scrutiny.9

In its determination of the specific issues discussed below, the Court has considered these various policies in juxtaposition to the need to disqualify counsel who has a true conflict of interest.

II

Defendants’ primary challenge is based on Farmer’s prior government service, and in this regard they rely on Canon 9 of the D.C.Code of Professional Responsibility10 which states that “[a] lawyer should avoid even the appearance of professional impropriety,” and upon the Code’s Disciplinary Rule 9-101(B) (hereinafter generally referred to as the Disciplinary Rule) which implements Canon 9 and provides that:

A lawyer shall not at any time accept private employment in connection with any matter in which he or she participated personally and substantially as a public officer or employee, which includes acting on the merits of a matter in a judicial capacity.

[29]*29In support of their disqualification claim, defendants provide a laundry list of governmental proceedings in which Farmer was claimed to have been involved and which are said to be connected with this litigation.

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Cite This Page — Counsel Stack

Bluebook (online)
103 F.R.D. 22, 1984 U.S. Dist. LEXIS 15513, 1984 WL 306905, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laker-airways-ltd-v-pan-american-world-airways-dcd-1984.